On July 8, 2025, Alberto Rojas, the Bishop of San Bernardino, offered a dispensation to faithful in his diocese from the holy Catholic obligation of attending Mass. This dispensation extends to those who have genuine fear of immigration enforcement actions. This document is the first dispensation for reasons of immigration enforcement in U.S. history.
The dispensation is a consequence of the Trump Administration’s rescission of the sensitive locations memo, a document that since 1993 has limited immigration enforcement activity at places of worship. It was Trump’s first target in his gambit to renegotiate the boundaries of religion in America during his second term.
Such an undertaking, Trump argued, required divine authority. During his second inaugural address, Trump reminded the country of the failed assassination attempt he survived. “Just a few months ago, in a beautiful Pennsylvania field, an assassin’s bullet ripped through my ear. But I felt then and I believe even more so now that my life was saved for a reason. I was saved by God to make America great again.” His return to power is, in his telling, the will of God. His almost martyrdom gives him a holy mandate to zealously implement his vision of the country. With this self-proclaimed mandate, he could begin to reshape the limits of public religion in the U.S.
The foundation of Trump’s racialized vision for making America great again is the enactment of the largest deportation effort in U.S. history. Trump learned during his first term that there would be religious opposition to his deportation plans. Liberal religious actors and institutions have defended immigrants in the United States for decades. In the 1980s, congregations across the country declared themselves “sanctuaries” for Central American migrants who fled civil conflicts in their home countries and were being systemically denied asylum in the United States. These sanctuary communities provided refuge and legal support and called attention to the role of U.S. intervention in creating the conditions that Central American migrants were fleeing.
The sanctuary movement became a flashpoint in 1985 when sixteen people were indicted for crimes ranging from smuggling, harboring, and aiding and abetting illegal entry. These charges stemmed from their sanctuary work at Southside Presbyterian Church in Tucson, Ariz. The public nature of the trial backfired for the U.S. government. Americans were outraged at images of priests and pastors in court for living out their religious convictions. Perhaps more shocking to Americans was the fact that the INS had conducted undercover investigations during religious services inside of the church. A religious boundary had been trampled in the state’s overzealous effort to maintain control of the border.
“Just a few months ago, in a beautiful Pennsylvania field, an assassin’s bullet ripped through my ear. But I felt then and I believe even more so now that my life was saved for a reason. I was saved by God to make America great again.”
This was not the only time that immigration enforcement profaned this sacred boundary. One September morning in 1988, dozens of immigrants congregated on a sidewalk in Orange, Cal. They were jornaleros, or day laborers, looking for work. As they waited, unmarked vehicles approached the group. It was an immigration enforcement operation. Scared, the jornaleros scattered. Two men ran into La Pursima Catholic Church as morning Mass was ongoing.
The Border Patrol agents chased them inside the church sanctuary, where they found five other jornaleros. The agents detained the group in front of the priest and Mass-goers. Dozens protested INS’s desecration of the church. The Los Angeles Times ran an editorial arguing that the Border Patrol had “crossed a line” by entering La Pursima. An INS spokesperson responded cynically. “Our policy has not changed. We’re not going to churches and kicking down doors looking for illegal aliens…. But I am not going to say to our agents that if someone runs to any particular building, with a cross on it or not, that it’s olly olly oxen free.’”
The sense that the INS was crossing a line extended beyond religious spaces. In 1992, faculty and students at Bowie High School, located just yards from the border in El Paso, sued the Border Patrol due the agency’s ongoing harassment and violence on the school’s campus. That same year, the American Friends Service Committee published a report highlighting abusive INS practices and argued that the agency was committing human rights violations. The INS was also on the government’s radar. In 1991, the U.S. Government Accountability Office noted “serious problems” with agency operations, including financial mismanagement and lack of accountability.
With public pressure mounting on the INS, the agency published the first sensitive locations memo in 1993. This memo for the first time indicated in writing that it was INS policy to avoid immigration enforcement operations “on the premises of schools, places of worship, funerals and other religious ceremonies.” The memo, signed by acting INS Commissioner James Puleo, was not law. It was an internal document that guided how enforcement operations should be handled. As such, it could be rescinded at any moment. However, it was an acknowledgement (even if implicit) that the agency had indeed crossed a line at Southside, La Purisima, and Bowie High School. Its power lay in reflecting and affirming an American consensus that religious spaces should be set apart, not to be profaned by the worldly work of immigration enforcement. It was also a low hanging opportunity for the INS to show a reformist impetus at a time when the agency was facing increased public scrutiny.
The sensitive locations memo was updated multiple times in the intervening years, with the latest version signed in 2021 by Alejandro Mayorkas, DHS secretary during the Biden Administration. The heart of the policy remained the same through each iteration of the memo: immigration enforcement operations at schools, hospitals, and places of worship should be avoided.
The memo was a thorn on Trump’s side during his first presidency. Shortly after the 2016 election, hundreds of churches revived the legacy of the Sanctuary Movement and declared themselves sanctuaries for immigrants. Based on the logics of the sensitive locations memo, these sanctuary churches were a last line of defense for immigrants with final orders of removal.
Immigrants like Alex Garcia in St. Louis or Jeannette Vizguerra in Denver spent grueling years living inside of churches during the Trump Administration, unable to step outside without risking apprehension. As scholar of religion Barbara Sostaita noted, sanctuary during the first Trump Administration was experienced “as both safety and captivity, both refuge and confinement.” The religious boundary that kept ICE away from churches, however, held strong. The sensitive locations memo remained untouched.
Its power lay in reflecting and affirming an American consensus that religious spaces should be set apart, not to be profaned by the worldly work of immigration enforcement.
With a (supposed) mandate from God in hand, Trump set his aim on the memo early in his second term. In January, DHS rescinded the sensitive locations memo. A DHS spokesperson celebrated the directive. “This action empowers the brave men and women in CBP and ICE to enforce our immigration laws and catch criminal aliens—including murderers and rapists—who have illegally come into our country. Criminals will no longer be able to hide in America’s schools and churches to avoid arrest.” This was one of Trump’s first moves to forcefully renegotiate the boundary of what religion could do to slow his immigration enforcement strategies.
The consequences of this policy shift were quickly evident. Days after DHS announced the change, Wilson Rogelio Velasquez Cruz attended Sunday service at Iglesia Fuente de Vida in Tucker, Georgia. He received a call on his cell phone from immigration. Moments later, his ankle monitor (which ICE had placed on him) began to sound. He stepped outside of church to minimize the interruption, only to find that ICE agents were there waiting for him.
In June, there were two reports of ICE activity on the grounds of Catholic parishes in the Diocese of San Bernardino. These arrests followed Stephen Miller’s call for increased apprehensions. ICE emphasized that the arrests took place in the parking lot, not in the church sanctuary. Nonetheless, these widespread operations have left immigrant communities reeling, impacting even how they live their religious lives.
The Trump Administration’s assertion of state power in relation to churches who stand in the way of the administration’s immigration enforcement strategy is jarring, especially when contrasted with their approach during the pandemic. As the number of Covid-related deaths continued to rise in the spring of 2020, churches across the country prepared to return to in-person religious services, thus bucking local public health orders preventing large gatherings. William Barr, then attorney general, told a group of pastors that he would “absolutely” support churches that decided to reopen. “I think the intransigence on this makes me feel that undergirding some of this is really an animus against religion.” In this case, the administration sided with churches who rebelled against governmental policies. Today, Trump’s immigration enforcement policies are preventing people from attending church without fear.
Bishop Rojas’s dispensation responds to the social and political context of his flock. It is also a troubling consequence of Trump’s gambit to redefine the limits of religion in American public life. Trump is less invested in asserting the power of the secular state over the sacrality of religious spaces and more invested in defining what religion can and cannot do vis-à-vis his policy agenda. In Trump’s telling, God has spared his life to make American great, and therefore religion should not challenge or interfere with what he sees as his mission.