RE: Comment on Notice of Proposed Rulemaking on Inadmissibility on Public Charge Grounds (Docket ID: USCIS-2010-0012)
Dear Ms. Deshommes:
Kids in Need of Defense (KIND) appreciates the opportunity to comment on the Notice of Proposed Rulemaking “Inadmissibility on Public Charge Grounds” (“Proposed Rule”), issued by U.S. Citizenship and Immigration Services (USCIS) on October 10, 2018 (83 FR 51114). The Proposed Rule would expand the scope of the public charge rule by adding new public benefits programs and worsen an existing chilling effect that is currently limiting access to public benefits by vulnerable children and families in need. KIND urges USCIS to withdraw the Proposed Rule, which would destabilize immigrant families and have a significant and detrimental impact on the health and well-being of child survivors of violence, trauma, and abuse.
KIND is a national nonprofit organization dedicated to providing free legal representation and protection to unaccompanied immigrant and refugee children in removal proceedings. Since January 2009, KIND has received referrals for more than 16,800 children from 70 countries, and has trained more than 30,000 attorneys to represent such children. KIND has field offices in ten cities: Los Angeles, San Francisco, Atlanta, Baltimore, Boston, Houston, Newark, New York City, Seattle, and Washington, DC. Legal services professionals who serve children through KIND provide defense in removal proceedings, and pursue immigration benefits and relief for which their clients may be eligible.
As minors who have fled violence, abandonment, and unsafe situations, unaccompanied children served by KIND arrive in the U.S. with very limited resources and face enormous challenges: healing from a history of trauma, overcoming language and educational barriers, and preparing their legal cases, among others. Social service and public benefits programs are of critical importance in ensuring these children have the support they need as they begin to process 2 and heal from harrowing violence, trauma, and abuse, and to navigate a new country and community.