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Publications Archive

Publication Category: Comments
  • Tahirih Comments on Good Cause for a Continuance in Immigration Proceedings

    • Publication Date: December 28, 2020
    • Publication Categories: Comments

    Tahirih submitted comments to the Executive Office of Immigration Review (EOIR) in response to the proposed rule on Good Cause for a Continuance in Immigration Proceedings published on November 27, 2020.

  • Tahirih Comments on Motions to Reopen and Reconsider, Effect of Departure, and Stay of Removal

    • Publication Date: December 28, 2020
    • Publication Categories: Comments

    Tahirih submitted comments to the Executive Office of Immigration Review (EOIR) in response to the proposed rule on Motions to Reopen and Reconsider, Effect of Departure, and Stay of Removal published on November 27, 2020.

  • Tahirih Comments in Response to Proposed Rules on Representation in Immigration Court

    • Publication Date: October 29, 2020
    • Publication Categories: Comments

    The Tahirih Justice Center submits the following comments to the Executive Office of Immigration Review (EOIR) in response to the proposed rule published on September 23, 2020. Tahirih strongly opposes the proposed rule insofar as it declines to expand limited in-person representation in immigration court, while threatening the existing Friend of the Court program. The proposed rule also refuses to remedy local procedures that effectively bar counsel of record and prospective counsel from accessing the record of proceedings in a case.

  • Tahirih Comment Opposing EOIR Proposed Rule

    • Publication Date: October 22, 2020
    • Publication Categories: Comments

    The Tahirih Justice Center submitted the following comments to the Executive Office of Immigration Review (EOIR) in response to the proposed rule published on September 23, 2020. Tahirih opposes the rule as both a matter of public policy and because it violates numerous laws, including the Immigration & Nationality Act (INA), the Administrative Procedure Act (APA), and the international obligations of the United States as a State party to the United Nations (UN) Convention Relating to the Status of Refugees and 1967 Protocol.

  • Tahirih Comments on Proposed Biometrics Rule

    • Publication Date: October 13, 2020
    • Publication Categories: Comments

    The Tahirih Justice Center submitted the following comments to the Department of Homeland Security in response and opposition to its proposed rule entitled Collection and Use of Biometrics by United States Citizenship and Immigration Services published on September 11, 2020.

  • Tahirih Comments on Proposed Changes to Appellate Procedures and Decisional Finality in Immigration Proceedings

    • Publication Date: September 25, 2020
    • Publication Categories: Comments

    Tahirih submitted comments to the Executive Office of Immigration Review in response to the proposed rule published on August 26, 2020. Tahirih opposes the rule as both a matter of public policy and because it patently violates numerous laws, including the Immigration & Nationality Act, the Administrative Procedure Act, and the international obligations of the United States as a State party to the United Nations Convention Relating to the Status of Refugees and 1967 Protocol.

  • Joint Comment Submitted in Response to USCIS Policy Manual Chapters on Applying Discretion in USCIS Adjudications

    • Publication Date: September 14, 2020
    • Publication Categories: Comments

    A coalition of organizations that assist, support, and advocate on behalf of immigrant survivors of domestic violence, sexual assault, human trafficking and other abuses submitted comments to object to the USCIS Policy Manual’s newest provisions regarding applying discretion in USCIS adjudications, including employment authorization. We are deeply concerned about the myriad ways this guidance will foreclose such survivors from the humanitarian relief that Congress specifically created for them, putting them at risk of continued harm.