Comment: Appellate Procedures for the Board of Immigration Appeals

April 7, 2026

Re: Appellate Procedures for the Board of Immigration Appeals, EOIR Docket No. EOIR–
26–AB37 | RIN 1125–AB37

Dear Assistant Director Comans:
Asian Americans Advancing Justice | AAJC (AAJC) and the Southeast Asia Resource Action Center (SEARAC) respectfully submit this comment in response to the Executive Office of Immigration Review’s (EOIR) interim final rule (IFR) fundamentally restructuring appellate review before the Board of Immigration Appeals (BIA).1 Southeast Asian deportation cases are complicated and involve significant barriers to representation. These cases are often dependent on meaningful appellate review. The IFR’s limitations will have a disproportionate impact on Southeast Asian immigrants and refugees, particularly those who have had contact with the criminal legal system. For this reason, we urge EOIR to rescind the IFR.

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