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Publications Archive

Publication Category: Comments
  • Tahirih Comments on Safe-Third-Country Agreement with Guatemala

    The Tahirih Justice Center submitted comments in opposition to the interim final rule, 84 Fed. Reg. 63994, implementing safe-third-country agreements and allowing the government to remove asylum seekers to Guatemala.

  • Tahirih Comments Opposing Presidential Proclamation on Health Insurance

    • Publication Date: October 31, 2019
    • Publication Categories: Comments

    The Tahirih Justice Center filed comments opposing the implementation of the presidential proclamation making “approved” health insurance a prerequisite to a receipt of an immigrant visa. The proclamation has since been blocked by a temporary restraining order.

  • Tahirih Comments to Proposed Rule on Special Immigrant Juvenile Petitions

    • Publication Date: November 15, 2019
    • Publication Categories: Comments

    The Tahirih Justice Center submitted comments in opposition to U.S. Citizenship and Immigration Services’ (USCIS) proposed rule on Special Immigrant Juvenile Petitions (76 FR 54978).

  • Tahirih Comments on Work Authorization Regulations for Asylum Seekers

    The Tahirih Justice Center submitted comments opposing the Department of Homeland Security’s proposed rule which would eliminate the 30-day deadline to adjudicate an asylum seeker’s work authorization application. Under the proposed rule, asylum seekers, including survivors of gender-based violence, will be forced to wait for Employment Authorization Documents (EAD) indefinitely, with no recourse or end in sight.

  • Tahirih Comments on EOIR Reorganization

    The Tahirih Justice Center submitted comments opposing the recent reorganization of the Executive Office of Immigration Review (EOIR), the agency that houses the immigration courts and the Board of Immigration Appeals (BIA). The reorganization undermines the independence of the BIA, and compromises the due process rights of survivors of gender-based violence and other immigrants, by imposing a uniform, strict timeline on BIA decisions and by giving the EOIR Director, an administrator who need not have judicial experience, the authority to decide individual cases.

  • Tahirih Resubmits Comments on Tip Form

    The Tahirih Justice Center submitted previously submitted comments in opposition to the proposed new Form G-1530, as our concerns were not addressed in April. The new proposed “tip” form will allow individuals to report claims of immigration benefit fraud anonymously, which will embolden violence abusers and make it easier for them to carry out their threats.

  • Tahirih Comments on Expanded Expedited Removal Policy

    The Tahirih Justice Center submitted comments opposing the Department of Homeland Security’s expansion of expedited removal. The policy will apply to anyone arrested by ICE, anywhere in the United States. Exceptions will be made for immigrants who are able to prove that they have lived in the U.S. continuously for more than two years.

    This rule compromises the safety and legal rights of immigrants, including survivors of gender-based violence. It worsens the climate of fear already felt by immigrant survivors and will discourage individuals from seeking help.