Families Belong Together: Comment on a Proposed Federal Rule

Holy God, as you have accompanied your people

through times of captivity, wilderness, and exile,

shelter and sustain all those who flee persecution,

oppression, warfare, violence, hunger, and poverty.

Open our hearts and homes, our gates and doors,

so that they might find safety, peace, and welcome—

a place to live in freedom and without fear;

through Jesus Christ, the hope of the world. Amen.

— Presbyterian Book of Common Worship (WJK, 2018), 631


Immigration policy in the U.S. is a complex mixture of laws passed by Congress (statutes), regulations/rules made by the Administration intended to enforce law, case law decided by the nation’s courts, and executive orders put in place by the U.S. President. Federal agencies, like the Department of Homeland Security (DHS) are then tasked with enforcing this law.

The current Administration has proposed a new rule that will make significant changes to standards for detention of migrant children in custody of the U.S. government (with and without their families). Administrative rule changes are public record and open to public comment before taking effect, so you now have the opportunity to comment on this drastic change in policy.

The timing is critical because the comment period closes on Tuesday, Nov. 6. This rule affects the Flores Settlement Agreement, “Apprehension, Processing, Care, and Custody of Alien Minors and Unaccompanied Alien Children,” which currently protects the welfare of migrant children in U.S. government custody. This proposed rule includes more than 400 pages of changes to standards for children and families in detention. Although some changes would be beneficial to families, the most glaring inconsistencies with current policy and practices are the government’s right to detain families and children indefinitely, including those seeking asylum. This approach disregards proven alternatives to mass detention. Catholic Legal Immigration Network, Inc. (CLINIC) created a toolkit that breaks down the rule change and how to make a public comment.

The comment period for the Flores rule will close on November 6, 2018! It is important to make comments online to ensure timely delivery.  

You may submit a comment at the Families Belong Together supported initiative at https://www.fwd.us/action/stop-family-detention-comment/The comment box already has editable text that will get you started, but be sure to edit it and add to this basic “ask” so that your comment is your own. It needs to be unique enough for DHS to count it as a distinct comment!

Click here for more information and talking points to help you write your comment.

To read the Stated Clerk’s response to yesterday’s announcement about policy changes on the border, click here.

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