Public Comments / Sign-on Letters

On January 25, 2022, the ILRC submitted comments in response to the DHS Notice Requesting Comments on “Identifying Recommendations To Support the Work of the Interagency Task Force on the Reunification of Families.” Our comments urge the U.S. government to stop criminal prosecutions for migration, admit wrongdoing and compensate the victims of family separation under the Trump Administration, curb enforcement and detention in the absence of meaningful opportunities for people to gain immigration status, rescind harmful border policies and practices, and expand the interpretation of family unity to ensure that children are not separated from both parental and non-parental caregivers.
On December 21, 2021, the ILRC submitted comments raising concerns on the form that ICE plans to utilize to allow the public to submit tips on suspicious or criminal activity. ILRC raised concerns with ICE’s use of this form given the high likelihood that information submitted will be unreliable or outright false, which has the potential to significantly harm immigrant communities. Particularly at risk are communities that have been historically targeted for hate crimes and targeted by ICE for discriminatory purposes as well as domestic violence survivors and immigrant communities already vulnerable to exploitation. The comment urges ICE to discontinue the use of this form.
On November 18, 2021, the ILRC submitted comments making recommendations to USCIS regarding the agency’s proposed regulation on the Deferred Action for Childhood Arrivals (DACA) program. ILRC focused on recommendations that address the need for USCIS to create standards within this regulation to ensure equitable and consistent treatment for DACA applicants.
On November 5, 2021, the ILRC participated in comments to USCIS with the Naturalization Working Group concerning proposed revisions to the N-648 form for Medical Certification for Disability Exception for naturalization applicants. The form revisions overall represent an improvement over prior versions by shortening the form and eliminating irrelevant questions. The comment also  urges USCIS to withdraw 2018 – 2020  changes to volume 12 of the USCIS policy manual that continue to unnecessarily limit eligibility for disability waiver  applicants.
The ILRC, along with 96 international and national organizations, urge the Department of Homeland Security (DHS) to halt the use of denaturalization, a racialized and criminalizing tactic to determine who belongs in the United States.
On October 19, 2021, the ILRC submitted comments raising concerns about USCIS’ proposed regulation changing the procedures for credible fear screenings and asylum. While the proposed regulation contains some provisions that would improve the current system, it also poses a significant risk to asylum seekers’ right to a full, fair and consistent hearing of their claims.
ILRC submitted this comment to commend USCIS on the recent update to the USCIS Policy Manual, entitled “Assisted Reproductive Technology and In-Wedlock Determinations for Immigration and Citizenship Purposes.” We applaud USCIS on this update and clarification, which was necessary to comport with evolving reproductive technology and address disparate treatment under previous guidance. The change will improve the fair interpretation of “wedlock” in acquisition of citizenship cases and help ensure access to citizenship for all who qualify.
In July 2021, African Communities Together, the UndocuBlack Network, and the Immigrant Legal Resource Center submitted a memo to USCIS outlining the reasons that an expired Liberian passport should be considered primary evidence of nationality for LRIF eligibility.