Push Back on Proposed Rule to Gut Asylum - Interfaith Immigration Coalition

The Trump administration proposed yet another rule to gut the U.S. asylum system, a sweeping effort in a long line of restrictions and bans. The goal is to end asylum in the United States administratively, without an act of Congress, and keep people fleeing violence and murder in harm’s way. The public had until July 15 at 11:59pm to comment on this proposed rule. Following are a selection of comments submitted and background information.

Comments Submitted

(N.B. this is a partial list)

Action Alerts, Model Comments, and Templates

Visit the Tahirih Justice Center’s “microsite” (tahirih.org/standwithsurvivors) on the proposed rule’s impact on gender-based survivors, with an action alert with simple model comments, a social media toolkit, information in Spanish, and other resources.
Tahirih Justice Center has a comment template for immigration legal service providers and detailed analysis of the rule’s impact. Información en Español aquí.
Alliance for Immigrant Survivors (AIS) created a landing page with comment template for domestic violence/sexual assault survivor advocates and social services providers.
CLINIC (Catholic Legal Immigration Network, Inc.)’s resource page includes simple tools to help you file your comment including a click-to-comment campaign and organizational model comment.
HIAS’ template public comment.
National Immigrant Justice Center action page to submit comments and Template Comment for attorneys and legal service providers.
The Young Center for Immigrant Children’s Rights microsite has a child-specific template comment and click-to-comment tool.
Médecins Sans Frontières / Doctors Without Borders USA have a Save Asylum campaign page and comment template for medical/mental health care professionals, as well as MSF-USA’s own detailed comment citing its comprehensive report on the impact of harsh migration policies and violence reported by those fleeing the Northern Triangle of Central America.
Physicians for Human Rights’ comment template is geared towards the PHR network of health professionals and medical school asylum clinics, but adaptable for other medical/mental health professionals.
Migrant Center for Human Rights (San Antonio) wrote this analysis of “political opinion” grounds for persecution and analysis of what harm amounts to “persecution,” and problems with the proposed rule’s sharply narrowed definition of both terms.
Coalition to End Violence Against Women has a detailed comment template for coalition members and allied groups working on U.S. foreign policy as it relates to gender equality and gender-based violence.
Immigration Justice Campaign (a joint initiative of AILA (American Immigration Lawyers Association) and the American Immigration Council) model comments.
Houston Immigration Legal Services Collaborative has resources and guidance for submitting comments here.
Immigration Equality created a comment portal with a simple template for the general public and a detailed template for LGBTQ organizations/legal service providers, focused on LGBTQ/H individuals fleeing persecution on account of sexual orientation and/or gender identity.
Oasis Legal Services is circulating an online petition that will be submitted to lawmakers (full text of petition at this link), with option to click-through to submit a comment.
Women’s Refugee Commission’s comment submission page includes sample comment guidelines.
Save the Children Action Network’s comment submission page also has a child-specific template.
Disciples of Christ wrote these recommendations for submitting comments from a faith perspective.
Action alerts from HIAS, CWS, Immigration Justice Campaign, Center for Gender and Refugee Studies, National Immigrant Justice Center, Children’s Defense Fund – Texas, and the Young Center for Immigrant Children’s Rights.
Center for Gender and Refugee Studies has a social media toolkit here and the Interfaith Immigration Coalition’s is posted here.

Webinars and Comments-Writing Workshops

“Attack on the U.S. Asylum System: FAQs on the Proposed Asylum Rule,” Center for Gender & Refugee Studies (CGRS). Recording at this link.

“Death by a Thousand Cuts – The Trump Administration’s Proposed Rulemaking to Gut Asylum,” Center for Gender & Refugee Studies (CGRS) and American Constitution Society (ACS) Bay Area Lawyer Chapter. Overview of the proposed rule and how to submit a comment, as well of U.S. asylum law history and conditions in asylum seekers’ home countries. CLE materials online here.

HIAS webinar on “Asylum in the U.S.: An Urgent Briefing on the Latest Policy Changes.” Recording here; slides here.

Center Global “Comment Writing Workshop (LGBTQ-Focused).” Recording available here.

“Our Asylum System at Grave Risk: What You Can Do,” CLINIC (Catholic Legal Immigration Network, Inc.). Recording available here.

“Shutting Doors: How the U.S. is Poised to End Asylum & Turn Its Back on the Persecuted,” Co-Sponsored by the American Bar Association (ABA) Section on Civil Rights and Social Justice, Commission on Domestic and Sexual Violence, and Commission on Immigration. Recording here.

“The Death of Asylum: Trump Administration’s New Regulation Will Devastate U.S. Asylum System,” Immigration Justice Campaign – a joint initiative of AILA (American Immigration Lawyers Association) and the American Immigration Council. Recording posted here and slides available here.

Videos

Short PSA for the RDJ Refugee Shelter to promote the comment campaign. Includes remarks from American Immigration Lawyers Association and the National Immigration Project.

4-minute video breakdown of what the rule would do and why your voice matters by the Center for Gender & Refugee Studies.

Articles and Backgrounders

Scott Roehm, “Trump’s Latest Assault on Asylum has Nothing to Do with National Security or Public Health,” Just Security, July 15, 2020.

Neela Ghoshal, “Trump Wants to Gut Asylum Claims. LGBTQ+ People Will Die.” The Advocate, July 14, 2020.

Nene Bah and Lindsay Harris, “An American Mother on Asylum: Trump’s New Rules Would Have Rewritten My Story,” Ms. Magazine, July 13, 2020 (written by a woman who was granted asylum from gender-based persecution, and is now speaking out against the proposed regulations).

James Goodman, “Closing the Door on Asylum,” The Progressive, July 9, 2020.

Anam Rahman, Calderón Seguin PLC, SUMMARY OF NOTICE OF PROPOSED RULEMAKING ON PROCEDURES FOR ASYLUM, WITHHOLDING OF REMOVAL, AND PROTECTION UNDER CAT, June 11, 2020.

Aaron Reichlin-Melnick, “What You Need to Know About Trump’s Proposal to Eliminate the US Asylum System,” Immigration Impact (American Immigration Council), June 11, 2020.

“Tahirih Explains: Gender-Based Asylum,” June 2020.

Bill Frelick, “For World Refugee Day, the US plans to reject them all,” The Hill, June 20, 2020.

Prof. Natalie Nanasi, “New Trump Immigration Regulations Would Devastate Refuge Pathways,” Op-Ed, The Hill, June 16, 2020

Prof. Philip G. Schrag, “The End of Asylum — For Now,” Op-Ed, The Hill, June 16, 2020

Bill Frelick, “For World Refugee Day, the US plans to reject them all,” Op-Ed, The Hill, June 20, 2020

Danilo Zak, “The Trump Administration’s Proposed Changes to the U.S. Asylum System,” National Immigration Forum, June 18, 2020

Sign-On Letters

Letter signed by 34 Senators calling on the Administration to rescind the proposed rule as well prior policies that have cut asylum-seekers’ off from protection

Letter signed by 502 organizations and coalitions requesting an extension of the truncated 30-day public comment period to respond, to provide a standard 60-days for meaningful stakeholder input. Also previews substantive concerns.

Selected Organizational Statements

American Immigration Council (link)

American Jewish Committee, Jacob Blaustein Institute for the Advancement of Human Rights (link)

Amnesty International USA (link)

Center for Gender and Refugee Studies (link)

HIAS (link)

Human Rights First (link)

IRAP (link)

KIND (Kids in Need of Defense) (link)

Tahirih Justice Center (link)

For More Information

Infographics from the Alliance for Immigrant Survivors, showing how prior policy changes by the Administration have blocked survivors’ access not only to asylum, but also to protections under the Violence Against Women Act and the Trafficking Victims Protection Act:

Changes to Asylum Policy are Undermining Protections for Survivors of Violence

Changes to Immigration Court System are Undermining Protections for Survivors of Violence

Changes to Immigration System Policies are Undermining Protections for Survivors of Violence