Policy Advocacy

On June 29, 2026, the Immigrant Legal Resource Center (ILRC) submitted comments urging USCIS to withdraw its proposed revisions to Form N-648, the Medical Certification for Disability Exceptions used by naturalization applicants seeking a waiver of the English and civics requirements based on disability. ILRC commented that the proposed revisions unlawfully impose new eligibility standards that are not authorized by the Immigration and Nationality Act, federal regulations, or USCIS's own Policy Manual.

The Immigrant Legal Resource Center (ILRC) submitted comments opposing the Department of Homeland Security's proposed rule to increase the filing fee for Form I-246, the Application for a Stay of Deportation or Removal, from $155 to $755. The comment provides that the proposed 387% fee increase is arbitrary and capricious under the Administrative Procedure Act because DHS fails to provide a reasoned justification for the increase or adequately consider its devastating impact on immigrants seeking protection from deportation.

For more than two years, advocates have decried Texas SB 4 (2023), a law that creates new state offenses of illegal entry, reentry, and failure to comply with a state removal order. As of May 29, 2026, the law is fully in effect, bringing all Texans and those suspected of being undocumented under the permanent threat of immediate detention and deportation by the state, should they be suspected of violating the law. Texas SB 4 represents an unheard-of state usurpation of federal law, violating constitutional principles and norms that govern how states interact with the federal government. This policy brief breaks down the law and shares how communities can best prepare for a world with Texas SB 4 on the books.

On June 22, 2026, the Immigrant Legal Resource Center (ILRC) submitted a comment opposing ICE’s proposed rule to increase the fee imposed on individuals ordered removed in absentia from $5,130 to $18,000.

On May 4, 2026, The Immigrant Legal Resource Center (ILRC) submitted a formal comment opposing proposed changes to the EOIR-33 change-of-address form, arguing that the revisions are procedurally improper and substantively harmful.

On April 23, 2026, the Immigrant Legal Resource Center (ILRC) submitted a comment opposing a proposed rule that would significantly limit work authorization for asylum seekers. The ILRC comments that the rule would drastically restrict access to work permits and make it nearly impossible for many asylum seekers to survive while their cases are pending. It highlights that the proposal would lengthen wait times, add new eligibility barriers, and allow broad discretionary denials, effectively undermining the asylum system and deterring legitimate applicants. The ILRC contends the rule would cause severe economic, social, and health harms, including lost wages, increased exploitation, family instability, and reduced access to legal representation and basic services, while also disproportionately harming immigrants of color. Additionally, the ILRC criticizes related form changes as unlawful and overly burdensome, concluding that the proposal lacks evidence to support its stated goals and urging DHS and USCIS to withdraw it entirely.

The U.S. Department of Justice transferred out all permanent staff from the Recognition and Accreditation program in March 2026, rendering the future of the program uncertain. ILRC wrote to DOJ demanding reinstatement of staff and a return to reasonable processing times for applications.

In recent months, practitioners have been reporting troubling new patterns in FOIA processing of A-file requests. Some people report unusually high rejection rates on Freedom of Information Act (FOIA) requests for reasons related to address requirements. Rejections due to “no record” also have been reported even where the requester is sure that there is a record because they have a partial paper trail of contacts with USCIS. Frequent over redaction of FOIA responses also has been reported. This alert discusses the address issue and suggests how to respond.

This brief spotlights legislative activity in Texas and Florida, it also covers a non-exhaustive list of other states that have recently enacted a patchwork of anti-immigrant laws and policies seeking to harm and hinder immigrant communities and their allies.

From October 3-7, 2025, Goodwin Simon Strategic Research surveyed a statewide representative sample of 1,213 registered voters. The poll explored voter attitudes towards mass deportation, recent ICE actions, and sanctuary protections in the state. Uniquely, this poll explores key themes that may be driving Californians’ growing disapproval of mass deportation, including revealing voters’ strong support for due process, including for people with past records, and equal treatment in the legal system, regardless of immigration status. Voters also expressed deep concern with the cost of the Trump administration’s approach to immigration on taxpayers.

ILRC submitted this comment on November 25, 2025 opposing the Interim Final Rule (IFR) eliminating automatic extensions of Employment Authorization Documents (“EADs”). The IFR was improvidently issued without prior notice and comment, is unsupported by data or reasoned analysis, and falsely claims that it is part of a foreign affairs exception intended for regulations which impact international policies.