December 11, 2017

VIA ELECTRONIC MAIL
Cameron Quinn
Officer for Civil Rights and Civil Liberties
Department of Homeland Security
Washington, DC 20528
John V. Kelly
Acting Inspector General
Department of Homeland Security
Washington, DC 20528
Re:

The Separation of Family Members Apprehended by or Found Inadmissible while in
U.S. Customs and Border Protection (CBP) Custody at the U.S.-Mexico Border

Dear Ms. Quinn and Mr. Kelly:
The undersigned organizations jointly file this complaint on behalf of numerous family members
who have been separated while in federal custody at the U.S. border, including instances in which
one family member has been referred for criminal prosecution by the Department of Justice (DOJ).
The alarming increase in family units being forcibly divided is consistent with the current

1

 Administration’s unabated series of attacks on the most vulnerable individuals in today’s
immigration system: protection-seeking children and their family members.1
Our organizations have for years and in great detail documented the immense trauma created by
the separation of family members and the impact of separation on their ability to pursue legal
immigration relief.2 The separation of parents from their children at the U.S.-Mexico border and
within the United States, absent a justifiable child protection grounds, is so fundamentally
unconscionable it defies countless international and domestic laws on child welfare, human rights
and refugees. In addition to this it violates CBP’s own standards on family unity and subverts the
mission of the Office of Refugee Resettlement (ORR) to vouchsafe the interests of unaccompanied
children as mandated by Congress. It is cruel and unlawful to separate family members for the sole
purpose of deterring migration; such separation deprives family members the ability, given their
detention, to locate each other and be reunited.
As such, we urge your offices to continue to investigate current Department of Homeland Security
(DHS) practices in order to stop the practice of separating families for purposes of punishment and
deterrence, to ensure compliance with international and domestic standards and already articulated
DHS policies on family separation, to identify and expand humane alternatives to detention and
separation, to better track family separation incidents, and to implement meaningful mechanisms
so that separated family members can locate, contact, and reunite with one another.
BACKGROUND
Family unity is recognized as a fundamental human right, enshrined in both domestic and
international law.3 The U.S. Supreme Court has held that the right to family unity is “perhaps the
oldest of the fundamental liberty interests recognized by [the Supreme] Court.”4 While some

President Donald J. Trump’s Letter to House and Senate Leaders & Immigration Principles and Policies, October
8, 2017, available at: https://www.whitehouse.gov/the-press-office/2017/10/08/president-donald-j-trumps-letterhouse-and-senate-leaders-immigration.
2
For extensive discussion on family separation at the border in the last three years, including recommendations on
next steps, see: Women’s Refugee Commission, Kids in Need of Defense, and Lutheran Immigration and Refugee
Service, Betraying Family Values: How Immigration Policy at the United States Border is Separating Families.
March 2017. https://www.womensrefugeecommission.org/rights/gbv/resources/1450-betraying-family-values. See
also: American Immigration Council. Divided by Detention: Asylum-Seeking Families Experiences of Separation.
August 2016. https://www.americanimmigrationcouncil.org/research/divided-by-detention-asylum-seeking-familiesexperience-of-separation. See also: Jesuit Conference of the United States and Canada & Kino Border Initiative. Our
Values on the Line: Migrant Abuse and Family Separation at the Border. September 2015 Available at:
http://jesuits.org/Assets/Publications/File/REPORT_2015_Our_Values_on_the_Line.pdf.
3
Family unity as a protected right can be found in: Final Act of the 1951 U. N. Conference of Plenipotentiaries on
the Status of Refugees and Stateless Persons, Recommendation B.; U.N. International Covenant on Civil and
Political Rights, art. 23, (March 23, 1976); U.N. Convention on the Rights of the Child, art. 9 (September 2, 1990);
General Comment 6 to the Convention, “Treatment of Unaccompanied and Separated Children Outside their
Country of Origin” (CRC 2005).
4
Troxel v. Granville, 530 U.S. 57, 65 (2000). Further, the Supreme Court has held that a parent’s right to the care
and custody of his or her child “has been deemed essential, [a] basic civil right of man, and rights far more precious
than property rights.” Stanley v. Illinois, 405 U.S. 645, 651, 92 S.Ct. 1208, 31 L.Ed.2d 551 (1972).
1

2

 family members who seek protection at the U.S. border may have been separated during their
journey prior to reaching the United States, or may be separated in isolated incidents by
immigration officials due to valid concerns over the best interest of the child,5 our organizations
have noticed an alarming increase in instances of family members who arrived together but were
intentionally separated by U.S. immigration officials without a clear or reasonable justification, as
a means of punishment and/or deterrence and with few to no mechanisms to locate, contact, or
reunite with separated family members.
While our organizations are concerned about family separation and its consequences in all of these
scenarios, this particular complaint focuses largely on the separation of children from their parents
specifically in cases where those families traveled together to the United States for the purposes
of seeking protection and found themselves instead separated.
While the TVPRA authorizes the separation of children from non-parents and legal guardians in
order to prevent trafficking and comply with safe family reunification standards, several
immigration laws demonstrate Congressional intent to keep children with their parents whenever
feasible and to prioritize the reunification of separated children with parents whenever in the best
interests of the child.6
CBP currently has insufficient guidance and policies relating to definitions of what constitutes
family membership, when and how family members should be separated, if necessary, and
mechanisms to help family members once they have been separated. However, CBP’s National

For example, the passage of the Homeland Security Act of 2002 (“HSA”) and the William Wilberforce Trafficking
Victims Protection Reauthorization Act (“TVPRA”) of 2008 and, provide for the separation of children from nonparents and legal guardians in order to prevent trafficking and comply with safe family reunification standards. See
Section 462 of the HSA, Pub. L. No. 107-296, codified at: 6 U.S.C. § 279 and Section 235 of the TVPRA, Pub. L.
No. 110-457, codified at: 8 U.S.C. § 1232.
6
See e.g., The Homeland Security Act of 2002 clearly defines an unaccompanied alien child as a child with respect
to whom “no parent or legal guardian in the United States is available to provide care and physical custody.” 6
U.S.C. § 279(g)(2)(C)(ii); HSA defines ORR’s role as “…ensuring that the interests of the child are considered in
decisions and actions relating to the care and custody of an unaccompanied alien child” 6 U.S.C. § 279(b)(1)(B);
The TVPRA states that “an unaccompanied alien child in the custody of the Secretary of Health and Human
Services shall be promptly placed in the least restrictive setting that is in the best interest of the child” 8 U.S.C. §
1232(c)(2)(A); TVPRA further requires that “an unaccompanied alien child may not be placed with a person or
entity unless the Secretary of Health and Human Services makes a determination that the proposed custodian is
capable of providing for the child’s physical and mental well-being” § 1232(c)(3)(A); regulations on the custody of
children states that “Juveniles may be released to a relative (brother, sister, aunt, uncle, or grandparent) not in
Service detention who is willing to sponsor a minor and the minor may be released to that relative notwithstanding
that the juvenile has a relative who is in detention” 8 C.F.R. § 212.5(b)(3); Flores Settlement Agreement of 1997,
Case No. CV 85-4544-RJK(Px) ¶ 14 establishes a policy favoring release of all children and prioritizing their
reunification with parents, available at:
http://web.centerforhumanrights.net:8080/centerforhumanrights/children/Document.2004-06-18.8124043749; Judge
Gee upheld Plaintiffs’ motion to enforce Paragraphs 14, 18, 19, and 23 of the Agreement on the issue of whether
Defendants are making and recording continuous efforts to release class members or place them in nonsecure,
licensed facilities in accordance with the Agreement, Jenny L. Flores, et al. v. Jefferson B. Sessions, III, et al., CV
85-4544 DMG (AGRx)(C.D. C.A., June 27, 2017), available at: http://www.centerforhumanrights.org/PDFs/06-2717_Flores_2016MTE_Order.pdf.
5

3

 Standards on Transport, Escort, Detention, and Search (TEDS) do require that family units stay
together “to the greatest extent operationally feasible” absent concerns for security and safety. 7
TEDS also requires documentation if separation does occur.8
However, in early March 2017, then DHS Secretary Kelly stated that the department was formally
considering a policy of separating children from their parents at the border in order to deter their
migration to the United States.9 Among others, the American Academy of Pediatrics expressed
serious concern over the proposal, stating that authorities should “exercise caution to ensure that
the emotional and physical stress children experience as they seek refuge in the United States is
not exacerbated by the additional trauma of being separated from their siblings, parents or other
relatives and caregivers.”10 Multiple members of Congress and non-governmental organizations
strongly opposed the idea.11 We remain concerned that such a policy or practice would only drive
vulnerable migrants further into the hands of unscrupulous smugglers or traffickers when fleeing
violence for safety but fearing the prospect of family separation at the hands of U.S. immigration
agents.
Moreover, other deterrence policies have already been found to violate U.S. law in the case of
asylum-seekers.12 Countless recent reports13 show that U.S. CBP has systematically violated U.S.
7

CBP, National Standards on Transport, Escort, Detention, and Search (TEDS), available at:
https://www.cbp.gov/sites/default/files/assets/documents/2017-Sep/CBP%20TEDS%20Policy%20Oct2015.pdf. For
further discussion on the lack of clear mechanisms and policies to track and identify separated family members, see
Betraying Family Values, p. 4.
8
TEDS at 4.3 and 5.6.
9
“Kelly: DHS is considering separating undocumented children from their parents at the border.” CNN.
http://www.cnn.com/2017/03/06/politics/john-kelly-separating-children-from-parents-immigrationborder/index.html.
10
See “AAP Statement Opposing Separation of Mothers and Children at the Border.” March 4, 2017. Available at:
https://www.aap.org/en-us/about-the-aap/aap-press-room/Pages/immigrantmotherschildrenseparation.aspx. For
further discussion and recommendations on the treatment of immigrant children, see also: Linton JM, Griffin M,
Shapiro AJ, AAP Council on Community Pediatrics. Detention of Immigrant Children. Pediatrics. March 2017.
Available at: http://pediatrics.aappublications.org/content/pediatrics/early/2017/03/09/peds.2017-0483.full.pdf
11
See: “Letter to Secretary Kelly Opposing Plan to Separate Migrant Families at the Border.” March 22, 2017.
Available at: https://www.womensrefugeecommission.org/rights/gbv/resources/1460-family-separation-sign-onletter. See: House Committee on Homeland Security, March 8, 2017, available at: https://democratshomeland.house.gov/sites/democrats.homeland.house.gov/files/documents/children030817.pdf; Letter to the
Congressional Hispanic Caucus, March 8, 2017, available at: https://congressionalhispaniccaucuslujangrisham.house.gov/media-center/press-releases/congressional-hispanic-caucus-pens-letter-to-dhs-opposingseparation-of; Letter to Democratic Members of Congress, March 9, 2017, available at:
https://bass.house.gov/media-center/press-releases/rep-bass-leads-house-democrats-letter-opposing-trumpadministration-plan.
12
See R.I.L.R. v Johnson, finding that the Department of Homeland Security is prohibited from using detention (a
“No Release Policy”) as deterrence to future migration, suggesting more broadly that the government cannot use any
detention tactic—including a policy of family separation—as a deterrence for future migration because it violates
the principle of individual decision-making in detention issues. Available at: https://www.aclu.org/cases/rilr-vjohnson.
13
See, e.g., Borderland Immigration Council, Discretion to Deny: Family Separation, Prolonged Detention, and
Deterrence of Asylum Seekers at the Hands of Immigration Authorities Along the U.S.-Mexico Border, 12 (2017),
https:// media.wix.com/ugd/e07ba9_72743e60ea6d4c3aa796becc71c3b0fe.pdf (reporting that “it is commonplace
for asylum seekers to be placed in expedited removal proceedings and summarily deported . . ., despite expressing

4

 law and binding international human rights law by refusing to allow individuals access to the
asylum process by utilizing various tactics including intimidation, inhumane treatment and threats
of violence, criminal prosecution, and family separation. U.S. law mandates that asylum seekers
be provided with due process of law and access to the asylum process.14 In addition to the trauma
caused to separated family members, the practice of dividing family units at the border leads to
the unlawful result of depriving asylum seekers of access to the asylum process – as a result of the
deterrent effect of family separation and due to the unavailability of critical legal evidence and
witnesses – and stripping them of their right to seek asylum under U.S. law.
Former Secretary Kelly subsequently stated on the record while testifying before the U.S. Senate
that the DHS would not, in fact, “routinely” separate children from their families when arriving at
the border except under extenuating circumstances, such as if “the mother is sick or addicted to
drugs,” or if the life of the child was in imminent risk.15 He testified to the U.S. Senate that these
were the only circumstances mothers and children would be separated and that he “[could not]
imagine” doing so in other cases.16 Despite this, our organizations and the media are documenting
cases of separation where, to our knowledge, families were not separated on account of a mother
or father who fit this description.
Family separation incidents are continuing and appear to be increasing
Despite Constitutional protections guaranteeing parents fundamental due process rights in the care
and custody of their children, controlling Supreme Court precedent, and the government’s
commitment that children would not be separated from their family members at the border except
under extenuating circumstances, our organizations have documented numerous instances of
family separation in the last several months alone. The Florence Immigrant and Refugee Rights
Project (FIRRP), a legal service provider in Arizona, has identified 155 cases of family separation
at the border involving parents and children as of late October 2017; of these, 90 cases had occurred
fear”); U.S. Comm’n on Int’l Religious Freedom, Barriers to Protection: The Treatment of Asylum Seekers in
Expedited Removal, 20 (2016) (reporting that despite findings and recommendations in a 2005 study relating to
primary inspection, USCIRF observers in 2016 continued to find “several examples of non-compliance with
required procedures” in CBP primary inspection interviews); see also 2005 USCIRF Report, supra note 25, at 54
(finding that, in approximately half of the inspections observed, inspectors failed to read the proper advisals
regarding asylum to the non-citizen and that “in 15 percent of [the] cases [ ] where an arriving [non-citizen]
expressed a fear of return to the inspector, that [non-citizen] was not referred” for a credible fear interview).
14
U.S. Const. Amend. V. See also, e.g., Marincas v. Lewis, 92 F.3d 195, 203 (3d Cir. 1996) (“The basic procedural
rights Congress intended to provide asylum applicants . . . are particularly important because an applicant
erroneously denied asylum could be subject to death or persecution if forced to return to his or her home country.”).
8 U.S.C. § 1158(a)(1) (The INA provides that any noncitizen “who is physically present in the United States or who
arrives in the United States” has a statutory right to apply for asylum, irrespective of such individual’s status);
15
Testimony before Congress in the Senate Homeland Security and Governmental Affairs Committee hearing titled,
“Improving Border Security and Public Safety” (April 5, 2017); see also “Kelly says DHS won’t separate families at
the border.” CNN. http://www.cnn.com/2017/03/29/politics/border-families-separation-kelly/index.html. See Elise
Foley and Roque Planas,“Trump Administration Won’t Routinely Separate Families At The Border After All,”
(HuffPost April 5, 2017), available at: http://www.huffingtonpost.com/entry/dhs-separating-familiesborder_us_58e50d4fe4b0f4a923b448b7.
16
Id.

5

 in the most recent quarter as of that time, indicating a significant spike in incidents of family
separation.17
Lutheran Immigration and Refugee Service (LIRS), an organization that provides services to
unaccompanied children in transitional foster care around the country, reports that until April 2017
it had seen no cases of children separated from parents, and in May and June 2017 encountered
one each month. Beginning in July 2017, however, LIRS began to see a substantial increase, with
four cases reported in July, five cases in August, and nine cases in September.18 Separated children
can include very young children; LIRS’s FY 2017 data revealed that children’s ages ranged from
two to 15, and were an average of eight years old. In the vast majority of these cases, LIRS social
workers have not been made aware any imminent child abuse or neglect allegations that would
warrant a child’s separation from a parent consistent with child welfare standards. 19 These
incidents of family separation directly contradict then-Secretary Kelly’s statements that DHS
would not separate families unless a child was in danger.
DHS and its components have consistently demonstrated that they are unable to manage the
separation of family members in a legal and ethical manner. Family members are given little to no
information on what happens to those from whom they are separated, including how to locate,
contact, or reunite with them. DHS and its components continue to lack the ability to track familial
relationships of individuals who are transferred to Immigration and Customs Enforcement (ICE)
custody or to coordinate mechanisms to work with ORR within the Department of Health and
Human Services (HHS) or the Department of Justice (DOJ) to facilitate location of, contact with,
or release and reunification with separated family members.
Criminal prosecution of asylum seekers impedes access to protection and increasingly separates
families
The undersigned organizations have received an increase in reports of family units being broken
up where a parent traveling with a child is referred by CBP officials for prosecution by DOJ under
8 U.S.C. §1325 for illegal entry or 8 U.S.C. §1326 for illegal re-entry; parents in these cases may
have no prior criminal history or removal orders. Those who do have prior removal orders—and
who are prosecuted for illegal re-entry under 8 U.S.C. §1326—are often seeking humanitarian
relief in the United States.
A recent report in the Houston Chronicle, detailed further below, reported knowledge of 22
specific cases “in which parents […] with no history of immigration violations were prosecuted
for the misdemeanor crime of improper entry and had their children removed.” The article notes
that “[f]ederal defense attorneys across the southern border say they are fielding unprecedented
17

Data on file with authors.
Affidavit of Jessica Jones, Policy Counsel at Lutheran Immigration and Refugee Service (LIRS). December 8,
2017. On file with authors.
19
DHS PREA Regulations also set out standards for the safety of juveniles and when a report should be made to
mandated reporting agencies by CBP or ICE. See 6 CFR § 115.14, 115.114, 115.61, and 115.161.
18

6

 requests from migrant clients to find their children.”20 This reported trend is consistent with the
cases that LIRS has documented, nearly all of which “occurred after the parent or legal guardian
was criminally prosecuted for crossing the border illegally or for reentry following a prior order
of removal.”21 Indeed, according to reports in the Houston Chronicle, Border Patrol (BP) officials
affirmed at an October 2017 meeting that family separation was occurring. A subsequent email
from CBP’s Office of Assistant Chief Counsel’s noted that “‘[a]ny increase in separated family
units is due primarily to the increase in prosecutions of immigration-related crimes.’”
These cases present not only additional hurdles to family reunification, but the DHS Office of
Inspector General (OIG) has already identified the prosecution of asylum seekers as a practice that
may violate U.S. obligations under international law.22 Prosecutions which take place before an
asylum seeker is able to complete, or in many cases even begin, the process of applying for asylum
will have the effect of denying asylum seekers access to the asylum process or dissuading them
from even attempting to avail themselves of humanitarian protections in the United States.23
Asylum law in the United States shields asylum seekers from punishment (including prosecution)
for unauthorized entry.24
The Impact of Family Separation
The long-term consequences of family separation have already been well documented.25 The cases
below illustrate the same trauma and the same profound impact on the ability to express or
document a fear of return as the dozens that have previously been published and/or filed with your
agency. Separated families are desperate to understand what happened to their loved ones and may
be unable to fully articulate or provide evidence to support a claim when they have no information
about and cannot locate those with whom they traveled. Many separated individuals receive no
“Trump moves to end ‘catch and release’, prosecuting parents and removing children who cross border.” Houston
Chronicle. November 25, 2017. Available at: http://www.houstonchronicle.com/news/houstontexas/houston/article/Trump-moves-to-end-catch-and-release-12383666.php.
21
Affidavit of Jessica Jones.
22
The 1951 Refugee Convention states: “The Contracting States shall not impose penalties, on account of their
illegal entry or presence, on refugees who, coming directly from a territory where their life or freedom was
threatened.…" See: Streamline: Measuring its Effect on Illegal Border Crossing, DHS Office of the Inspector
General, May 2015, pp. 16-17, available at: https://www.oig.dhs.gov/assets/Mgmt/2015/OIG_15-95_May15.pdf.
See also: The Rise in Criminal Prosecutions of Asylum Seekers, Human Rights First, July 2017, pp. 6-7 Available at:
http://www.humanrightsfirst.org/sites/default/files/hrf-criminal-prosecution-of-asylum-seekers.pdf.
23
Sign-on Letter to Stop Streamline Prosecution of Asylum Seekers, July 10, 2015, AILA Doc. No. 15072304,
available at: http://www.aila.org/advo-media/aila-correspondence/2015/sign-on-letter-end-prosecution-of-asylumseekers?utm_source=aila.org&utm_medium=InfoNet%20Search.
24
Streamline: Measuring Its Effect on Illegal Border Crossing, p. 2.; The United States is bound through its
accession to the 1967 Protocol Relating to the Status of Refugees to Article 31(1) of the Refugee Convention, which
prohibits states from penalizing refugees for illegal entry. Because refugee status is a matter of discovery and a
refugee is, in fact, deserving of the protections of the Refugee Convention and Protocol prior to recognition of
refugee status, the referral of asylum seekers for criminal prosecution in the manner described by the OIG report is
incompatible with U.S. commitments under Article 31(1). Convention Relating to the Status of Refugees art. 31(1),
July 28, 1951, 19 U.S.T. 6259, 189 U.N.T.S. 137, available at http://www.refworld.org/docid/3be01b964.html.
25
See: Betraying Family Values, Divided by Detention, Our Values on the Line.
20

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 information on how to locate, contact, or reunite with a family member. We believe that referrals
to DOJ for prosecution only further exacerbate these circumstances.
The practice of separating families at the border will cause family members—including parents
with young children—to seek alternative ways of entering the United States, rather than presenting
at a port of entry on the U.S.-Mexico border out of fear that they will be separated. As a result,
vulnerable individuals desperate to avail themselves of humanitarian and legal protections may
fall into the hands of unscrupulous smugglers. A systemic, wide-scale policy of family separation
on the U.S.-Mexico border intended as deterrence will have dangerous repercussions for asylum
seekers attempting to access the U.S. asylum system.26 Indeed one study that conducted a statistical
analysis of DHS data on the migration of unaccompanied children from Northern Triangle
countries from 2011 through 2016, found that no U.S. policy—whether it be deterrence or not—
has a statistical impact in the migration of a child.27 Instead, the study found that the single biggest
indicator of a child’s migration was the number of homicides in locality of where the child lived,
finding that for every 10 homicides in a locality, 6 more additional children would migrate. So not
only is the practice inhumane, the premise for the policy is unfounded.
Further, the separation of family members constitutes a significant impediment to due process.
Separated family members whose cases would otherwise be linked may no longer have access to
critical physical or testimonial evidence, or the trauma of separation may preclude sharing critical
information. In one case of a separated child who had been rendered unaccompanied and was later
encountered by LIRS it was “[o]nly after talking to the parent [that] LIRS learn[ed] of why the
parent and child fled because the parent kept that information away from the child to protect the
child.”28 As families are separated at the border, an asylum-seeking individual’s spouse, parent, or
sibling—who is being held in DOJ or ICE custody in a remote detention facility hundreds or
thousands of miles away—may possess the very evidence that will enable the asylum seeker to
prevail before an Immigration Judge or the Asylum Office. The cases below demonstrates the

26

On July 12, 2017, the American Immigration Council, along with the Center for Constitutional Rights and a large
law firm, filed a class action lawsuit challenging Customs and Border Protection’s (CBP) unlawful practice of
turning away asylum seekers who present themselves at ports of entry along the U.S.-Mexico border. This litigation
remains pending at the time of submission of this complaint.
https://www.americanimmigrationcouncil.org/litigation/challenging-customs-and-border-protections-unlawfulpractice-turning-away-asylum-seekers. See also, “Rights groups sue U.S. government, alleging it is turning away
asylum applicants at Mexico border,” Washington Post, July 12, 2017, available at:
https://www.washingtonpost.com/world/the_americas/rights-groups-sue-us-government-alleging-it-is-turning-awayasylum-applicants/2017/07/12/35b95508-6650-11e7-94ab-5b1f0ff459df_story.html?utm_term=.ea50c1b28505.
27
Violence, Development, and Migration Waves: Evidence from Central American Child Migrant Apprehensions,
CGD Working Paper 459. Washington, DC: Center for Global Development, available at:
https://www.cgdev.org/publication/violence-development-and-migration-waves-evidence-central-american-childmigrant.
28

Affidavit of Jessica Jones. On file with authors.

8

 negative effects family separation may have on an individual’s legal case, which may lead to
prolonged detention for some or even deportation.
The Particular Focus on Parents and Children at the Border
Current and previous practices separating families affect every possible configuration of family
and have occurred in a variety of settings. Our organizations have received accounts of spouses or
partners being separated from one another; one or both parents from children; non-parent
caregivers from dependents; siblings or cousins (including where one or both are adult); or
situations in which one parent and child are sent to family detention while another parent and/or
child are detained in a different family detention facility. Members of the same family may be
detained in separate ORR, ICE, CBP, and DOJ facilities.
Forcibly dividing families at the border can occur in the jurisdiction of either BP or Office of Field
Operations (OFO) when someone has recently crossed, but family separation can also occur when
ICE or CBP apprehend family members who have been in the United States for a long time,
separating them from other relatives including U.S. citizen children or others. This complaint
focuses on the separation of children from their parents at the border despite having traveled to the
United States together as a unit and where, to our knowledge, there are no indications of child
trafficking or danger to the child at the hands of the parent.
INDIVIDUAL COMPLAINTS & EXAMPLES OF TRENDS OF FAMILY SEPARATION
Many of our organizations have already filed complaints with your office on behalf of individual
separated family members. The cases below represent a sample of recent cases of family members
who have been separated, with a specific emphasis on parents and children. They underscore not
only the significant emotional impact family separation can have on an adult or a child, which may
in turn frustrate his or her ability to articulate a claim for relief, but also the due process
implications of impeding access to a loved one who may possess critical legal evidence. Any
policies or practices of intentionally separating immigrant children from their parents when there
is not a specific and clear protection concern, and in particular in cases involving prosecution of
the parent, also raise serious legal concerns.
Further, these cases demonstrate the difficulties that separated family members face in locating
and reuniting with one another once separated due to insufficient policies and systems. In many
cases, family members and the service providers assisting them are not able to locate and reach all
of the different affected individuals; as a result, some of the stories are incomplete without this
additional information. Therefore, we are also including cases that were observed by service
providers but have been anonymized and should not be seen as individual complaints. These cases

9

 are denoted as such below. While in some cases more detailed affidavits may be available, not all
cases include full identifying information.29
1. Case of Sofia, whose husband was separated from their five-year-old son Rodrigo at
the U.S.-Mexico border
Sofia fled Guatemala with her husband and their two minor children. Her husband, Luis, entered
the U.S. with their five-year-old son, Rodrigo on or around November 11, 2017. Luis was separated
from his son at the border. Sofia entered the United States with their one-year-old child, Jaime,
the following day and was subsequently transferred to the South Texas Family Residential Center
(STFRC) in Dilley, Texas. Sofia learned that Rodrigo had been separated from her husband and
transferred to the custody of ORR and that her husband had been transferred to the San Luis
Regional Detention Center in Arizona. Through the assistance of her attorney, Sofia discovered
that her husband was in the custody of the U.S. Marshals and that he had likely been charged
criminally for illegal re-entry to the United States, even though he had traveled to the United States
for the purpose of seeking asylum.
Sofia reports that her attorney attempted to coordinate a phone call between her and her husband
on numerous occasions, but was informed that phone calls between detainees are not permitted
when at least one of them is in the custody of the U.S. Marshals. Sofia describes the emotional
impact of being separated from both her minor son, Rodrigo, and her husband and the negative
impact this separation had on her legal case:
When I finally spoke to Rodrigo, [my older son], we both cried. He seemed very
upset. He asked why his father had left him. I did not know what to tell him to make
him feel better. I had to lie and tell him that his dad was working and that he was
going to be brought to me very soon to try to calm him down, but it did not help
much. He is far too young to be separated from his parents. He is in a foreign
country where everything seems different and there is no one around him that he
knows.
I had my credible fear interview on Monday, November 27. I know that I cannot
return to Guatemala, and did my best to explain why to the asylum officer.
However, I feel that I really needed to speak to my husband to understand exactly
why we were in danger because he was the one who heard the threats against us
directly. I could not describe exactly what words the gang used or how many times
we were threatened. I think that my husband did not tell me the whole story because
he was trying to protect me. I am waiting and hoping that what I knew was enough
to pass the interview and that I will be called to sign a positive decision soon.
At the time of submission of this complaint, Sofia and their one-year-old child Jaime had been
released and were permitted to pursue their immigration cases in a non-detained setting; it is

29

Only pseudonyms are used in public versions of this complaint.

10

 unclear whether or not Rodrigo remains in the custody of ORR or where exactly Luis remains in
custody.
2. Aurelia, Honduras, formerly detained at Karnes County Residential Center with her
1.5-year-old daughter; separated from her husband who was transferred to U.S.
Marshals custody
Aurelia, her husband, and their 1.5-year-old daughter fled gang violence in Honduras and entered
the United States on October 22, 2017 around El Paso, Texas. Aurelia reports that after the family
was apprehended by U.S. Border Patrol authorities (BP), officers indicated to the family that, “they
were not accepting anymore [sic] families with kids.” Aurelia reports that although she requested
to call her sponsor, officials told her that they “weren’t allowed to have a lawyer, or a judge, and
that they were the judges.” She states, “[T]hey did not ask us if we feared returning to our country
and they did not give us the chance to ask for asylum.”
Aurelia reports that her husband was subsequently transferred to another facility. Aurelia was
given no information regarding his location, just that he had been transferred to a different facility
and that he would be deported after her. Although she was told she would be deported, she was
instead transferred to the Karnes County Residential Center with her 1.5-year-old daughter. She
tried repeatedly to locate her husband. She was told that he was detained in the Otero County
Processing Center, but even when Geo Group officials tried to connect her to the facility, she was
told that the facility could not locate him. She finally learned that he’d been referred to U.S.
Marshals custody, not ICE custody. Aurelia reports that her husband has no criminal history, and
writes “I only want to communicate with him and to know how he is.” Her daughter also “asks for
him every day.”
3. Maria, Guatemala, separated from her five- and 14-year-old children and her
husband
Maria fled Guatemala with her husband, child, and her husband’s child to escape violence,
including the murder of their 21-year-old child. They entered the United States on September 9,
2017, at the San Ysidro port of entry. Maria reports that on September 11, she was separated from
her husband and children and subsequently transferred to the Otay Mesa Detention Center. For at
least ten days, she notes that DHS officers failed to provide her with any information regarding
the whereabouts of her children. At that point, she was told that her children had been separated
from her husband and that they were sent to a shelter in New York while her husband was also
detained at the Otay Mesa Detention Center.
Maria received a phone number to call her children, which she reports does not give her the
opportunity to leave a message if no one answers. She writes that: “When I do talk to my kids,
they tell me they don’t want to be there, they miss me, and they want to be with me.”

11

 Maria and her husband agreed to have their children released to an uncle; however the uncle was
not able to receive the children. She is concerned over what will happen with them, and they
continue to be in ORR custody in New York.
4. Case of Valentina, detained with one-year-old child, after being separated from her
husband at the U.S.-Mexico border
Valentina fled El Salvador with her husband and their one-year-old son and entered the U.S. on or
around November 14, 2017. Following several days in a processing unit on the border near San
Luis, Arizona, Valentina’s husband was transferred to an adult immigrant detention center in
Arizona, and Valentina and their child were transferred to a family detention center in Dilley,
Texas.
Valentina reports that she attempted to speak with her husband on the phone on numerous
occasions after they were separated. According to Valentina, the adult detention center in which
her husband was detained required proof of her marriage to her husband in order to coordinate a
phone call. She describes the emotional impact of the separation from her husband:
Hilario and I are legally married, but I do not have our marriage certificate easily
accessible. I only traveled with my passport, which has my married name of “[last
name].” [My pro bono attorney at] CARA requested if that was sufficient for the phone
call, but it has not yet been accepted. My mom has been trying to send me my marriage
certificate, but whenever she tries to fax or email it does not go through.
I received my positive credible fear determination today. Hilario and I fled El Salvador
for exactly the same reason, so I believe that if I have a positive credible fear
determination he should also have one. I am terrified of what will happen if he is
deported. I fear he will be killed and I will have to raise [Juan] alone. I am worried about
the developmental effects the psychologist talked about. I feel helpless because I am
unable to talk to my husband and help him.
Valentina’s pro bono attorney contacted USCIS and requested that her case be linked to that of her
husband’s. Valentina was given a phone call to her husband 13 days after her attorney requested
it. Her case was eventually linked to that of her husband. Valentina and her minor son were
released from custody on or around December 5, 2017 and allowed to pursue their immigration
case in a non-detained setting. However, her husband remains detained at the time of submission
of this complaint.
5. Case of Camila, Mexico, detained with 17-year-old daughter, separated from her
husband and 16-year-old child at the U.S.-Mexico border
Camila fled Mexico with her husband and their two teenaged children, Rebeca (17 years old) and
Xavier (16 years old). Xavier is a U.S. citizen. The family entered the United States on or around
November 7, 2017, at the Hidalgo Port of Entry. Xavier was separated from his parents and older

12

 sister shortly after they entered the United States, and transferred to the custody of Camila’s sisterin-law, who lives in Texas. Camila and Rebeca were transferred to the South Texas Family
Residential Center in Dilley, Texas, and her husband was transferred to the Port Isabel Detention
Facility. Camila describes the emotional trauma associated with being separated from her husband
and son:
It has been very traumatic for our family to be separated in this way. It is difficult for my
daughter and I to discuss it without crying. It has been very difficult for my daughter to be
separated from her father and brother. I have never been separated from my son and I worry
about him every day. We fled Mexico as a family and I believe we should have been kept
together as a family, especially because my children are still underage.
At the time of submission of this complaint, Camila and her daughter have been reunited with her
son and permitted to pursue their immigration case in a non-detained setting, but her husband
remains detained.
6. Case of Javier, El Salvador, separated from 12-year old son Rodrigo near San Ysidro
Port of Entry
Javier and Rodrigo presented themselves at the San Ysidro port of entry on November 12, 2017,
after having first tried to request asylum at the Otay pedestrian port of entry but being indicated
they had to find the San Ysidro port to be process. Upon requesting asylum, Javier and Rodrigo
were handcuffed and taken to a holding room (at some point during this time, the handcuffs were
removed). Both were eventually transferred to another holding cell with other fathers and children.
The cell contained a toilet and sink, meaning that any use of the toilet occurred with the other men
and children around. Javier reports that he and the others spent some days being held in the cell or
transported to another federal building during the day and being transported to a hotel in the
evenings.
On November 16, 2017, the men were taken to a cell in the other building and held again with
other men and their children. Officers repeatedly pressured the men to give up their children;
eventually, when only four men and their children were left, someone who introduced himself as
the “boss” explained again that the men would be separated from their children. As Javier was
taken out of the cell to identify his and his child’s belongings, officers took his and the children of
the other fathers. Javier reports that he never signed anything relinquishing custody of his child.
He reports that the officer also took his belongings. Javier reports that immigration officers gave
him a phone number with which he could try to locate his son and speak to him; however, Javier
states that he was unable to locate his son despite repeated attempts to do so. According to
advocates working on his case, Rodrigo remains in ORR custody.
7. Case of Angelo, El Salvador, separated from his one-year-old son Tobias near San

Ysidro Port of Entry

13

 Angelo and his one-year-old son requested asylum from U.S. border authorities on November 12,
2017. They were held in custody at San Ysidro in a room they described as very cold. While at
San Ysidro, an immigration officer (who Angelo reports was wearing a green uniform, though all
other officers were wearing blue) took an inventory of Angelo’s belongings, and kept one-yearold Tobias’s birth certificate while returning the rest of the items. When Angelo asked why she
kept it, he reports that she told him that it was important and needed to remain separate. Angelo
and Tobias were, like others, transferred back and forth between a federal immigration building in
San Diego during the day and a hotel at night. While en route to the building on November 16,
2017, Angelo reports that he asked to change Tobias’s diaper, but officials refused the request.
Angelo reports that while at the building on November 16, immigration officials repeatedly
approached Angelo and other fathers to pressure them into giving up their children. On one
occasion, Angelo reports that an officer indicated that “letting go of their kids was what was good
for them, because otherwise it would affect their whole process.” According to Angelo, the officer
also indicated he would “take action” if the fathers did not cooperate, and that “they should not
make their children witness violence.” Angelo reports that eventually an official arrived who
indicated that he was the director, and that he said that he had orders from authorities above him
to separate the fathers from their children.
Angelo and the three other dads insisted that they stay with their children, but eventually an officer
took Tobias away. Angelo reports that the officers did not take Tobias’s belongings, and that that
evening he and the other fathers were transferred to the Otay Mesa Detention Center. Angelo
eventually received a phone number that he was told to use to locate Tobias, but when he called it
he was told that he could not receive any information about Tobias “for security reasons.”
According to advocates working on his case, Tobias remains in ORR custody at the time of
submission of this complaint.
8. Case of Alejandro, El Salvador, separated from his five-year-old daughter Aria near

San Ysidro Port of Entry
Alejandro and his five-year-old daughter, Aria, turned themselves in to seek asylum at the San
Ysidro port of entry on Friday, November 10, 2017, fleeing death threats in El Salvador. Alejandro
showed authorities his and his daughter’s passports, which indicate that he is her father. He was
not asked for any additional documents. Alejandro reports that he and his daughter were there for
approximately five days, that it was cold, and that his daughter “would cry all the time because
she was afraid that the men guarding us with guns were there to kill us. She knew that we had left
El Salvador because someone wanted to kill us so she was very afraid.”
Alejandro reports that he and other fathers and their children were transported subsequently to a
hotel. The next day they were taken to a building where they were detained in two different holding
cells until they returned to the hotel in the evening. The following morning, they returned to the

14

 office. They were eventually told to separate their belongings from their children’s and that they
would be separated from them. Although they resisted, eventually an individual who Alejandro
reports was a senior official with ICE (a “jefe”) appeared who told them that the order to separate
had come from higher levels and that they would have to be separated from their children.
Alejandro interpreted the official’s words as a threat that their cases would be negatively impacted.
Alejandro reports that the children became extremely upset. He said that Aria said to him “ ‘I don’t
want to be separated, I’m going to hug you so hard that no one will be able to separate us […]
Who will protect me if I’m afraid that someone will kill me?’”
After they were separated, Alejandro reports that he and the others received a phone number for
ORR to call his daughter, but that he could not do so from detention. Alejandro writes:
I am worried about [Aria’s] mental health. I tried calling but I have no funds. She has a
congenital condition that causes her to lose control of her bladder.
I do not understand why I was separated from my daughter. The officers never asked me
for any other documents proving I was her father. It did not seem that there was ever any
question that Aria is my daughter. I have never been arrested in any country. I had an in
absentia removal order from many years ago, but I explained that to the officers and they
never mentioned it as a reason for taking my child from me. It has been very difficult not
knowing where she is.
According to advocates working on his case, Aria remains in ORR custody at the time of
submission of this complaint.
9. Case of Federico, Honduras, separated from his three-year-old son Sami at the U.S.-

Mexico Border
Federico and Sami crossed the U.S.-Mexico border on Monday, November 13, 2017, to seek
humanitarian protection, after fleeing Honduras. Federico and Sami were apprehended by Border
Patrol and transferred to a facility he believes was in Chula Vista. Federico reports that he and his
son were badly treated while being held; Sami had to repeatedly use the bathroom and eventually
the Border Patrol officer interacting with them got upset and screamed at them to shut up. Sami
ultimately wet his pants. When Federico asked to call his sponsor, he reports he was told that he
was not allowed to do so and that “it would not make any difference.” On Tuesday, November 14,
Federico and Sami were taken to a building he believes was in San Diego, and that night stayed in
a hotel. He and his son were taken back to the building the next day and held in a room with other
fathers and children until they returned to the hotel that night. On November 16, he reports they
were again taken to the same building and that on this day they were told they would have to let
go of their children so the children could go to a shelter.

15

 Federico reports that they repeatedly resisted, until eventually an official arrived who announced
that he was in charge. Federico reports that he and the other fathers still tried to refuse letting go
of their children, but that eventually the officials returned and said they would “have to use force
to take them away.” Federico writes that Sami “begged to not be taken away and put his arms
around me. I grasped him firmly in my arms. I told the officials that I would not give him up, and
that they would have to take him from me. Then, one of the officers came up to me and with both
hands forcefully pulled [Sami] out of my arms. They didn’t give us any paperwork to sign or
anything.”
Federico shared that he was only provided with a number for ORR, but told when he called that
they could not give him any information about his son. He writes “I feel like I have no will to do
anything without knowing where my son is or whether he is safe. The only thing I ask for right
now is that [Sami] be by my side.” Advocates working on the case believe Sami remains in an
ORR custody program.
10. “Andrea,” Honduras, older woman separated from husband, children, daughter-inlaw, and grandchild, separated at the U.S.-Mexico border30
Andrea is a Garifuna woman in her 60s who presented at the Nogales port of entry along the
Arizona-Mexico border in June 2017. She has no criminal history and no past immigration history.
Andrea and her family fled to the U.S. after violent gangs killed three of her sons because the
family was unable to pay the monthly extortion payments the gang demanded. Andrea presented
at the port of entry with her son, daughter, daughter-in-law, granddaughter and husband, who
suffered from cancer and was seriously ill. Her daughter, granddaughter, daughter-in-law, and
husband were paroled into the United States and allowed to go to Texas to complete their
immigration case in a non-detained setting, while Andrea and her son were both detained in Eloy,
Arizona. Despite Andrea’s husband being in critical condition as of late October 2017, ICE refused
to release Andrea to be with him. It was only after her husband’s death and intensive efforts by
Andrea’s attorneys that Andrea was paroled in order to attend her husband’s funeral.
11. “Fernando,” Honduras, disabled 18-year-old separated from mother and younger
siblings at the U.S.-Mexico border
Fernando is an 18-year-old with developmental disabilities, who fled gang violence in Honduras
with his mother and younger siblings following the murder of his half-brother. Fernando, his
mother, and his younger brothers presented at a port of entry on the U.S.-Mexico border in
September 2017. The family had never been in the United States before. Fernando was separated
30

Cases #10-#13 are anonymized in order to protect identity and were reported through the Florence Project. Although
we cannot share more specific information, they serve to illustrate a growing trend of family separation observed by
service providers.

16

 from his family members and detained alone in adult detention while his mother and siblings were
sent to a family detention center. It has been difficult for attorneys working with Fernando to reach
the rest of his family and for Fernando to provide information about his claim due to his
developmental disability. Because of the separation, it has also been difficult for attorneys to obtain
medical records documenting Fernando’s medical history and disability and which would provide
critical evidence in his asylum case. Fernando remained detained in Arizona as of December 6,
2017.
12. “Anna,” Guatemala, a two-year-old separated from her father at the U.S.-Mexico
border and rendered unaccompanied and “Antony,” Guatemala, two-year-old
separated from his father at the U.S.-Mexico border and rendered unaccompanied
Anna’s and Antony’s cases are completely unrelated, but both are examples of family separation
involving young toddlers. Anna is a two-year-old Guatemalan girl who was separated from her
father at the U.S.-Mexico border and transferred to ORR custody. Antony is a two-year-old
Guatemalan boy who was also separated from his father at the U.S.-Mexico border and
encountered by legal service providers in ORR custody. Both were too young to be able to
communicate with legal service providers about their arrest, separation, or reasons why their
families left Guatemala. In Antony’s case, legal service providers were able to determine that his
father had been prosecuted for illegal entry 8 U.S.C. §1325(a)(1) in the Western District of Texas.
This separation occurred despite records indicating that the father had no prior immigration history
or known criminal history.
13. “Carlos,” Guatemala, 16-year-old separated at U.S.-Mexico border from his mother,
who was prosecuted for illegal entry under 8 USC §1325(a)(1)
“Carlos” is a 16-year-old boy from Guatemala who was separated from his mother after they were
apprehended while crossing the U.S.-Mexico border. Together they were seeking asylum based on
gang violence and threats they received after reporting violence to the police. Carlos was
transferred to a shelter in Tucson as an unaccompanied child, while his mother was prosecuted and
convicted for illegal entry pursuant to 8 U.S.C. §1325(a)(1) in the Western District of Texas.
According to records, Carlos’s mother had no immigration or criminal history.
14. “Alex,” who was separated from his toddler child, “Jesse,” and then subsequently
deported31
Jesse, a toddler child and his parent Alex were detained in CBP custody, where a CBP agent
mocked Alex and the circumstance of being in CBP custody. The agent asked Alex if Alex
believed in God. Alex replied that he was Catholic. The agent then proceeded to say, "Where is
your God now?!...Is your God going to save you from being deported?!...Your God must not care
about you because he allowed you to be here!” Alex was subsequently deported to their country
31

Case information in #14-#15 are from the affidavit of Jessica Jones, LIRS. They have been anonymized and given
gender neutral names to protect the identity of the family. Full information will be filed separately.

17

 of origin without his child. The child was rendered unaccompanied and transferred to ORR and
placed in an LIRS foster care program. Upon placement, ORR did not have any information on
whether Alex had been criminally prosecuted, where he was, or whether the child had a fear of
return, because the Form 93 or I-213 were not provided to ORR. LIRS has frequently called Alex
to gather more case information and understand what Alex would like to happen; during these
calls, “Alex frequently would sob uncontrollably about the experience in CBP custody and
reported severe anxiety attacks. The foster parent caring for the toddler child has reported that the
child has also had severe anxiety attacks for a toddler and has been unable to sleep at night due to
the separation from the parent. This has required a high level of care by the foster parent and LIRS
foster care agency due to the medical attention needed for the child.”
15. “Chris,” an asylum-seeking parent separated from “T.J.” a U.S. citizen child and
“A.J” an undocumented child
TJ, a U.S. citizen child and AJ, an undocumented child arrived at the border with their parent Chris
who was coming to the United States for the first time and seeking asylum. Border Patrol separated
both children from Chris and LIRS believes Chris was transferred to ICE detention, but Chris may
have been previously detained in United States Marshals custody. LIRS does not have these details
because ORR was not provided the I-213 and other documentation. TJ was transferred to state
child protective services and because AJ was rendered “unaccompanied” when CBP transferred
AJ to ORR custody. ICE told Chris that if he decided to pursue an asylum case he would remain
detained for over six months. Further, Chris has children in two different forms of custody and
may face a child welfare proceeding for Chris’s U.S. citizen child. Forced to choose between
months of separation from his children or pursuing asylum, Chris ultimately decided not to pursue
an asylum claim and requested to be deported.
CONCLUSION
The above case examples demonstrate a disturbing, increasing trend of family separation at the
hands of U.S. immigration officials at the U.S.-Mexico border despite former Secretary Kelly’s
assurances to the contrary. The separation of family members, and specifically minor children
from their parents, absent extraordinary circumstances, raises significant legal concerns and
threatens the most fundamental interests of parents and their children.
We urge your office to investigate and clarify current DHS policy on family separation and ensure
that former Secretary Kelly’s commitment to avoid family separation is implemented. Many of
our organizations have also outlined recommendations designed to prevent family separation,
ensure a fair process for those seeking protection, and help families stay connected and in
communication if separation does occur. These include that:
1. DHS should consider family unity as a primary factor in all charging and detention
decisions. DHS agents should receive training and clear guidance on the identification,
documentation, processing, and placement decisions for families.

18

 2. DHS and its component agencies should document and trace all family relationships to
better understand when family separation occurs and inform strategies to address it.
3. DHS should consider the best interests of the child in all processing, custody, and removal
and repatriation decisions.
4. DHS should mandate the hiring of child welfare professionals at the border to supervise
the protection of children and families and, in rare instances in which it is warranted,
oversee instances of family separation.
5. DHS should coordinate among its components and with HHS and DOJ to identify family
separation and facilitate release and reunification. DHS and its components should work
with HHS and DOJ to ensure an inter-agency process to help separated family members be
released and/or reunited. This should include mechanisms to help detained family members
locate and connect with loved ones, such as an inter-agency hotline.32
6. DHS should prioritize humanitarian considerations and obligations to ensure access to
protection for asylum seekers when considering referral for criminal prosecution. Those
traveling together as a family and who are asylum seekers should not be referred for
prosecution until a determination has been made about an individual’s eligibility for relief.
7. For families who require additional support, DHS should explore alternatives to detention
such as the Family Case Management Program (FCMP) that ICE terminated in June 2017
and that—rather than unnecessarily relying on detention or ankle monitors—facilitated
access to case management to ensure compliance with immigration requirement.
8. The Office for Civil Rights and Civil Liberties and the Office of the Inspector General
should continue to investigate the unscrupulous prosecution of asylum seekers for entry
and reentry following a former attempt to avail themselves of humanitarian protection in
the United States.
Thank you in advance for your time and consideration. If you have any questions or require
additional information, please contact Katie Shepherd of the American Immigration Council at
kshepherd@immcouncil.org or (202) 507-7511, or Katharina Obser of the Women’s Refugee
Commission at katharinao@wrcommission.org or (202) 750-8597.
Al Otro Lado
American Immigration Council (Council)
American Immigration Lawyers Association (AILA)
32

The undersigned organizations recommend the implementation of a coordinated, national phone system that will
permit detained (and non-detained) individuals to locate and contact their family members. Individuals in ICE, CBP,
and DOJ custody—who should already have access to telephones with which they may call their attorneys or nondetained individuals—should be able to call a free number and speak with an individual who can assist in
coordinating a phone call in a timely manner. The agency has already had some success with the ICE ERO
Detention Reporting and Information Line (DRIL), which may serve as a model, but is specific to ICE custody,
rather than HHS and DOJ. The coordination of phone calls between family members could address several concerns
raised in this complaint.

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 Florence Immigrant and Refugee Rights Project (FIRRP)
Kids in Need of Defense (KIND)
Lutheran Immigration and Refugee Service (LIRS)
Refugee and Immigrant Center for Education and Legal Services (RAICES)
Women’s Refugee Commission (WRC)

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