First Focus on Children submitted the following comment to the U.S. Department of Homeland Security urging them to withdraw the “Circumvention of Lawful Pathways” proposed rule in its entirety and instead uphold the laws establishing our humanitarian protection system and implement policies and procedures that make children’s best interests the primary consideration.

Excerpt from the Comment:

There are life or death consequences for children who do not receive protection in our immigration system. Without policies that take their experiences and needs into account, children may be wrongfully denied legal protection, separated from family, and returned to persecution. Instead of ensuring due process and access to protection for children, this proposed rule would impose new, unrealistic barriers for children and families seeking asylum, and in practice would be a new version of similar asylum bans promulgated by the Trump Administration that were repeatedly struck down by federal courts as unlawful.

Read the full comment.