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AILA's Comments on DOJ/EOIR Regulations
AILA's Comments on DOJ/EOIR Regulations
2004 -2002
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2001 - 1997
AIC/AILA Comments on DOJ Regulatory Review
(944 KB - 11/28/2012)
AIC/AILA comments in response to the advance notice of proposed rulemaking published in the Federal Register on 9/28/12 as part of the DOJ “Retrospective Regulatory Review” under Executive Order 13563. Includes comments on 8 CFR Parts 1003, 1216, and 1235. AILA Doc. No. 12112860.
AILA Comments on OSC’s Forthcoming I-9 Guidance on Self-Audits
(637 KB - 11/13/2012)
AILA’s comments and clarifications on OSC’s stakeholder input session held on 9/13/12, addressing the topic of forthcoming guidance for employer self-audits of Employment Eligibility Verification forms (Form I-9). Special thanks to Montserrat Miller and Marketa Lindt. AILA Doc. No. 12111344.
AILA Comments on EOIR’s Recognition and Accreditation Program
(643 KB - 4/6/2012)
AILA’s comments on the regulations governing the EOIR Recognition and Accreditation Program, encouraging EOIR to adopt additional safeguards to help strengthen the program and combat program-related fraud. AILA Doc. No. 12040644.
AILA Comments on DOJ Regulatory Review
(67 KB - 4/1/2011)
AILA’s comments on the Department of Justice’s implementation of Executive Order 13563, “Improving Regulation and Regulatory Review.” Special thanks to the AILA EOIR Liaison Committee and the AILA Refugee & Asylum Liaison Committee. AILA Doc. No. 11040163.
Immigration Council Submits Recommendations for Protecting the Right to Effective Assistance of Counsel
(11/13/2009)
The American Immigration Council and AILA sent a letter to the Executive Office for Immigration Review recommending steps the immigration courts and the Board of Immigration Appeals can take to protect the right to effective assistance of counsel and help ensure that noncitizens in removal proceedings are afforded a fair hearing. AILA Doc. No. 09111364.
AILA Comment on EOIR’S Proposed Rules for Professional Responsibility
(85 KB - 9/30/2008)
AILA’s comment on the proposed rule, “Professional Conduct for Practitioners – Rules and Procedures, and Representation and Appearances,” stresses the need for greater clarity of standards for misconduct, the need for application of the rules to government attorneys, and the need to reexamine the disciplinary procedures. AILA Doc. No. 08093060.
AILA’s Comment to EOIR’s Practice Manual
(81 KB - 9/10/2008)
AILA’s comment to EOIR’s Practice Manual. Submitted to EOIR on September 10, 2008. AILA Doc. No. 08091066.
AILF and AILA Comment on EOIR’S Proposed Rule on “Streamlining”
(75 KB - 8/21/2008)
AILF and AILA’s comment on the proposed rule, “Board of Immigration Appeals: Affirmance Without Opinion, Referral for Panel Review, and Publication of Decisions as Precedents,” stresses the need for federal court oversight over the “AWO” procedure and objects to EOIR’s proposal to allow two permanent BIA members to issue precedent decisions. AILA Doc. No. 08082174.
AILF and AILA Comment on EOIR's Proposed Rule to Amend Voluntary Departure Regulations
(56 KB - 2/1/2008)
AILF and AILA submitted comments to EOIR's proposed rule on voluntary departure. The proposed rule provides that the filing of a motion to reopen or reconsider or a petition for review automatically terminates the grant of voluntary departure. AILA Doc. No. 08020137.
AILA Comment on EOIR's Notice on Codes of Conduct for Immigration Judges and BIA Members
(79 KB - 7/31/2007)
AILA’s comment prepared by Holly Cooper, Maile Hirota, Linda Kenepaske, and Steve Morley in response to the EOIR Notice on Codes of Conduct for Immigration Judges and BIA members. AILA Doc. No. 07073167.
AILA/AILF Comment on the DOJ Proposed Rule on Jurisdiction and Venue in Removal Proceedings
(4/27/2007)
In a comment submitted on 4/26/07, AILA and AILF urge the DOJ to reconsider proposed regulations regarding venue determinations for removal proceedings. The proposed rule fails to carry out its intended purpose of “greater clarity and consistency of interpretation” and does not adequately address the statutory language at 8 USC §1252(b)(2). AILA Doc. No. 07042772.