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July 13, 2020
"Comments in Opposition to Proposed Rulemaking: 85 FR 36264 RIN 1125-AA94; 1615-AC42 EOIR Docket No. 18-0002; A.G. Order No. 4714-2020
The Round Table of Former Immigration Judges is composed of 46 former Immigration Judges and Appellate Immigration Judges of the Board of Immigration Appeals. We were appointed by and served under both Republican and Democratic administrations. We have centuries of combined experience adjudicating asylum applications and appeals. Our members include nationally-respected experts on asylum law; many regularly lecture at law schools and conferences and author articles on the topic.
... The proposed rules are impermissibly arbitrary and capricious. They attempt to overcome, as opposed to interpret, the clear meaning of our asylum statutes. Rather than interpret the views of Congress, the proposed rules seek to replace them in furtherance of the strongly anti-immigrant views of the administration they serve.3 And that they seek to do so in an election year, for political gain, is clear.
... [W]e strongly urge the Departments to withdraw all sections of the proposed rule."