Public Comments / Sign-on Letters

ILRC submitted this comment in response to the recent update to the USCIS Policy Manual, entitled “Naturalization Eligibility and Voter Registration Through a State’s Benefit Application Process,” issued May 27, 2021, and effective immediately. ILRC wrote to commend USCIS on the addition of this update, suggest edits to the wording of the false claim ground to better reflect the law and avoid...
In 1994, Congress established an exception to the English and civics testing requirements for applicants with disabilities, creating access to citizenship for people who previously had none. Subsequent administrative guidance restricted eligibility for the waiver. On June 21, 2021 ILRC joined with dozens of organizations submitting a comment to USCIS regarding changes to the N-648 naturalization...
The Liberian Refugee Immigration Fairness (LRIF) Strategy Group submitted these comments in connection with the U.S. Citizenship and Immigration Services’ (USCIS) Request for Public Input published in the Federal Register on April 19, 2021. The Strategy Group is a focused coalition of local, state, and national-level organizations that provide direct legal and other community-based services to...
ILRC submitted these comments on December 18, 2020 to oppose the administration's dramatic expansion of USCIS guidance on how to assess whether someone has a “lawful admission” for purposes of naturalization eligibility under INA § 318. The updated policy guidance is an unwarranted directive to officers to engage in extreme vetting and unnecessary scrutiny of all naturalization applicants.
On March 16, 2021, ILRC and seven other coalition members of the Liberian Refugee Immigration Fairness (LRIF) Strategy Group submitted recommendations to the Administration and USCIS leadership for equitable implementation of LRIF. The group requested a meeting with the government to discuss these recommendations.
ILRC submitted these comments on March 16, 2021 to oppose the numerous unnecessary and burdensome changes that former President Trump's administration proposed in the last few days of his presidency, as well as to propose some further changes that President Biden's administration could take to streamline the application process and eradicate barriers to naturalization.
On December 22, 2020, the ILRC submitted comments in opposition to EOIR’s notice of proposed rulemaking regarding what constitutes “good cause” for a continuance in removal proceedings. The proposed changes severely restrict the circumstances in which respondents can obtain continuances in removal proceedings, as well as the number and length of continuances. These changes will have a devastating...
ILRC filed comments opposing USCIS’s changes to discretion in adjustment because they violate existing case law. The changes represent an attempt to impose new eligibility requirements that are also a violation of the Administrative Procedure Act (APA) because they went into effect without the required regulatory notice and comment process. The agency has provided no explanation for this abrupt...
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. Much of the impact will be from the way the regulation redefines key terms: First, by broadening the scope of legal “practice,” the proposed rule would require non-representative providers...


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