Innovation Law Lab engages in the rulemaking process to defend the right to asylum. Over the past two years, we have opposed proposed regulatory changes that attack this right, including changes that would limit work authorization for asylum-seeking immigrants, undermine the integrity of immigration court adjudication, and obstruct legal service provision. Our comments seek to uphold procedural rights, to protect the substantive law of asylum, and to illustrate the tangible impacts of proposed changes.

Asylum Procedures and Eligibility

• LL Comment on Expansion of Criminal Bars to Asylum – January 21, 2020
• LL Comment on Proposed Asylum Regulations – July 15, 2020
• LL Comment on Public Health Asylum Ban – August 10, 2020
• LL Comment on Revised Asylum Procedures – October 22, 2020
• LL Comment on Proposed CFI and Asylum Procedures – October 19, 2021
• LL Comment on Proposed Asylum Ban Rule – March 27, 2023

Limitations on Work Authorization

• LL Comment on Changes to EAD Eligibility – January 13, 2020

Immigration Court Organization and Procedures

• LL Comment on Reorganization of the Executive Office for Immigration Review – October 25, 2019
• LL Comment on Appellate Procedures and Decisional Finality of Immigration Proceedings – September 25, 2020
• LL Comment on Changes to Motions to Reopen and Stays of Removal – December 28, 2020
• LL Comment on Limitations to Continuances in Immigration Court – December 28, 2020

Requirements of Legal Service Providers

• LL Comment on EOIR Limited Representation – October 30, 2020