The following sample points are meant to serve as guides for people of faith to submit comments against the proposed rule by the Department of Homeland Security on standards established during the Flores court agreement. The proposed rule would strip existing immigrant child protection standards, making it standard to keep children in detention. Comments against proposed regulations are most helpful when they are unique. Use the sample points below as guides for your comment but add your experience/expertise in your final comment. Do not cut and paste comments without customizing!
Customize your comment
If you have credibility in an issue area, say so. If you are a subject matter expert and offer comments on your area of expertise, explain why you are uniquely qualified to offer this perspective. If you are or your organization is an expert on a topic relevant to the proposed regulations, such as child welfare, please detail how these proposed rules would fail to safeguard children’s welfare and instead run counter to child welfare best practices. If possible, include data and examples. If you or your congregation work directly with immigrant children and/or their families, please describe, e.g., why they usually come to the U.S.; whether and how being detained factors into their decision to come to the U.S. and/or their decision to go through the process of seeking asylum or other protections; how detention affects their well-being and/or compromises their right to due process of law; and the need for alternatives to detention to protect family welfare and due process. Your comment should reflect why you think this proposed rule change should never take effect.Additional resources
To learn more about the proposed Flores rule and how to organize others to submit comments, visit the Catholic Legal Immigration Network Inc (CLINIC)’s Flores Mini-toolkit. To submit comments, please visit the fwd.us site designed to make commenting an easier process. or submit comments through our partners at the Columban Center for Advocacy and Outreach. To view a list of comprehensive template comments on the proposed Flores regulations, visit this site put together by multiple organizations.Sample Points
Do not cut and paste comments without customizing. They must be unique to count as separate!Our faithful calling
- Welcoming others and caring for the most vulnerable are part of my/our core beliefs as people of faith. I/we believe U.S policies should reflect core moral values that I/we was/were taught through my faith. Our government should provide broad protections for all children, regardless of citizenship, in the custody of the United States government.
- U.S. policies on immigration and the treatment of all children should recognize the gifts, contributions, and struggles of immigrants and refugees, ensuring justice and protection for all.
- Our/my faith tradition(s) have presence around the world. Through this work, we know the families and children who will be affected by this rule change. They are fleeing their communities due to violence and have faced incredible challenges in hopes of seeking protection in the United States. The rule change would hurt already vulnerable children who had hope to find a safe place in our country.
Faith and Child protection
- This rule change would destroy child protection standards the U.S. government and court system established, hurting some of the most vulnerable among us. Our faith grounding has led my/our denomination to advocate for the highest child protection standards to be applied to children in U.S. custody without additional qualifiers. Our treatment of children in U.S. policy is a moral decision that speaks to who we are as a nation.
- There is no reason to enact a rule change that would keep families and children in detention longer. Faith-based organizations, such as Lutheran Immigration and Refugee Service and the U.S. Conference of Catholic Bishops, have piloted community-based alternatives to detention (ATDs) that are humane, cost-effective and successful in ensuring families continue their immigration cases. Most recently, in 2013 these organizations coordinated ATDs for asylum seekers and vulnerable communities. Faith-based and secular organizations have the expertise to provide services to children and families that honor their God-given humanity and follow child protection standards while they go through their legal process.
- People of faith have started ministries so that children are held in the least restrictive setting while going through their immigration process. Faithful people foster children who do not have a family member in the U.S. and become their sponsors so they can go to school, receive the mental health care they need, and be welcomed into our communities. We live out our faith in many ways. The proposed change would make it harder for our communities to walk alongside people we are called to welcome.
Faith and expanding detention
- People of faith have stood strongly against family separation and family detention, regardless of administration, because it hurts some of the most vulnerable among us.
- Detaining mothers and fathers with their children leads to long-term trauma for children and creates barriers to legal representation for people who should receive protection in the U.S. It is inhumane and dehumanizing to put families seeking protection in detention.
- Beyond punishing children and parents who have already been through a difficult journey to arrive in the U.S., there is no reason to implement rule changes that could potentially increase the detention of children.