Maryland Attorney General Anthony G. Brown joined a multistate coalition opposing proposed revisions to the U.S. Citizenship and Immigration Services AR-11 Change of Address form.
The U.S. Department of Homeland Security proposed the revisions in May. The current form requires a physical address and basic biographical information, including a person’s name, date of birth and registration number.
The proposed form would also require information about employment, education and the use of public benefits.
DHS cited immigration law enforcement, public charge deportation rules and enforcement of the Personal Responsibility and Work Opportunity Reconciliation Act as reasons for collecting the additional information.
Brown and the coalition submitted a comment letter requesting that DHS withdraw the proposal. The coalition argues that the revisions are unlawful, overly broad and burdensome.
The letter states that DHS did not follow required notice-and-comment procedures under the Administrative Procedure Act and does not have authority to require the additional information.
The coalition also argues that the requested information is broader than necessary for public charge determinations and could discourage eligible noncitizens and their families from participating in public benefit programs.
According to the information provided, Maryland has approximately 70,000 people awaiting asylum decisions, 12,500 Deferred Action for Childhood Arrivals recipients, nearly 50,000 refugees and 27,000 people with Temporary Protected Status.
Nearly 500,000 U.S. citizen children in Maryland live with at least one foreign-born parent, according to the American Immigration Council.
The coalition said reduced participation in benefit programs could increase demand for state and locally funded services, safety-net providers and emergency medical care.
Brown was joined by the attorneys general of California, Colorado, Connecticut, Delaware, Hawaii, Illinois, Maine, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, New Mexico, New York, Oregon, Rhode Island, Vermont, Virginia, Washington and the District of Columbia.
