This practice advisory outlines the process for researching and commenting on federal forms. A previous advisory covers the process specific to commenting on regulations, which has many parallels to the forms comment process. Federal forms and their comment process are often overlooked by advocates, even those who regularly follow changes in regulations and comment on them. However, form changes can be significant and sometimes can be used to change policy by agencies. The statute regulating forms is the Paperwork Reduction Act (PRA).
On January 17th, 2025, the Fifth Circuit Court of Appeals (“Court”) issued its latest decision in the ongoing DACA litigation. While nothing has changed, and current DACA recipients can continue to renew their DACA and obtain both protection from deportation and work authorization, it is important to understand what the current state of DACA is and what can change in the future.
Operation Lone Star (OLS) is an unconstitutional and deadly Texas law enforcement scheme that wastes vital state resources to target migrants for arrest, jail, and deportation. To date, nearly $11 billion has been spent on OLS. This policy brief delves into how misguided OLS has been for Texans from a financial perspective and provides recommendations for how OLS funds could be reinvested to support the everyday lives of Texans who need strengthened public services and infrastructure.
CBP has signed an agreement delegating immigration enforcement authority to the Texas National Guard. Under the President's "mass influx" declaration, local and state law enforcement agencies may take on civil immigration enforcement authority that they wouldn't otherwise have. These specific powers are designated in a Memorandum of Understanding signed with CBP. This quick explainer highlights what this MOU says, what this means for Texas, and how it relates to Operation Lone Star.
Following the new administration’s dramatic reorientation of all federal agencies into immigration enforcers, on January 21st, 2025, the DOJ issued a directive requiring all federal prosecutors to prioritize immigration prosecutions. The memorandum also threatens prosecutions and civil lawsuits to sanctuary jurisdictions and entities that seek to protect immigrants. In this analysis, we explain the different sections of the DOJ’s memo and what they mean for immigrants and federal courts nationwide.
In 2024, USCIS issued a new Form N-400, Application for Naturalization, with more lengthy and complicated instructions on evidence that could be included. This guide will help practitioners understand what documents naturalization applicants must submit to the USCIS to accept and adjudicate the N-400 form and when to submit each document.
The Laken Riley Act (LRA) was signed into law by President Trump on January 29, 2025. It amends the Immigration and Nationality Act (INA) by expanding mandatory detention of certain inadmissible noncitizens who are merely arrested or charged with certain offenses. This practice advisory addresses the question of whether the provisions of the LRA that seek to vastly increase the number of people subject to mandatory immigration detention would be triggered by children engaging in acts of juvenile delinquency. In the advisory, we argue that the answer is no, in alignment with longstanding precedent in immigration law that treats acts of juvenile delinquency as distinct from adult criminal acts. However, given that this is a new law with unclear drafting, we also provide tips for juvenile defense attorneys to help clients avoid charges that could implicate the mandatory detention provision of the LRA.