Take Action: Defend Asylum & Protect Survivors of Gender-Based Violence

(see below for sample comment templates, instructions on submitting comments, webinars, and resources)

Since 1980, when the Refugee Act incorporated our treaty obligations into domestic law and created the asylum system, the United States has offered people fleeing persecution in their home countries the chance to seek safe haven here. For anyone fleeing life-threatening harm due to their gender, asylum protection provides hope. To escape violence. To protect their children. To build a new life.

On June 15, casting aside decades of legal precedent and defying our humanitarian obligations, the Department of Justice (DOJ) and Department of Homeland Security (DHS) released a proposed rule that would make sweeping changes to eligibility for and the process to seek asylum, withholding of removal, and protection under the Convention Against Torture (CAT).

The proposed rule would sharply curtail protection for all asylum-seekers, and effectively eliminate “gender-based asylum” altogether by

  • cutting off access to asylum for women fleeing rape, severe domestic violence, human trafficking, and other forms of horrific gender-based persecution.

  • sharply narrowing other eligibility criteria such that it would also deny protection to feminist activists and others who fight for equal rights in matters of education, employment, and other spheres, even when those activities make them targets for brutal retaliatory violence and oppression.

Among many other concerns for advocates for survivors, the proposed rule would also prohibit asylum-seeking survivors in “expedited removal” from applying for protection under the Violence Against Women Act (VAWA) or Trafficking Victims Protection Act (TVPA). It would also allow for disclosure of information in an asylum application under a slew of new circumstances, potentially providing opportunities for abusers to obtain survivors’ information.

The good news? The asylum rule is currently a proposal and not yet in place. The public has just until 11:59 pm EDT on July 15 to provide feedback on the impact the proposed rule will have on vulnerable immigrants fleeing life-threatening persecution. Join the Alliance for Immigrant Survivors (AIS) and our partners in opposing this harmful proposal by lifting your voice and submitting your public comment today!

HOW TO SUBMIT YOUR COMMENT & COMMENT TEMPLATES

AIS and our partners have developed sample comment templates for you to use to draft your unique comment in opposition to the proposal. The administration is required by law to review and respond to every unique public comment they receive about the proposed regulation, so we strongly encourage you to personalize and modify the template to speak to your own experiences and perspective, as well as those of the survivors you work with.

  1. Download sample comment templates or visit click-to-comment sites:

  2. Edit comments as you wish to personalize them and make them unique.

  3. Submit your comments at this link by uploading a pdf, which is what we strongly recommend to avoid loss of formatting,  particularly to preserve links to supporting materials that can be important to build a strong case against the rule.

  4. Contact us at info@immigrantsurvivors.org if you have any questions or problems.

Some commenting tips:

  • The administration requires that all comments be submitted in English.

  • Ideally, your comments explain how this rule change will harm immigrant survivors, which could include you, your family, your clients, or your community.

  • If you do not want to include any personal information, a friend or representative can submit a comment for you.

  • If you have any questions about this process, please contact info@immigrantsurvivors.org.

The United States has long served as a beacon of hope for vulnerable individuals fleeing persecution. We cannot and will not allow survivors to be returned to life-threatening violence. Please submit your comment in opposition to the harmful asylum rule TODAY.

AIS CO-CHAIRS COMMENTS ON ASYLUM RULE

ADDITIONAL ORGANIZATION COMMENTS ON ASYLUM RULE

PAST ASYLUM WEBINAR RESOURCES

  • “Shutting Doors: How the U.S. is Poised to End Asylum & Turn Its Back on the Persecuted,” ABA Commission on Sexual & Domestic Violence, Commission on Immigration, and Section on Civil Rights and Social Justice, June 23. Webinar recording online here.

  • “The End of Asylum: Administration’s New Regulation Would Devastate U.S. Asylum System,” American Immigration Council, June 25. Webinar recording online here.

  • “Our Asylum System at Grave Risk: What You Can Do,” CLINIC, June 26. Webinar recording online here.

  • “Death by a Thousand Cuts - The Trump Administration’s Proposed Rulemaking to Gut Asylum,” Center for Gender & Refugee Studies (CGRS) and American Constitution Society (ACS) Bay Area Lawyer Chapter. Overview of the proposed rule and how to submit a comment, as well of U.S. asylum law history and conditions in asylum seekers’ home countries. CLE materials online here.

  • “Attack on the U.S. Asylum System: FAQs on the Proposed Asylum Rule,” Center for Gender & Refugee Studies, July 9. Webinar recording online here.

  • “Briefing: Proposed Changes to U.S. Asylum System,” HIAS, July 9. Webinar recording and slides available online here.

  • “Comment Writing Workshop (LGBTQ-Focused),” Center Global, July 9. Webinar recording online here.

ADDITIONAL RESOURCES