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The preeminent function of government is to provide for the safety and security of the law-abiding public. It is among the chief reasons that we consent to be governed and bound by a collection of laws. We want those that we love to be protected, so we abide by the law in the hopes that others will feel similarly bound. We think so highly of the law that we make aspiring citizens take an oath that contains six separate references to the law. This system of laws failed Kate Steinle as it has failed others like her, and this is more than an academic discussion about prosecutorial discretion. It is quite literally life and death. The definition of "sanctuary" is a place of refuge or safety. It almost sounds utopian. Refuge for whom? Safety for whom? For a young woman walking on a pier with her father, or for a career recidivist like Juan Francisco Lopez-Sanchez, who had a quarter century's worth of lawlessness dating all the way back to 1991. He committed local, State, and Federal crimes in at least 5 separate States. He was deported 5 times, and each time had so little regard for the law that he reentered that border that we are supposed to have functional control over. His procedural history is every bit as disturbing. In May of 2011, this defendant was convicted and sentenced to 46 months imprisonment for illegal reentry again. At the conclusion of that sentence, he was released from the Bureau of Prisons to a known sanctuary jurisdiction for the ostensible prosecution of an old drug case. San Francisco did not prosecute that old drug case.