Reader Mitzi Hellmer, an immigration lawyer, writes:
PLEASE HELP! WE NEED AS MANY PEOPLE AS POSSIBLE TO SUBMIT COMMENTS BEFORE JULY 15. Trump’s latest proposal to kill asylum is a doozy. The administration wants to define asylum in such a narrow way as to basically eliminate the protection altogether. This would endanger the lives of thousands of desperate people who have abandoned everything to seek refuge in this country, especially Central Americans whose countries have been decimated by US foreign policy. Indeed, these proposed regulations seem specifically drafted with Central Americans in mind. For example, they would bar those fleeing gang violence and persecution on account of their gender from asylum, despite the fact that Central America is one of the most dangerous places in the world for women and that even the President of El Salvador has called gangs “a parallel state.” These proposals are racist to their core and an outrage against our treaty obligations.
I know that a lot of Trump’s horrid attacks against immigrants have been stayed by courts, but these might actually stick. Why? Because unlike his previous outrages, he’s actually following the law which requires that he notify the public about any proposed changes to the regulations and allow them to comment. Each individual comment must be addressed by the administration before the new regulations can be implemented, so the more individual comments we get, the more likely it is that the regulations will become more humane. Or, at the very least, more comments might slow things down enough that we might have a non-sociopath in the White House before these horrid restrictions ever get implemented.
So, we’re asking EVERYONE to please submit a unique comment on these proposed regulations BEFORE JULY 15. There are templates and information available at the links below, as well as guidance about where to submit comments (you can do it online). Thank you so much for helping! For what you did for the least of these, you did for me.
“So far there are 4711 public comments against the proposed asylum regulations that will totally gut our asylum system. LET’S DOUBLE THAT NUMBER. The public charge comment received 280,000 comments and it slowed things down by 10 months. The recent asylum employment authorization regs that just went into effect received around 1000 comments that took from November to June to issue. Let’s comment ourselves and motivate at least FIVE people in our lives (including our spouses, office staff, interns, best friends, etc) to comment, too. There are tons of resources and comment templates. I like the NIJC one available here.
There are tons of other resources to choose from, including prerecorded webinars, videos, Op Eds, articles, etc, to educate yourself and your community about these proposed regs also on this site.
There is NO excuse not to comment. Make it unique. – PLEASE COMMENT.”
Done. Here was my comment:
I am writing today to express my absolute opposition to the proposed rules, DHS/EOIR; RIN 1125-AA94; EOIR Docket No. 18-0002, which is one of the most devastating and comprehensive attacks on asylum seekers yet. The U.S. government has made it nearly impossible for people fleeing harm in their countries of origins to find safety here, and I think this is evil.
I believe the United States should welcome refugees and asylum seekers into our communities because it is the morally right thing to do and it is good for our country in the long term. The principles and rules we base our decisions on should seek to protect as many as possible because we believe in the right to life and liberty. The Trump administration’s focus seems to be on how few can we protect and how many can we deport even with clear evidence that we have sent people to be tortured and killed.
Asylum seekers make the incredibly difficult decision to upend their lives and uproot their families to seek safety and stability; once in the United States, they enrich and strengthen our communities. If this rule becomes final, the United States will no longer be a place of welcome for these brave people.
The Trump administration has already begun dismantling the asylum system, returning countless asylum seekers to harm and death. I object to these rules because I fear for the lives of those who will be deported to harm, and because I object to the false assertions the administration makes throughout the proposed rules, labeling asylum seekers as fraudsters without proof and in furtherance of racist and xenophobic stereotypes. Implementation of these rules will irrevocably devastate the United States asylum system and leave even more asylum seekers without anywhere to turn for safety. The Department of Homeland Security and the Department of Justice should immediately withdraw their current proposal, and instead dedicate their efforts to ensuring that individuals fleeing violence are granted full and fair access to asylum protections in the United States.
I am particularly outraged to see that these proposed rules will make asylum unavailable for nearly all women, and particularly for survivors of domestic violence and gender-based harm. Violence against women is a global crisis. In many countries state protection for survivors is non-existent. It shocks the conscience for the United States to turn its back on survivors. Domestic violence, when the perpetrators are protected by the state must be addressed by our laws and asylum provided to these victims, who, if deported back to their country of origin would be placed in immediate harm.
Also, the proposed rules would shut LGBTQI individuals out of asylum protections, an unconscionable action when in many parts of the world being lesbian, gay, bisexual, transgender, or intersex, means living with persistent harassment and violence. Sexual activity between two people of the same gender is still considered a crime in 70 countries. Refusing protection to those fleeing violence and harm because of their gender identity or sexual orientation will sentence countless refugees to harm and even death. Again, the moral principle should be that we protect as many as can be protected because we believe in the right to life and liberty.
Gang violence also should be an area of concern for our rules. Homicide rates in Central American cities are among the highest in the word, and children and young adults face unrelenting cycles of recruitment, extortion, and sexual violence. People make the excruciating decision to flee their homes and loved ones when they cannot find protection from their own government. Yet the proposed rules would categorically exclude these asylum seekers from protections, a shameful abdication of the United States’ most basic obligations to protect asylum seekers from return to harm
Across the board, the proposed rules will make it difficult if not impossible for refugees arriving in the United States to actually access the asylum system, at a time when scores of anti-asylum policies have already caused asylum rates in the United States to plummet. The rules impose harsh new standards of proof for threshold asylum interviews and allow immigration adjudicators to summarily reject asylum claims before applicants—many of whom are experiencing trauma and preparing their cases without legal representation—are able to properly present their case. Every asylum seeker should have the right to legal representation and counsel to be able to best explain their case.
In conclusion, our laws and regulations should be based on the principle that we seek to protect as many as possible, including from gang violence, domestic violence, violence and discrimination based on gender identity and/or sexual orientation when the country of origin is not able to provide those protections to their own people. The United States must continue to stand for Life and Liberty or we have abdicated our moral standing.
Thanks. A good letter.
I used the NIJC link, copy & pasted their text into a word document, then edited it, added to it, subtracted until I could fit a different enough comment into the comment form. I hope that others will do the same.
Here is my comment. Since this administration likes to boast about its supposed Christian values, I wanted to make sure they knew I oppose their new rules because of my faith:
I am writing today to express my strong opposition to the proposed rules, DHS/EOIR; RIN 1125-AA94; EOIR Docket No. 18-0002, which would define asylum in such a narrow way that it would essentially eliminate the protection entirely. The rules impose harsh new standards of proof for threshold asylum interviews and allow immigration adjudicators to summarily reject asylum claims before applicants—many of whom are experiencing trauma and preparing their cases without legal representation—are able to properly present their case. This makes it one of the most devastating and comprehensive attacks on asylum seekers yet. The U.S. government continues to place unnecessary burdens on those fleeing harm in their countries of origins to find safety here, and I believe this is wrong.
Asylum is a human right, and asylum seekers make the incredibly difficult decision to upend their lives and uproot their families to seek safety and stability. These people are not a threat, in fact, they enrich and strengthen the communities that welcome them. If this rule becomes final, the United States will no longer be a place of welcome for these brave people, and we will ultimately be a weaker, poorer nation.
As a devout Christian, I believe that we have an absolute duty to care for the weak and oppressed. This command to defend and protect our neighbor is a constant refrain throughout the Bible, from Moses to Christ himself. Some verses members of this administration might like to be reminded of include:
“Rescue those who are being taken away to death; hold back those who are stumbling to the slaughter. If you say, “Behold, we did not know this,” does not he who weighs the heart perceive it? Does not he who keeps watch over your soul know it, and will he not repay man according to his work?” (Proverbs 24:11-12)
“Give justice to the poor and the fatherless; maintain the right of the afflicted and the destitute. Rescue the weak and the needy; deliver them from the hand of the wicked.” (Psalm 82:3-4)
“Thus says the Lord: Do justice and righteousness, and deliver from the hand of the oppressor him who has been robbed. And do no wrong or violence to the resident alien, the fatherless, and the widow, nor shed innocent blood in this place.” (Jeremiah 22:3)
“Is not this the fast that I the LORD choose: to loose the bonds of wickedness, to undo the straps of the yoke, to let the oppressed go free, and to break every yoke? Is it not to share your bread with the hungry and bring the homeless poor into your house; when you see the naked, to cover him, and not to hide yourself from your own flesh?” (Isaiah 58:6-7)
“If anyone is poor among your fellow Israelites in any of the towns of the land the Lord your God is giving you, do not be hardhearted or tightfisted toward them. Rather, be openhanded and freely lend them whatever they need.” (Deuteronomy 15:7-8)
“Then [the Lord] will say to those on his left, ‘Depart from me, you who are cursed, into the eternal fire prepared for the devil and his angels. For I was hungry and you gave me nothing to eat, I was thirsty and you gave me nothing to drink, I was a stranger and you did not invite me in, I was naked and you did not clothe me, I was sick and in prison and you did not look after me. “They also will answer, ‘Lord, when did we see you hungry or thirsty or a stranger or naked or sick or in prison, and did not help you?’ He will reply, ‘Truly I tell you, whatever you did not do for one of the least of these, you did not do for me.’ “Then they will go away to eternal punishment, but the righteous to eternal life.” (Matt 25:41- 46)
The Bible could not be more clear. If we do not help those in need, we are betraying God himself and his explicit commands, and we will suffer the consequences.
If this President truly wants to present himself as a leader who believes in and defends Christian values, then he will withdraw these new draconian laws against asylum seekers and listen to the Scriptures he claims to love. He will stop making false assertions about asylum seekers without proof and will seek to help as many find safety as possible.
Please, for the sake of the woman and children fleeing violence and persecutions, and for the sake of your own souls, stop these proposed rules and protect the right to asylum.
This was mine. I guess I tried to play to the audience:
I am writing today to express my strong opposition to the proposed rules, DHS/EOIR; RIN 1125-AA94; EOIR Docket No. 18-0002, which is one of the most devastating and comprehensive attacks on asylum seekers yet. The U.S. government has made it harder and harder for people fleeing harm in their countries of origins to find safety here, and I think this is wrong, and ultimately, self-defeating.
I believe the United States should welcome refugees and asylum seekers into our communities because its one of the ways in which it exerts soft power and influence on a global scale. Its one of the things that grants us a degree of moral authority and credibility regarding our role in international politics.
Just from a purely pragmatic and self-interested perspective, it seems foolish not to use all of the tools at our disposal. There is also a cost to be paid in terms of lost potential. Being able to recruit talent from a wider range of options is one of the things that has placed and kept the US on top.
These proposed changes have the potential to change all that for the worse.
Done. this is what I wrote.
As a gay man, out for 50 years, I have frequently felt like a refugee in my own country. I listen to the attacks by political leaders on my community, on ME, on my brothers and sisters, all for the purpose of making money and accruing power, but with no thought at all for the actual common good, let alone capital-T TRUTH. I listen to the attacks by supposed “Christians“, attacks based upon dubious and odious interpretations of even more dubious And odious biblical passages, filled with lies, slander, reviling, notably lacking in thought, facts, logic, and experience, all for the purpose of scapegoating an innocent minority for the purpose of harvesting power, money, and religious dominion.
And all of that using an alleged “faith“ as a shield behind which to hide a vicious, ancient, and durable prejudice.
There is absolutely no difference between the homohatred that hides behind political ideology or “sincere” “religious” “belief”— multiple quotation marks intentional— and the anti-immigrant and/or racial hatred that barely bothers to hide at all behind political ideology, “Christian” “Nationalism”, and exclusionary belief systems. It is all about promoting hatred for the “other“, with the goal of procuring power and money on the backs of innocent people.
My gay, lesbian, and trans brothers and sisters are frequently fleeing their own countries, even their own families, because one misstep, one confidence given to the wrong person or in the wrong situation, can result in a loss of family, career, Freedom, or even of life itself. Our country appears to my brothers and sisters as the beacon of freedom and hope, as it has to every other immigrant for every other reason— as it appeared once to me and to my many friends and family members, before its dark underbelly of fear made itself so very obvious….
…Before those who wish to exploit fear and misunderstanding for power and profit, or their own very obvious personal issues, were able to gain the influence that enable them to attack others.
I have no issue with people who wish to come here and are willing to live in peace with their neighbors. As an atheist and as a gay man, I think that all people willing to live in peace with their neighbors and contribute to the common good are beneficial to society. I have no issue with people seeking asylum from oppressive foreign lands. My ancestors did precisely that: they came here from Eastern Europe, seeking asylum and a better life for their families because of anti-Jewish oppression there.
I am absolutely in favor of a well regulated, fair, open and honest asylum, immigration, and naturalization system and process. We no longer live in a world where the troubles and evils in one part are of no interest or concern in another. Diminishing the humanity and worth of asylum seekers and immigrants does absolutely nothing to make our country better, or Americans a better people. Quite the opposite. It makes the values we supposedly hold dear appear to be nothing more than tinsel of the cheapest quality, and dismisses and diminishes our own humanity under the pretense of giving our self-laudatory theatrics a reality it simply does not have.
As a gay man, as an atheist, a Jew, and an empathetic human being, I am absolutely opposed to eliminating or restricting asylum, either de facto or de jure.
We ought to be better than this. One sickening rationalization for anti-gay bigotry in this country is “Well, at least we’re not as bad as the Muslims.” By denying gay, lesbian, and trans refugees asylum, we are proving that while not willing to throw the victims off of buildings ourselves, or behead them, or hang them, as happened to two BOYS in Iran a few years ago, we are perfectly fine with being complicit with psychopathic autocrats and theocrats the world over.
That’s not what I want for my brothers and sisters. That’s not what I want for my country.
I sent off a comment yesterday. Was to sleepy to comment here that I’d done so. Thank you so much for the heads up.