Another woman famously took refuge in that church as she championed immigration reform, and at least 13 other illegal immigrants are doing the same at churches around the country. So far, they have little to fear.

U.S. Immigration and Customs Enforcement officials have arrested illegal immigrants by the hundreds in raids at factories, restaurants, malls, farms and meat packing plants, but they have handled cases involving churches delicately.

"Our agency takes enforcement actions when we deem it appropriate," said Julie Myers, assistant secretary of homeland security for ICE. "I am personally not aware of an instance when ICE has gone into a church. That being said, if there was a particular, extremely egregious, ax murderer or something else, that's not to say we would not enforce the law at that time."

Avoiding churches is unofficial policy for federal immigration officials, according to Doris Meissner, a former commissioner at the Immigration and Naturalization Service, the agency that oversaw immigration until the Department of Homeland Security was formed in 2003.

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