Public Comments / Sign-on Letters

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...

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...