NCLC (on behalf of its low-income clients), Fines and Fees Justice Center, FICPFM, Just Future Project, Civil Rights Corps, JustLeadershipUSA, Southern Poverty Law Center, Washington Lawyers’ Committee for Civil Rights and Urban Affairs, and Worth Rises ask for the public record to reflect that the undersigned organizations believe DOJ, BOP, and the public record lack sufficient data to understand the full impact of the proposed rule amendment and that to move forward without such data would be arbitrary and capricious. Each of the undersigned organizations opposes implementation of the amended rule on numerous grounds, including but not limited to, the harm it will do to incarcerated people and their loved ones, the fact that DOJ has other means at its disposal to address perceived nonpayment of financial obligations, that it contradicts President Biden’s avowed policies of racial equity in agency operations and the administration’s support of successful reentry programming, and our belief that DOJ and BOP lack the legal authority to make the proposed changes.
The undersigned organizations request that DOJ and BOP refrain from moving forward with this proposed rule unless or until the data from that FOIA request is produced, disseminated, and analyzed and the public is once again provided an opportunity to weigh in with a full understanding of the facts.