Such is life, death, and injustice in a so-called sanctuary city like San Francisco and a sanctuary state like California. In addition, many major cities outside of those states—including Albuquerque, Boston, New Orleans, Newark, and Philadelphia—had been designated as sanctuary cities. The Center for Immigration Studies counts the number of sanctuary cities or counties across the country at more than 200. Not only does the sanctuary movement foment and incentivize illegal immigration, it also shields known violent predators from justice. Philadelphia formally adopted sanctuary city policies in 2014.