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Publication Date
09/07/2016
Letter from 380 national, state, and local non-profit organizations to President Obama requesting that he expand Temporary Protected Status for El Salvador, Honduras, and Guatemala and provide relief from deportation to 1.2 million undocumented immigrants.
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Publication Date
01/18/2017
Letter from 850+ national, state, and local non-profit organizations to President-elect Trump requesting that he continue Deferred Action for Childhood Arrivals (DACA) in light of the public safety, economic, and humanitarian benefits.
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Publication Date
03/09/2017
Letter from 292 law professors and scholars in the areas of immigration, migration, constitutional, administrative, and international law to President Trump stating that section 9(a) of Executive Order 13768, which directs the federal government to terminate federal funding for so called "sanctuary" jurisdictions, is unconstitutional.
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Publication Date
05/17/2017
Letter from National, State, and Local non-profit organizations opposing the Trump Mass Deportation Act (The Michael Davis, Jr. and Danny Oliver in Honor of State and Local Law Enforcement Act, H.R. 2431).
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Publication Date
06/27/2017
Letter from 400+ national, state, and local non-profit organizations opposing H.R. 3003, the No Sanctuary for Criminals Act, and H.R. 3004, Kate's Law.
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Publication Date
07/13/2017
Letter from 300+ national, state, and local non-profit organizations to the U.S. Senate opposing Lee Francis Cissna's nomination for director of U.S. Citizenship and Immigration Services and asking senators to "hold" his nomination.
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Publication Date
09/27/2017
Letter from 500+ national, state, and local organizations requesting that the Dream Act of 2017 sponsors adopt more flexible requirements in regards to expungements and misdemeanors.
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Publication Date
05/23/2018
This statement from a coalition of immigrant rights organizations urges members of Congress to vote no on the FIRST STEP Act of 2018 (H.R. 5682). This bill excludes a wide swatch of immigrants, further criminalizes aspects of migration, and fails to address root systemic causes of incarceration nor advance any meaningful criminal justice reform.
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Publication Date
11/13/2018
This comment period has closed. Click here respond to the latest notice of proposed fee waiver rule change.
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Publication Date
08/29/2019
On August 8, 2019 the Department of Homeland Security’s U.S. Citizenship and Immigration Services (USCIS) posted a second opportunity for notice and comment on the new USCIS Tip Form to collect information from the public regarding purported immigration fraud.
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Publication Date
05/06/2019
This comment period has closed. Click here respond to the latest notice of proposed fee waiver rule change.
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Publication Date
06/17/2019
On June 5, 2019, the Department of Homeland Security’s U.S. Citizenship and Immigration Services (USCIS) published a third notice regarding its plans to dramatically change fee waiver eligibility and process. The June 5 notice attempts to provide additional justification for its plan to eliminate means-tested benefits as a basis for requesting a fee waiver, among other changes, following April 5 and September 28 notices that lacked rationale for why such changes to fee waivers are justified. Now, USCIS is also claiming lost fee revenue as a reason for its proposed changes to fee waivers, making clear its intention to reduce the number of fee waivers that are granted. If finalized, these proposed changes will discourage eligible individuals from filing for fee waivers and immigration benefits and place heavy time and resource burdens on those who do still apply for fee waivers.
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Publication Date
09/16/2019
The Immigrant Legal Resource Center created this template to help you draft your own comments in opposition to this interim rule with request for comment. The new rule can be found here. Comments are due by October 25, 2019. We are very concerned about this rule’s “reorganization” at EOIR that eliminates OLAP, the office that has operated the Recognition and Accreditation (R & A) Program and the legal orientation programs until now. The rule places the remaining functions of OLAP under an Office of Policy.
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Publication Date
10/04/2019
On August 26, 2019, the Department of Justice, Executive Office for Immigration Review (EOIR) published an interim final rule, effective immediately, with a request for public comments by October 25, 2019. ILRC posted a templated comment urging programs to send in their own responses.
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Publication Date
12/23/2019
On December 23, 2019, ILRC submitted a comment in opposition of the Department of Homeland Security’s notice of proposed rulemaking titled, “U.S. Citizenship and Immigration Services Fee Schedule and Changes to Certain Other Immigration Benefit Request Requirements,” published in the Federal Register on November 14, 2019, with supplemental information published on December 9, 2019. ILRC submitted supplemental comments in early 2020.
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Publication Date
04/02/2020
The American Immigration Council, the American Immigration Lawyers Association, ASISTA Immigration Assistance, the Catholic Legal Immigration Network, Inc., the Immigrant Legal Resource Center, Kids in Need of Defense, and the Tahirih Justice Center submitted this comment in response to the proposed revisions to USCIS Form I-290B, which were published in the Federal Register on December 6, 2019.
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Publication Date
04/03/2020
ILRC sent a request to USCIS headquarters to provide more information and to also take certain actions to deal with the consequences of the closure of USCIS public services and the impact of COVID-19 on the immigrant public. These are concerns raised by the individuals and organizations with whom we partner. We have promised to raise more issues as the emergency situation continues.
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Publication Date
05/05/2020
COVID-19 has made one thing clear; when law enforcement cooperates with ICE this has dire public health implications. There have been renewed and urgent efforts to stop this cooperation, including a recently filed lawsuit California Attorneys for Criminal Justice, et al. v. Gavin Newsom, California Governor, et al., challenging the transfer of people from state and local custody to ICE in the midst of COVID-19. Ten current and former district attorneys and police chiefs from across California filed an amicus curiae letter brief in support of this lawsuit. This letter brief was authored and organized by Fair and Just Prosecution, Immigrant Legal Resource Center, and Pillsbury Winthrop Shaw Pittman LLP.
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Publication Date
05/15/2020
On May 7, 2020, ILRC co-authored and signed on to a comment opposing recently published USCIS policy manual instructions for adjustment applications under the Liberian Refugee Immigration Fairness Act (LRIF).
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Publication Date
06/11/2020
U.S. Citizenship and Immigration Services (USCIS), an agency funded by the fees of US citizens, employers, and immigrants, is asking Congress for $1.2 billion in appropriated money to cover up years of deliberate fiscal and policy mismanagement by the Trump administration. The ILRC and DHS Watch drafted a letter signed by over 100 groups asking that Congress condition any appropriated funds to USCIS's reversal of policies and actions that produced the current deficit and subverted the agency’s core services mission.
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Publication Date
06/15/2020
On June 5, 2020, the California Court of Appeals, Second Appellate District, published People v. Ruiz, holding that the defendant could vacate her conviction because she was not advised that her conviction will carry deportation consequences. Rose Cahn, Mike Mehr, and appellant’s counsel, filed the above letter with the Court of Appeal, suggesting clarification that defense counsel bears the duty to advise about specific immigration consequences, and distinguishing from the court’s more general obligation to advise about potential immigration consequences.
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Publication Date
08/04/2020
On November 15, 2019, the ILRC and Public Counsel submitted comments in response to the re-opened comment period on the proposed SIJS regulations, originally published in 2011. The ILRC and Public Counsel each submitted comments on the proposed rule during the original 2011 comment period, organizationally and as part of the Immigrant Children Lawyers Network. Accordingly, in 2019, we wrote to renew our 2011 comments and briefly supplement them due, in part, to concerns and changes in practice that had arisen in the intervening eight years.
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Publication Date
08/17/2020
On August 13, 2020, ILRC submitted comments on recent changes to USCIS’s policy manual. The new chapters on discretion will radically alter adjudications of a wide variety of applications for immigration benefits. We recommend that the changes be stricken because they are ultra vires, lack legal support, and will exacerbate USCIS’s current crisis. The policy manual changes compound agency inefficiency, waste, and mismanagement at a time when the agency has crisis-level backlogs and is seeking a bailout from Congress. Instead of looking for ways to streamline adjudications, the policy manual imposes a secondary adjudication process on dozens of application types that will require adjudicators to multiply the amount of time that they spend determining eligibility, a move that will grind adjudications to an even slower pace and deny applicants relief for which they would otherwise be eligible.
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Publication Date
09/17/2020
In January 2020, the Committee for Review of the Penal Code began convening with the intent of putting forward wide ranging recommendations for reforms to the California criminal legal code. Understanding the significant impact of the process for California’s immigrant population, the ILRC has formally submitted recommendations, advice, and expert testimony as the committee engages in its deliberations. We will continue to update this site with our recommendations to the committee.
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Publication Date
09/18/2020
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Publication Date
09/30/2020
On September 25, ILRC submitted comments in opposition to EOIR's proposed rule regarding court procedures. The proposed rule is an unlawful attempt to curb Immigration Judges’ authority, limit case review, and drastically restrict due process for immigrants. The rule undermines the appellate process and curtails the efficient adjudication of the courts.
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Publication Date
11/05/2020
On October 30, 2020, ILRC filed a comment opposing an EOIR proposed rule that would have a substantial negative impact on legal orientation programs operated by non-profit immigration legal services programs.