LatinoJustice Submits Letter to Federal Register Opposing Immigrant Registry Requirement
FOR IMMEDIATE RELEASE
April 14, 2025
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LatinoJustice Submits Letter to Federal Register Opposing Immigrant Registry Requirement
New York, NY – LatinoJustice PRLDEF, a national civil rights organization, submitted a formal letter to the Federal Register in response to the Department of Homeland Security’s (DHS) U.S. Citizenship and Immigration Services (USCIS) Interim Final Rule published on March 12, 2025, on the Alien Registration Form and Evidence of Registration. The rule’s authority lies in the Alien Registration Act of 1940 and it requires all undocumented immigrants to register with the federal government or risk prison time and fines.
The Interim Final Rule (IFR) mandates that all undocumented individuals aged 14 and older register with the federal government, provide fingerprints and personal information, and carry registration documents at all times or face criminal penalties, including fines up to $1,000 a day and imprisonment.
LatinoJustice in its letter draws comparisons to past federal programs whose roots lay in the Alien Registration Act of 1940—such as the internment of Japanese Americans (most of whom were citizens) during World War II and the post-9/11 National Security Entry-Exit Registration System (NSEERS). These programs, LatinoJustice argues, caused significant harm to immigrant communities, undermined civil liberties, and failed to enhance national security.
“The NSEERS program led to over 13,000 deportations and widespread fear in Muslim communities, without a single terrorism-related conviction,” said Karen Muñoz, Associate Counsel at LatinoJustice PRLDEF. “We’ve seen how these types of registries play out. They lead to mass surveillance, racial profiling, and serious violations of civil rights.”
LatinoJustice PRLDEF also outlines multiple legal and civil rights concerns with the IFR including the lack of public input sought by DHS, which bypassed standard rulemaking policies by mislabeling the rule as procedural and avoiding public comment as required under the Administrative Procedure Act. The comments add that by requiring individuals to update address information within 10 days and the threat of criminal penalties, and “show-me-your-papers” disproportionately harms Latino, Black, Indigenous, and immigrant communities, and criminalizes youth.
In addition, the LatinoJustice letter indicates that the mandatory use of Form G-325R compels individuals to disclose personal history, potentially violating the Fifth Amendment right against self-incrimination. The rule may also infringe on Equal Protection and Due Process principles and chill First Amendment freedoms by discouraging free speech, religious practice, and protest due to fear of profiling.
“This rule criminalizes undocumented people, undermines due process, and stokes fear in our immigrant communities,” said Namratha Somayajula, Columbia Justice Fellow, LatinoJustice PRLDEF. “LatinoJustice strongly opposes the IFR and demands that all immigrant communities be treated with dignity and their rights be respected. We urge DHS to withdraw the rule immediately.”
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About LatinoJustice
LatinoJustice PRLDEF works to create a more just society by using and challenging the rule of law to secure transformative, equitable and accessible justice, by empowering our community and by fostering leadership through advocacy and education. For over 50 years, LatinoJustice PRLDEF has acted as an advocate against injustices throughout the country. To learn more about LatinoJustice, visit www.LatinoJustice.org