Public Comments / Sign-on Letters

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...

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...

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). USCIS took a restrictive view of the LRIF statute and published administrative guidance which would disqualify persons who should be eligible under the statutory language. The LRIF statute...

On May 8, 2020, ILRC submitted a comment to USCIS opposing a recent USCIS Information Collection notice published in the Federal Register on April 10, 2020 to overhaul the form I-864 Affidavit of Support. USCIS used a form change process under the Paperwork Reduction Act to propose extensive changes in the I-864, I-864 A and I-864 EZ which would further discourage sponsors from pledging support...

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...

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.

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.

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...