9 Whittier Law Review 683 (1987-1988)
The Sanctuary Movement

handle is hein.journals/whitlr9 and id is 693 raw text is: THE SANCTUARY MOVEMENT
MICHELE ALTEMUS*
TABLE OF CONTENTS
I.  INTRODUCTION  ........................................  683
II. HISTORICAL BACKGROUND ............................ 685
III. UNITED STATES IMMIGRATION LAW ................... 688
A. United Nations Protocol and Geneva Convention .. 688
B. Application of International Law to United States
Refugee Policy: The Refugee Act of 1980 .......... 691
1. Procedures for Asylum Under the 1980 Refugee
A ct  ...........................................  693
i.  Burden  of Proof ...........................  694
ii. Role of the Department of State ........... 697
iii. Problems With Immigration and
Naturalization Service ..................... 703
IV. SANCTUARY TRIALS ................................... 704
V.  RECOMMENDATIONS ...................................    715
VI.  CONCLUSIONS   .........................................  720
I. INTRODUCTION
As a nation of immigrants, many of whom fled oppression in their
homelands, the United States has a deeply rooted commitment to the
protection of victims and potential victims of persecution.' This com-
mitment to protect such people is embodied in the Refugee Act of
19802 and international treaties.' For various reasons, it has been
alleged that this commitment to safeguard the sanctity of human life
has not been justly extended to Salvadorans and Guatemalans.
* Michele Jan Altemus, B.A., U.S.C., 1983; J.D./M.A. U.S. Foreign Policy, The Ameri-
can University, 1987.
1. Note, The Right of Asylum U.S. Law, 80 COLUM L. REV. 1125 (1980).
2. See infra note 51.
3. See infra note 36.

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