Professional Conduct for Practitioners, Scope of Representation and Appearances, 11446-11448 [2019-05838]
Download as PDF
11446
Proposed Rules
Federal Register
Vol. 84, No. 59
Wednesday, March 27, 2019
This section of the FEDERAL REGISTER
contains notices to the public of the proposed
issuance of rules and regulations. The
purpose of these notices is to give interested
persons an opportunity to participate in the
rule making prior to the adoption of the final
rules.
DEPARTMENT OF JUSTICE
Executive Office for Immigration
Review
8 CFR Parts 1003 and 1292
[EOIR Docket No. 18–0301; RIN 1125–AA83]
Professional Conduct for Practitioners,
Scope of Representation and
Appearances
• Mail: Lauren Alder Reid, Assistant
Director, Office of Policy, Executive
Office for Immigration Review, 5107
Leesburg Pike, Suite 2616, Falls Church,
VA 22041. To ensure proper handling,
please reference EOIR Docket No. 18–
0301 on your correspondence. This
mailing address may be used for paper,
disk, or CD–ROM submissions.
• Hand Delivery/Courier: Lauren
Alder Reid, Assistant Director, Office of
Policy, Executive Office for Immigration
Review, 5107 Leesburg Pike, Suite 2616,
Falls Church, VA 22041. Contact
Telephone Number (703) 305–0289.
FOR FURTHER INFORMATION CONTACT:
Lauren Alder Reid, Assistant Director,
Office of Policy, Executive Office for
Immigration Review, 5107 Leesburg
Pike, Suite 2616, Falls Church, VA
22041, telephone (703) 305–0289 (not a
toll-free call).
SUPPLEMENTARY INFORMATION:
Executive Office for
Immigration Review, Department of
Justice.
ACTION: Advance notice of proposed
rulemaking with request for comment.
I. Public Participation
The Department of Justice
(Department) is evaluating the
possibility of revising the rules and
procedures governing representation
and appearance during proceedings
before the Executive Office for
Immigration Review’s (EOIR)
immigration courts and Board of
Immigration Appeals (BIA). The
Department is considering whether to
amend those rules to allow for, and
identify the nature and scope of,
authorized practitioners’ limited
representation of aliens before EOIR.
The Department is issuing this advance
notice of proposed rulemaking
(ANPRM) to solicit public suggestions
for any such potential amendments to
the relevant portions of EOIR’s
regulations.
DATES: The Department invites written
or electronic comments from members
of the public submitted on or before
April 26, 2019. Written comments
postmarked on or before that date will
be considered timely. The electronic
Federal Docket Management System
will accept comments prior to midnight
Eastern Time at the end of that day.
ADDRESSES: You may submit comments,
identified by EOIR Docket No. 18–0301
or RIN 1125–AA83, by one of the
following methods:
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
Interested persons are invited to
submit written data, views, or
arguments on all aspects of this
ANPRM. EOIR also invites comments
that relate to the economic,
environmental, or federalism effects that
might result from any regulatory
changes related to these matters.
Please note that all comments
received are considered part of the
public record and made available for
public inspection at
www.regulations.gov. Such information
includes personally identifiable
information (such as a person’s name,
address, or any other data that might
personally identify that individual) that
the commenter voluntarily submits.
If you want to submit personally
identifiable information as part of your
comment, but do not want it to be
posted online, you must include the
phrase ‘‘PERSONALLY IDENTIFIABLE
INFORMATION’’ in the first paragraph
of your comment and precisely and
prominently identify the information of
which you seek redaction.
If you want to submit confidential
business information as part of your
comment, but do not want it to be
posted online, you must include the
phrase ‘‘CONFIDENTIAL BUSINESS
INFORMATION’’ in the first paragraph
of your comment and precisely and
prominently identify the confidential
business information of which you seek
redaction. If a comment has so much
AGENCY:
SUMMARY:
VerDate Sep<11>2014
17:45 Mar 26, 2019
Jkt 247001
PO 00000
Frm 00001
Fmt 4702
Sfmt 4702
confidential business information that it
cannot be effectively redacted, all or
part of that comment may not be posted
on www.regulations.gov. Personally
identifiable information and
confidential business information
provided as set forth above will be
placed in the agency’s public docket
file, but not posted online. To inspect
the agency’s public docket file in
person, you must make an appointment
with agency counsel. Please see the FOR
FURTHER INFORMATION CONTACT
paragraph above for the agency
counsel’s contact information specific to
this rule.
II. Background
The Immigration and Nationality Act
(INA) provides that aliens appearing
before an immigration judge and on
appeal before the BIA ‘‘shall have the
privilege of being represented, at no
expense to the Government, by counsel
of the alien’s choosing who is
authorized to practice in such
proceedings.’’ INA § 240(b)(4)(A) (8
U.S.C. 1229a(b)(4)(A)); see also INA
§ 292 (8 U.S.C. 1362). Attorneys in good
standing and accredited representatives
approved by EOIR are eligible to
represent respondents in EOIR
proceedings, as well as certain other
persons as provided in 8 CFR 1292.1.
In order to represent an alien before
EOIR, an attorney or representative must
meet the regulatory requirements,
including the filing of a Notice of Entry
of Appearance as Attorney or
Representative before the Immigration
Court (Form EOIR–28) or a Notice of
Entry of Appearance as Attorney or
Representative before the Board of
Immigration Appeals (Form EOIR–27),
as appropriate. See 8 CFR 1003.3(a)(3),
1003.17, 1003.38(g), and part 1292.
Representation continues in the
proceedings for which an attorney or
representative enters an appearance
before EOIR, whether it is front of the
immigration court or the BIA. The
representation continues until and
unless the immigration judge or the BIA,
whichever applies, grants an oral or
written motion to withdraw or
substitute. See 8 CFR 1003.17(b),
1003.38(g), 1292.4(a).1
1 In 2003, the Attorney General redesignated the
previous regulations in 8 CFR parts 3 and 292,
relating to EOIR, as 8 CFR parts 1003 and 1292 in
connection with the abolition of the former
Immigration and Naturalization Service and the
E:\FR\FM\27MRP1.SGM
27MRP1
Federal Register / Vol. 84, No. 59 / Wednesday, March 27, 2019 / Proposed Rules
Historically, EOIR did not permit
limited appearances by attorneys and
accredited representatives. That is, prior
to a regulatory change published in
2015, an attorney or accredited
representative who entered an
appearance on behalf of a respondent
for any purpose was deemed to be the
person’s representative for purposes of
all of immigration court or BIA
proceedings for which they entered an
appearance, including bond proceedings
and removal proceedings.
In 2015, the Department published a
final rule to allow representatives ‘‘to
enter an appearance solely to custody
and bond proceedings before the
Immigration Court’’ by amending 8 CFR
1003.17(a). 80 FR 59500 (Oct. 1, 2015).
In response to a comment seeking a
broadening of the limited scope of
representation permitted, the
Department noted that the regulations
would still require ‘‘a representative of
record to represent an individual in all
aspects of each separate type of
proceeding, unless the immigration
judge grants a motion to withdraw or
substitute counsel.’’ 80 FR 59501.
Therefore, when an attorney or
authorized representative enters an
appearance before an immigration court,
the appearance may be entered for
representation in ‘‘custody or bond
proceedings only, any other proceedings
only, or for all proceedings’’ before an
immigration judge. 8 CFR 1003.17(a).
In any case appealed to the BIA, the
alien may also be represented by an
attorney or representative. See 8 U.S.C.
1362. Representation before the BIA
continues until and unless withdrawal
or substitution of attorney or
representative is permitted. See 8 CFR
1003.38(g), 1292.4(a).
In addition to the foregoing
regulations dealing with appearances,
the current EOIR regulations also
include definitions pertaining to
practice. See 8 CFR 1001.1(i) and (k):
(i) The term practice means the act or acts
of any person appearing in any case, either
in person or through the preparation or filing
of any brief or other document, paper,
application, or petition on behalf of another
transfer of its responsibilities to the Department of
Homeland Security. 68 FR 9824 (Feb. 28, 2003).
Under the Homeland Security Act, EOIR (including
the BIA and the immigration courts) remains under
the authority of the Attorney General. See 6 U.S.C.
521; 8 U.S.C. 1103(g). 8 CFR 1292.4(a) (previously
8 CFR 292.4(a)) provides that withdrawal/
substitution of counsel before the BIA is permitted
in accordance with 8 CFR 1003.36 (previously 8
CFR 3.36). However, 8 CFR 3.36 (later 8 CFR
1003.36) was redesignated as 8 CFR 3.38 (later 8
CFR 1003.38) in April 1992. See 57 FR 11568,
11570 (Apr. 6, 1992). Thus, the correct reference in
8 CFR 1292.4(a) should be to 8 CFR 1003.38(g).
Further, the reference to 1003.16 should be
understood as a reference to 1003.17.
VerDate Sep<11>2014
17:45 Mar 26, 2019
Jkt 247001
person or client before or with DHS, or any
immigration judge, or the Board.
*
*
*
*
*
(k) The term preparation, constituting
practice, means the study of the facts of a
case and the applicable laws, coupled with
the giving of advice and auxiliary activities,
including the incidental preparation of
papers, but does not include the lawful
functions of a notary public or service
consisting solely of assistance in the
completion of blank spaces on printed
Service forms by one whose remuneration, if
any, is nominal and who does not hold
himself out as qualified in legal matters or in
immigration and naturalization procedure.
The Department is now considering
further revision to EOIR’s regulations
governing the rules of practice and the
scope of appearance and representation
in proceedings before the immigration
courts and the BIA.
III. Request for Public Comments
Before proposing any specific
regulatory text for public comment, the
Department is seeking preliminary input
from the public. In addition to soliciting
suggestions and comments in responses
to the specific questions raised in this
ANPRM, the Department is particularly
interested in hearing from all those who
have a stake in providing, receiving, or
coordinating representation in the
immigration court system. The
Department is interested in hearing all
views related to the possibility of
expanding procedures for the limited
representation of aliens in proceedings
before EOIR.
Question 1: Should the Department
permit certain types of limited
representation currently impermissible
under regulations? If so, to what extent?
If not, why not?
Question 2: Should limited
representation be permitted to allow
attorneys or representatives to appear at
a single hearing in proceedings before
EOIR, possibly leaving the respondent
without representation for a subsequent
hearing on the same filing? If so, to what
extent? If not, why not?
Question 3: Should limited
representation be permitted to allow
attorneys or representatives to prepare
or file a pleading, application, motion,
brief, or other document without
providing further representation in the
case? If not, why not? If so, should
attorneys or representatives be required
to identify themselves as the author of
the document or should anonymity (i.e.,
ghostwriting) be permitted?
Question 4: If limited representation
is permitted in proceedings before EOIR,
should an attorney or representative be
required to file a Notice of Entry of
Appearance regardless of the scope of
the limited representation? If so, should
PO 00000
Frm 00002
Fmt 4702
Sfmt 4702
11447
a form separate from the EOIR–27 and
EOIR–28 be created for such
appearances?
Question 5: If limited representation
is permitted, should attorneys or
representatives certify to EOIR, either
through a form or filings made, that the
alien has been informed about the
limited scope of the representation?
Question 6: If limited representation
is permitted in proceedings before EOIR,
to what extent should such attorneys or
representatives have access to the
relevant record of proceedings?
Question 7: To what extent could
different approaches for limited
representation impair the adjudicative
process or encourage abuse or other
misconduct that adversely affects EOIR,
the public, or aliens in proceedings, or
lead to increased litigation regarding
issues of ineffective assistance of
counsel?
Question 8: What safeguards, if any,
should be implemented to ensure the
integrity of the process associated with
limited representation in proceedings
before EOIR, and to prevent any
potential abuse and fraud?
Question 9: What kinds of constraints
or legal concerns with respect to limited
representation may arise under state
rules of ethics or professional conduct
for attorneys who are members of the
bar in the various states?
Question 10: Should EOIR provide
that practitioners, as a condition of
representing aliens in a limited manner,
be required to agree to limit their fees
in charging for their services?
Question 11: The Department is
interested in gathering other
information or data relating to the issue
of expanding limited appearances in
EOIR proceedings. Are there any
additional issues or information not
addressed by the Department’s
questions that are important for the
Department to consider? Please provide
as much detail as possible in your
response.
Comments that will provide the most
assistance to EOIR will reference a
specific regulatory section, provide draft
regulatory language, explain the reasons
for the recommended amendment, and
include data, information, or authority
that support the recommended
amendment.
IV. Statutory and Executive Order
Review
This ANPRM has been drafted and
reviewed in accordance with Executive
Order 12866, ‘‘Regulatory Planning and
Review,’’ section 1(b), The Principles of
Regulation, in accordance with
Executive Order 13563, ‘‘Improving
Regulation and Regulatory Review,’’
E:\FR\FM\27MRP1.SGM
27MRP1
11448
Federal Register / Vol. 84, No. 59 / Wednesday, March 27, 2019 / Proposed Rules
section 1(b), General Principles of
Regulation, and in accordance with
Executive Order 13771, ‘‘Reducing
Regulation and Controlling Regulatory
Costs.’’ The Department has determined
that this ANPRM is a significant
regulatory action under Executive Order
12866, section 3(f), and accordingly this
ANPRM has been reviewed by the
Office of Management and Budget.
Pursuant to guidance issued by OMB,
the requirements of E.O. 13771 do not
apply to this ANPRM.
This action does not propose or
impose any requirements. The ANPRM
is being published to seek information
from the public regarding the possibility
of revising the rules and procedures
governing representation and
appearance during proceedings before
EOIR’s immigration courts and the BIA.
The requirements of the Regulatory
Flexibility Act (RFA) do not apply to
this action because, at this stage, it is an
ANPRM and not a ‘‘rule’’ as defined in
5 U.S.C. 601. Following review of the
comments received in response to this
ANPRM, if EOIR decides to proceed
with a notice of proposed rulemaking
regarding this matter, EOIR will conduct
all relevant analyses as required by
statute or Executive Order.
Dated: March 5, 2019.
James R. McHenry,
Director.
[FR Doc. 2019–05838 Filed 3–26–19; 8:45 am]
BILLING CODE 4410–30–P
DEPARTMENT OF AGRICULTURE
Animal and Plant Health Inspection
Service
9 CFR Parts 50, 51, 71, 76, 77, 78, 86,
93, and 161
[Docket No. APHIS–2011–0044]
RIN 0579–AD65
Brucellosis and Bovine Tuberculosis;
Update of General Provisions
Animal and Plant Health
Inspection Service, USDA.
ACTION: Proposed rule; partial
withdrawal.
AGENCY:
We are announcing a partial
withdrawal of a proposed rule
published in the Federal Register on
December 16, 2015, that, if finalized,
would have consolidated the regulations
governing bovine tuberculosis and those
governing brucellosis. Specifically, we
are withdrawing those portions of the
proposed rule that would have affected
the provisions governing our domestic
SUMMARY:
VerDate Sep<11>2014
17:45 Mar 26, 2019
Jkt 247001
brucellosis and tuberculosis programs.
We are taking this action after
considering the comments we received
following the publication of the
proposed rule.
DATES: As of March 27, 2019, the
proposed amendments to 9 CFR parts
50, 51, 71, 76, 77, 78, 86, and 161 that
were contained in the proposed rule
published December 16, 2015 (80 FR
78462) are withdrawn.
FOR FURTHER INFORMATION CONTACT: Dr.
C. William Hench, Senior Staff
Veterinarian, Cattle Health Center,
Strategy and Policy VS, APHIS, 2150
Centre Avenue, Building B–3E20, Fort
Collins, CO 80526–8117; (970) 494–
7378.
SUPPLEMENTARY INFORMATION: On
December 16, 2015, we published in the
Federal Register (80 FR 78462–78520,
Docket No. APHIS–2011–0044) a
proposed rule 1 to amend the regulations
in 9 CFR parts 50, 51, 71, 76, 77, 78, 86,
93, and 161 to consolidate the
regulations governing bovine
tuberculosis, and those governing
brucellosis. The proposed rule would
have affected both domestic and import
regulations for the two diseases.
We solicited comments concerning
our proposal for 90 days ending on
March 15, 2016. We extended the
deadline for comments until May 16,
2016, in a document published in the
Federal Register on March 11, 2016 (81
FR 12832–12833, Docket No. APHIS–
2011–0044,). We received a total of 164
comments by that date. They were from
captive cervid producers and captive
cervid breeders’ associations, cattle
industry groups, State agriculture
departments, State game and fish
departments, veterinarians,
representatives of foreign governments,
and private citizens. The commenters
raised a number of comments and
concerns about the proposed rule.
The commenters were especially
concerned with the proposal to combine
the bovine tuberculosis and brucellosis
domestic programs into a single
program for cattle, bison, and captive
cervids. The commenters pointed to
differing disease epidemiology, source
populations, modes of transmission,
surveillance streams, movement
controls, testing, and management
practices.
Commenters were also concerned by
our proposal to require States to submit
animal health plans that detail cattle,
bison, and captive cervid demographics
in the State, information regarding
1 To view the proposed rule, supporting
documents, and the comments we received, go to
https://www.regulations.gov/
#!docketDetail;D=APHIS-2011-0044.
PO 00000
Frm 00003
Fmt 4702
Sfmt 4702
sources of bovine tuberculosis or
brucellosis in the State, surveillance and
mitigations in the State, and personnel
available to enforce the plan. The
commenters expressed concern that the
States may lack personnel, resources,
and funding to implement and maintain
Animal Health Plans, based on the
proposed requirements.
Commenters expressed concern about
our proposal to base State statuses on
whether a State has implemented and is
maintaining an Animal Health Plan
instead of prevalence rates, saying that
it seemed to be a move away from
disease eradication and international
standards, and pointing out that it
would require foreign trading partners
to re-evaluate their requirements for
importing U.S. cattle.
We proposed that, if an area had a
known source of tuberculosis and
brucellosis that presents a risk, that area
could not be accredited or reaccredited.
We further proposed to require whole
herd tests and individual animal tests
for captive cervids as a condition of
interstate movement, unless they come
from accredited herds for brucellosis.
Many captive cervid producers
expressed concern that if these changes
were adopted, they would lose their
current accreditation. Several
commenters questioned the need for a
national requirement for what they
consider a regional problem. Elk
breeders expressed concern about the
cost of this requirement, and stated that
our economic analysis underestimated
testing costs.
We proposed that exhibited, rodeo,
and event cattle and bison would have
to be tested 60 days prior to initial
interstate movement, then at 180 day
intervals after initial interstate
movement, with limited exceptions.
Many State animal health officials and
several industry groups objected to
considering exhibited cattle and bison
equivalent to rodeo and event cattle and
bison in terms of disease risk. They
stated that exhibited cattle and bison
are, in their experience, a very low risk
for bovine tuberculosis and brucellosis,
and these requirements could adversely
impact regional fairs and exhibitions.
Finally, wildlife and animal health
authorities expressed significant
concern about our proposal that, if a
State has known wildlife sources of
bovine tuberculosis or brucellosis that
pose a risk of transmission to program
animals, the State would have to
conduct surveillance of these source
populations in a manner sufficient to
detect brucellosis or tuberculosis in an
animal within the source population.
Several animal health officials stated
that wildlife authorities in some States
E:\FR\FM\27MRP1.SGM
27MRP1
Agencies
[Federal Register Volume 84, Number 59 (Wednesday, March 27, 2019)]
[Proposed Rules]
[Pages 11446-11448]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-05838]
========================================================================
Proposed Rules
Federal Register
________________________________________________________________________
This section of the FEDERAL REGISTER contains notices to the public of
the proposed issuance of rules and regulations. The purpose of these
notices is to give interested persons an opportunity to participate in
the rule making prior to the adoption of the final rules.
========================================================================
Federal Register / Vol. 84, No. 59 / Wednesday, March 27, 2019 /
Proposed Rules
[[Page 11446]]
DEPARTMENT OF JUSTICE
Executive Office for Immigration Review
8 CFR Parts 1003 and 1292
[EOIR Docket No. 18-0301; RIN 1125-AA83]
Professional Conduct for Practitioners, Scope of Representation
and Appearances
AGENCY: Executive Office for Immigration Review, Department of Justice.
ACTION: Advance notice of proposed rulemaking with request for comment.
-----------------------------------------------------------------------
SUMMARY: The Department of Justice (Department) is evaluating the
possibility of revising the rules and procedures governing
representation and appearance during proceedings before the Executive
Office for Immigration Review's (EOIR) immigration courts and Board of
Immigration Appeals (BIA). The Department is considering whether to
amend those rules to allow for, and identify the nature and scope of,
authorized practitioners' limited representation of aliens before EOIR.
The Department is issuing this advance notice of proposed rulemaking
(ANPRM) to solicit public suggestions for any such potential amendments
to the relevant portions of EOIR's regulations.
DATES: The Department invites written or electronic comments from
members of the public submitted on or before April 26, 2019. Written
comments postmarked on or before that date will be considered timely.
The electronic Federal Docket Management System will accept comments
prior to midnight Eastern Time at the end of that day.
ADDRESSES: You may submit comments, identified by EOIR Docket No. 18-
0301 or RIN 1125-AA83, by one of the following methods:
Federal eRulemaking Portal: https://www.regulations.gov.
Follow the instructions for submitting comments.
Mail: Lauren Alder Reid, Assistant Director, Office of
Policy, Executive Office for Immigration Review, 5107 Leesburg Pike,
Suite 2616, Falls Church, VA 22041. To ensure proper handling, please
reference EOIR Docket No. 18-0301 on your correspondence. This mailing
address may be used for paper, disk, or CD-ROM submissions.
Hand Delivery/Courier: Lauren Alder Reid, Assistant
Director, Office of Policy, Executive Office for Immigration Review,
5107 Leesburg Pike, Suite 2616, Falls Church, VA 22041. Contact
Telephone Number (703) 305-0289.
FOR FURTHER INFORMATION CONTACT: Lauren Alder Reid, Assistant Director,
Office of Policy, Executive Office for Immigration Review, 5107
Leesburg Pike, Suite 2616, Falls Church, VA 22041, telephone (703) 305-
0289 (not a toll-free call).
SUPPLEMENTARY INFORMATION:
I. Public Participation
Interested persons are invited to submit written data, views, or
arguments on all aspects of this ANPRM. EOIR also invites comments that
relate to the economic, environmental, or federalism effects that might
result from any regulatory changes related to these matters.
Please note that all comments received are considered part of the
public record and made available for public inspection at
www.regulations.gov. Such information includes personally identifiable
information (such as a person's name, address, or any other data that
might personally identify that individual) that the commenter
voluntarily submits.
If you want to submit personally identifiable information as part
of your comment, but do not want it to be posted online, you must
include the phrase ``PERSONALLY IDENTIFIABLE INFORMATION'' in the first
paragraph of your comment and precisely and prominently identify the
information of which you seek redaction.
If you want to submit confidential business information as part of
your comment, but do not want it to be posted online, you must include
the phrase ``CONFIDENTIAL BUSINESS INFORMATION'' in the first paragraph
of your comment and precisely and prominently identify the confidential
business information of which you seek redaction. If a comment has so
much confidential business information that it cannot be effectively
redacted, all or part of that comment may not be posted on
www.regulations.gov. Personally identifiable information and
confidential business information provided as set forth above will be
placed in the agency's public docket file, but not posted online. To
inspect the agency's public docket file in person, you must make an
appointment with agency counsel. Please see the FOR FURTHER INFORMATION
CONTACT paragraph above for the agency counsel's contact information
specific to this rule.
II. Background
The Immigration and Nationality Act (INA) provides that aliens
appearing before an immigration judge and on appeal before the BIA
``shall have the privilege of being represented, at no expense to the
Government, by counsel of the alien's choosing who is authorized to
practice in such proceedings.'' INA Sec. 240(b)(4)(A) (8 U.S.C.
1229a(b)(4)(A)); see also INA Sec. 292 (8 U.S.C. 1362). Attorneys in
good standing and accredited representatives approved by EOIR are
eligible to represent respondents in EOIR proceedings, as well as
certain other persons as provided in 8 CFR 1292.1.
In order to represent an alien before EOIR, an attorney or
representative must meet the regulatory requirements, including the
filing of a Notice of Entry of Appearance as Attorney or Representative
before the Immigration Court (Form EOIR-28) or a Notice of Entry of
Appearance as Attorney or Representative before the Board of
Immigration Appeals (Form EOIR-27), as appropriate. See 8 CFR
1003.3(a)(3), 1003.17, 1003.38(g), and part 1292. Representation
continues in the proceedings for which an attorney or representative
enters an appearance before EOIR, whether it is front of the
immigration court or the BIA. The representation continues until and
unless the immigration judge or the BIA, whichever applies, grants an
oral or written motion to withdraw or substitute. See 8 CFR 1003.17(b),
1003.38(g), 1292.4(a).\1\
---------------------------------------------------------------------------
\1\ In 2003, the Attorney General redesignated the previous
regulations in 8 CFR parts 3 and 292, relating to EOIR, as 8 CFR
parts 1003 and 1292 in connection with the abolition of the former
Immigration and Naturalization Service and the transfer of its
responsibilities to the Department of Homeland Security. 68 FR 9824
(Feb. 28, 2003). Under the Homeland Security Act, EOIR (including
the BIA and the immigration courts) remains under the authority of
the Attorney General. See 6 U.S.C. 521; 8 U.S.C. 1103(g). 8 CFR
1292.4(a) (previously 8 CFR 292.4(a)) provides that withdrawal/
substitution of counsel before the BIA is permitted in accordance
with 8 CFR 1003.36 (previously 8 CFR 3.36). However, 8 CFR 3.36
(later 8 CFR 1003.36) was redesignated as 8 CFR 3.38 (later 8 CFR
1003.38) in April 1992. See 57 FR 11568, 11570 (Apr. 6, 1992). Thus,
the correct reference in 8 CFR 1292.4(a) should be to 8 CFR
1003.38(g). Further, the reference to 1003.16 should be understood
as a reference to 1003.17.
---------------------------------------------------------------------------
[[Page 11447]]
Historically, EOIR did not permit limited appearances by attorneys
and accredited representatives. That is, prior to a regulatory change
published in 2015, an attorney or accredited representative who entered
an appearance on behalf of a respondent for any purpose was deemed to
be the person's representative for purposes of all of immigration court
or BIA proceedings for which they entered an appearance, including bond
proceedings and removal proceedings.
In 2015, the Department published a final rule to allow
representatives ``to enter an appearance solely to custody and bond
proceedings before the Immigration Court'' by amending 8 CFR
1003.17(a). 80 FR 59500 (Oct. 1, 2015). In response to a comment
seeking a broadening of the limited scope of representation permitted,
the Department noted that the regulations would still require ``a
representative of record to represent an individual in all aspects of
each separate type of proceeding, unless the immigration judge grants a
motion to withdraw or substitute counsel.'' 80 FR 59501. Therefore,
when an attorney or authorized representative enters an appearance
before an immigration court, the appearance may be entered for
representation in ``custody or bond proceedings only, any other
proceedings only, or for all proceedings'' before an immigration judge.
8 CFR 1003.17(a).
In any case appealed to the BIA, the alien may also be represented
by an attorney or representative. See 8 U.S.C. 1362. Representation
before the BIA continues until and unless withdrawal or substitution of
attorney or representative is permitted. See 8 CFR 1003.38(g),
1292.4(a).
In addition to the foregoing regulations dealing with appearances,
the current EOIR regulations also include definitions pertaining to
practice. See 8 CFR 1001.1(i) and (k):
(i) The term practice means the act or acts of any person
appearing in any case, either in person or through the preparation
or filing of any brief or other document, paper, application, or
petition on behalf of another person or client before or with DHS,
or any immigration judge, or the Board.
* * * * *
(k) The term preparation, constituting practice, means the study
of the facts of a case and the applicable laws, coupled with the
giving of advice and auxiliary activities, including the incidental
preparation of papers, but does not include the lawful functions of
a notary public or service consisting solely of assistance in the
completion of blank spaces on printed Service forms by one whose
remuneration, if any, is nominal and who does not hold himself out
as qualified in legal matters or in immigration and naturalization
procedure.
The Department is now considering further revision to EOIR's
regulations governing the rules of practice and the scope of appearance
and representation in proceedings before the immigration courts and the
BIA.
III. Request for Public Comments
Before proposing any specific regulatory text for public comment,
the Department is seeking preliminary input from the public. In
addition to soliciting suggestions and comments in responses to the
specific questions raised in this ANPRM, the Department is particularly
interested in hearing from all those who have a stake in providing,
receiving, or coordinating representation in the immigration court
system. The Department is interested in hearing all views related to
the possibility of expanding procedures for the limited representation
of aliens in proceedings before EOIR.
Question 1: Should the Department permit certain types of limited
representation currently impermissible under regulations? If so, to
what extent? If not, why not?
Question 2: Should limited representation be permitted to allow
attorneys or representatives to appear at a single hearing in
proceedings before EOIR, possibly leaving the respondent without
representation for a subsequent hearing on the same filing? If so, to
what extent? If not, why not?
Question 3: Should limited representation be permitted to allow
attorneys or representatives to prepare or file a pleading,
application, motion, brief, or other document without providing further
representation in the case? If not, why not? If so, should attorneys or
representatives be required to identify themselves as the author of the
document or should anonymity (i.e., ghostwriting) be permitted?
Question 4: If limited representation is permitted in proceedings
before EOIR, should an attorney or representative be required to file a
Notice of Entry of Appearance regardless of the scope of the limited
representation? If so, should a form separate from the EOIR-27 and
EOIR-28 be created for such appearances?
Question 5: If limited representation is permitted, should
attorneys or representatives certify to EOIR, either through a form or
filings made, that the alien has been informed about the limited scope
of the representation?
Question 6: If limited representation is permitted in proceedings
before EOIR, to what extent should such attorneys or representatives
have access to the relevant record of proceedings?
Question 7: To what extent could different approaches for limited
representation impair the adjudicative process or encourage abuse or
other misconduct that adversely affects EOIR, the public, or aliens in
proceedings, or lead to increased litigation regarding issues of
ineffective assistance of counsel?
Question 8: What safeguards, if any, should be implemented to
ensure the integrity of the process associated with limited
representation in proceedings before EOIR, and to prevent any potential
abuse and fraud?
Question 9: What kinds of constraints or legal concerns with
respect to limited representation may arise under state rules of ethics
or professional conduct for attorneys who are members of the bar in the
various states?
Question 10: Should EOIR provide that practitioners, as a condition
of representing aliens in a limited manner, be required to agree to
limit their fees in charging for their services?
Question 11: The Department is interested in gathering other
information or data relating to the issue of expanding limited
appearances in EOIR proceedings. Are there any additional issues or
information not addressed by the Department's questions that are
important for the Department to consider? Please provide as much detail
as possible in your response.
Comments that will provide the most assistance to EOIR will
reference a specific regulatory section, provide draft regulatory
language, explain the reasons for the recommended amendment, and
include data, information, or authority that support the recommended
amendment.
IV. Statutory and Executive Order Review
This ANPRM has been drafted and reviewed in accordance with
Executive Order 12866, ``Regulatory Planning and Review,'' section
1(b), The Principles of Regulation, in accordance with Executive Order
13563, ``Improving Regulation and Regulatory Review,''
[[Page 11448]]
section 1(b), General Principles of Regulation, and in accordance with
Executive Order 13771, ``Reducing Regulation and Controlling Regulatory
Costs.'' The Department has determined that this ANPRM is a significant
regulatory action under Executive Order 12866, section 3(f), and
accordingly this ANPRM has been reviewed by the Office of Management
and Budget. Pursuant to guidance issued by OMB, the requirements of
E.O. 13771 do not apply to this ANPRM.
This action does not propose or impose any requirements. The ANPRM
is being published to seek information from the public regarding the
possibility of revising the rules and procedures governing
representation and appearance during proceedings before EOIR's
immigration courts and the BIA. The requirements of the Regulatory
Flexibility Act (RFA) do not apply to this action because, at this
stage, it is an ANPRM and not a ``rule'' as defined in 5 U.S.C. 601.
Following review of the comments received in response to this ANPRM, if
EOIR decides to proceed with a notice of proposed rulemaking regarding
this matter, EOIR will conduct all relevant analyses as required by
statute or Executive Order.
Dated: March 5, 2019.
James R. McHenry,
Director.
[FR Doc. 2019-05838 Filed 3-26-19; 8:45 am]
BILLING CODE 4410-30-P