SIGN ON TO LETTER OPPOSING LATEST EOIR REGULATORY ASSAULT ON DUE PROCESS! — Act By 11:59 pm on Thursday evening!

Admin and Imm Prof Comment – EOIR Reorganization Interim Rule

From: ‘Jennifer S Breen’ via ImmProf [mailto:immprof@lists.ucla.edu]
Sent: Tuesday, October 22, 2019 11:56 AM
To: immprof@lists.ucla.edu; adminlaw@chicagokent.kentlaw.edu
Subject: [immprof] Sign-On Comment re: EOIR Reorganization Interim Rule

 

Dear colleague-

 

Please consider signing onto the attached comment in response to the interim rule recently issued by the Executive Office of Immigration Review. The comment was drafted by Lenni Benson, Jill Family, and me.

 

We are circulating the comment to both the ImmProf and Administrative Law Professor lists (apologies for cross-posting!) because the comment embraces an administrative law “best practices” approach to immigration adjudication.

 

Our comment is centered on on two changes made by the rule:  1) the attempt to codify the creation of the Office of Policy within EOIR, and 2) the delegation of adjudicatory power to the Director of EOIR and his designees (including the Assistant Director of the newly created Office of Policy).

 

The comment opposes the rule because it compromises the fairness of immigration proceedings by diminishing due process, creates inefficiencies in the adjudication process, and violates basic principles of good administrative process design. Further, because the interim rule will not achieve its intended effect and because it is part of a larger scheme to damage the independence of immigration adjudication, the rule is arbitrary and capricious.

 

Please use the following link to add your signature to the comment:

 

https://forms.gle/cXKrGHJMC2WCUmVA6

 

Comments are due Friday, so all signatures must be received by 11:59 pm on Thursday evening.

 

Thanks very much for considering this request.

 

Jenny Breen

 

 

Jennifer Stepp Breen

Associate Professor

Syracuse University College of Law

 

T 315.443.2392

jsbreen@law.syr.edu

321 Dineen Hall, 950 Irving Ave., Syracuse, NY 13244

law.syr.edu

 

Syracuse University

 

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I signed on.

PWS

10-22-19