The term generally applies to cities that do not allow municipal funds or resources to be used to enforce federal immigration laws, usually by not allowing police or municipal employees to inquire about an individual's immigration status. The designation has no legal meaning.
There are dozens of US cities that willfully ignore federal immigration laws. It's a known fact. But, since "the designation has no legal meaning" I guess cities like Los Angeles are mere "phantoms".
Seems to be trying to play glittering generality games here.
That said, we got to be careful about what we do with 10th Amendment rights unless we want to bury that sucker so deep that even new originalists can’t get at it.