The Center for Constitutional Rights (CCR), in conjunction with the National Immigration Project of the National Lawyers Guild, responded this week to a request for comments from Immigration and Customs Enforcement (ICE). The comments respond to Federal Register request for public comment to ICE’s draft questionnaire called Form 70-008 aimed at stakeholders of the new “Secure Communities” initiative. The new initiative is designed to increase information sharing between local departments of corrections, law enforcement, the Federal Bureau of Investigations (FBI) and immigration authorities. Through increased information sharing, ICE believes that Secure Communities will be able to target “the most dangerous criminal aliens” for deportation. Blurring the lines between local enforcement and the federal immigration authorities can lead to racial profiling, increased incarceration and deportation of noncitizens with US Citizen family members and community ties.

CCR and the National Immigration Project object to the release of the current draft of the survey tool because it fails to adequately assess attitudes towards Secure Communities. The survey neglects to address important concerns and lessons learned from similar immigration initiatives like 287(g) agreements. Specifically, the survey ignores critical questions of cost, infrastructure support, monitoring, training and oversight that undeniably affect attitudes and opinions about Secure Communities. The eight recommendations submitted to ICE suggest that the survey incorporate precise questions regarding the tracking of law enforcement abuse and compliance with national and local racial profiling policies. We suggest that ICE assess the available capacity of stakeholders and that ICE clarify its goals and policies to ensure a common understanding of the purpose and procedure of Secure Communities.

Download more information about the National Immigration Project and CCR’s submitted comments below.

For additional information, read the Federal Register announcement.