We submitted our analysis of the government’s interim final rule reducing the number of BIA members. Our comment urges the Department of Justice to rescind the rule in its entirety.
We submitted our analysis of the government’s interim final rule regarding registration for noncitizens. Our comment urges the government to withdraw the rule in its entirety.
We submitted our analysis of the government's final rule that essentially closes off asylum during "emergency border circumstances." Our comment urges the government to withdraw the rule in its entirety.
We submitted our analysis of the government's interim final rule that essentially closes off asylum during "emergency border circumstances." Our comment urges the government to withdraw the rule in its entirety.
We submitted our analysis of the government's proposed rule permitting asylum officers to consider the applicability of statutory bars during initial fear screenings. Our comment urges the government to withdraw the rule in its entirety.
We submitted our analysis of the Joint Interim Final Rule, urging the Departments of Justice and Homeland Security to make improvements to the Rule to ensure that asylum seekers are not rushed through a process with a high risk of mistaken decisions resulting in return to their country of origin.
We submitted a comment analyzing and urging the Biden administration to withdraw its proposed rule creating a new system for adjudication of asylum, withholding of removal, and Convention Against Torture (CAT) claims, which undermines U.S. legal obligations to protect refugees.
We submitted our analysis of the government's final "asylum ban" rule, which bars from asylum most people seeking protection at the U.S. southern border. Our comment urges the agencies to withdraw the rule in its entirety.
We submitted our analysis of the government's proposed "asylum ban" rule, which would bar from asylum most people seeking protection at the U.S. southern border. Our comment urges the agencies to withdraw the rule in its entirety.
Executive Branch Comment
CGRS Comment in Response to DOJ Request for Comments: Reducing the Size of the Board of Immigration Appeals, 90 FR 15525
We submitted our analysis of the government’s interim final rule reducing the number of BIA members. Our comment urges the Department of Justice to rescind the rule in its entirety.
CGRS Comment in Response to CBP Request for Input on San Diego County Border Barrier Construction, CBP Publication Number 4071-0425
We provided our analysis of the planned additional border barriers and urged that they be halted.
CGRS Comment in Response to DHS Request for Comments: Alien Registration Form and Evidence of Registration, 90 FR 11793
We submitted our analysis of the government’s interim final rule regarding registration for noncitizens. Our comment urges the government to withdraw the rule in its entirety.
CGRS Comment in Response to DHS and DOJ Request for Comments: Securing the Border, 89 FR 81156
We submitted our analysis of the government's final rule that essentially closes off asylum during "emergency border circumstances." Our comment urges the government to withdraw the rule in its entirety.
CGRS Comment in Response to DHS and DOJ Request for Comments: Securing the Border, 89 FR 48710 and Presidential Proclamation, 89 FR 48487
We submitted our analysis of the government's interim final rule that essentially closes off asylum during "emergency border circumstances." Our comment urges the government to withdraw the rule in its entirety.
CGRS Comment in Response to DHS Request for Comments: Application of Certain Mandatory Bars in Fear Screenings, 89 Fed. Reg. 41347
We submitted our analysis of the government's proposed rule permitting asylum officers to consider the applicability of statutory bars during initial fear screenings. Our comment urges the government to withdraw the rule in its entirety.
CGRS Comment in Response to DHS Request for Comments: Procedures for Credible Fear Screening and Consideration of Asylum, Withholding of Removal, and CAT Protection Claims by Asylum Officers, 87 Fed. Reg. 18078
We submitted our analysis of the Joint Interim Final Rule, urging the Departments of Justice and Homeland Security to make improvements to the Rule to ensure that asylum seekers are not rushed through a process with a high risk of mistaken decisions resulting in return to their country of origin.
CGRS Comment in Response to DHS Request for Comments: Procedures for Credible Fear Screening and Consideration of Asylum, Withholding of Removal, and CAT Protection Claims by Asylum Officers
We submitted a comment analyzing and urging the Biden administration to withdraw its proposed rule creating a new system for adjudication of asylum, withholding of removal, and Convention Against Torture (CAT) claims, which undermines U.S. legal obligations to protect refugees.
CGRS Comment in Response to DHS and DOJ Request for Comments: Circumvention of Lawful Pathways, 88 Fed. Reg. 31314
We submitted our analysis of the government's final "asylum ban" rule, which bars from asylum most people seeking protection at the U.S. southern border. Our comment urges the agencies to withdraw the rule in its entirety.
CGRS Comment in Response to DHS and DOJ Request for Comments: Circumvention of Lawful Pathways, 88 Fed. Reg. 11704
We submitted our analysis of the government's proposed "asylum ban" rule, which would bar from asylum most people seeking protection at the U.S. southern border. Our comment urges the agencies to withdraw the rule in its entirety.
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