Brief Comments Regarding DHS Proposed Rule on Employment Authorization for Certain Classes of Aliens With Final Orders of Removal, 85 Fed. Reg. 74,196 (November 19, 2020)

The American Immigration Council, the American Immigration Lawyers Association, and Immigrant Legal Defenseomments relating to the Department of Homeland Security's proposed rule to restrict or prohibit work authorization for individuals with final orders of removal. The proposed rule is unlawful, without justification, and cruel in its stated purpose of penalizing vulnerable individuals by depriving them of the ability to earn a living to force them to self-deport.