Busing & The Sanctuary City

Sanctuary cities demonstrated notable legal resilience during the first Trump administration, withstanding legal and political pressure aimed at dismantling their policies. That resilience, however, was undermined by Texas's busing program in 2022 and 2023 in ways that earlier legal and political attacks could not achieve. As this Article argues, busing succeeded not merely by imposing fiscal and logistical burdens, but by surfacing longstanding internal cleavages and ultimately fracturing the coalition that sustained the sanctuary movement. This Article advances a theoretical framework that understands sanctuary cities not as a uniform policy, but as a coalition-based form of local governance, composed of distinct and sometimes conflicting commitments. Within this framework, we identify three distinct strands within the sanctuary movement-administrative sanctuaries, political sanctuaries, and welcoming cities-each of which pulled sanctuary policies toward dissimilar interests. While the unification of these strands under a single policy umbrella drove the movement's initial rise, the busing crisis did more than merely reveal these dividing lines; it exploited them to devastating effect. Through comparative case studies of New York, Chicago, and Denver, this Article provides empirical evidence of how migrant busing fractured the legal and administrative coalitions underlying sanctuary governance. By theorizing the connections between busing and sanctuary cities offers not only a new theoretical framework but also a warning: without reckoning with its internal divisions, the sanctuary movement may prove far more fragile than its legal victories suggest.