American Gateways opposes all aspects of the Proposed Rule that would erode the due process rights of asylum seekers or otherwise impede—in any way—the ability of individuals who have suffered persecution to access humanitarian protection in the United States. At the same time, American Gateways expresses heightened concern regarding the disproportionate harms that will befall certain refugees—namely, detained and pro se asylum seekers—if the Proposed Rule is not withdrawn.

A sincere thanks to our partners at Baker Botts for helping to draft these comments.