Comment Submitted by F. Rios, University of Laverne

Special Immigrant Juvenile Petitions address the needs of those most vulnerable in our society children who have been abused, neglected and abandoned. In doing research on the issue it has been clear that congressional intent was that this would be a form of relief for these children and not a limitation or a means for deportation. While researching this proposed rule it has been clear that more minors have suffered deportation and detainment due to improper implementation of the legislation then have found relief. It is important to clarify the process so that more petitions can be granted and the relief that was established for this vulnerable population of our society and that this legislation can be implemented under its original intent. Working with vulnerable populations in my career it is clear that many times there is no other option for these individuals. While there are many other factors that come into play in cases such as these, recovery from abuse can be hindered by concern that once again that the future is uncertain and detainment for removal is another form of abuse that we are unintentionally inflicting on these victims. We need to strive to clarify processes and expedite these proceedings to place these juveniles on a road to recovery otherwise we are only further ensuring more physiological damage on an already vulnerable population. Granting these petitions in a timelier manner by clarifying the processes and creating timelines will assist in ensuring that these juveniles have the opportunity that congress originally intended them to have is a step in the right direction. It is clear that this proposed rule is attempting to do that by clarifying the eligibility requirements, consent requirements, application process, adjudication and post-adjudication, and adjustment status.