American Gateways opposes all aspects of the Proposed Rule that would interfere with judicial independence, undermine the integrity of the immigration court system, and/or erode the due process rights of people in immigration proceedings. At the same time, American Gateways expresses heightened concern regarding the disproportionate harms that would befall certain immigrants, especially pro se and detained individuals, as well as other vulnerable individuals seeking humanitarian protection in the United States.

A sincere thanks to our partners at Baker Botts for helping to draft these comments.