1/ I just read through the new proposed rules for #asylum-based employment authorization while waiting in #immigrationcourt with a 16-year-old asylum seeker, and I'm just so tired and angry that this seems like a good time to tell you how bad it is.

It's bad.

(1/5000000000)

2/ This opening sentence says everything.

In Trumpworld, the only possible reason anyone would file an application for #asylum is to get a work permit, and most of them are probably criminals.

3/ Under current regulation, #asylum applicants can't file for a work permit until their cases have been pending 180 days. (Under current processing times, they receive it about 30 days later.) This rule would double that to a full year.

4/ How, you might reasonably ask, are destitute asylum seekers (who DO NOT qualify for any government benefits) supposed to support themselves w/out work permits for a year? By subjecting themselves to exploitation and/or working w/fake papers. DHS is well aware of these options.

5/ Here's the worst one. Remember that anyone present in the US (no matter how they got here) is eligible to apply for #asylum. Denying those who came w/o permission work permits is almost certainly a violation of out international treaty obligations.

But it gets even worse!

6/ A very common scenario: someone who has been in the US on a student visa for more than 1 yr & is now unexpectedly subject to persecution at home for something like sexual identity or a religious conversion.

This rule would deny them work permits through most of the process.

7/ This is just more ways to play games with the #asylum work permit "clock" system. Amending your application? Trying to request more time to collect and file vital evidence from abroad? Miss an interview? You are trying to "delay" your case, and your 365-day clock will stop.

8/ Here's one a lot of people might miss: more fees for #asylum seekers.

You may have heard that Trump wants to charge $50 for an application? This would tack on another $85 for a biometrics check. (None of this has ever cost anything for asylum seekers, nor should it.)

9/ This one would severely restrict eligibility for employment authorization for people granted special lawful entry to the US for "humanitarian" or "public interests" reasons. Because why would we want to make their lives any easier

10/ The new rule would also allow DHS to deny work permits not only to people convicted of many crimes (major and minor) but those *arrested* for them w/pending charges. Because the best way to keep people w/pending charges out of more trouble is to... deny them the right to work

11/ Plenty more, but the overall effect is to continue to punish people simply for having the temerity to seek our protection.

Will a federal court stop this in 61 days? Almost certainly yes. Do I have to tell my clients to expect it will become law until then? Also yes.