Public Comments / Sign-on Letters

The ILRC submitted comments in opposition to the Department of Homeland Security's notice of proposed rulemaking on the affidavit of support, published in the Federal Register on October 2, 2020. The proposed rule would discourage, deter, or outright disqualify many U.S. citizens and U.S. permanent residents from immigrating their family members and, like the public charge rule, cause families to...

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.

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...

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...

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...

The ILRC pointed out problems with the language in the DOS form on fee waivers, on household income, and on health insurance. Other NGOs and practitioners are encouraged to comment by the deadline of July 2, 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...

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...