On Jan. 21, 2020, CLINIC submitted a public comment opposing the proposed rule to create additional criminal bars to asylum. CLINIC opposes this rule because it expands the categorical bars to asylum to include minor offenses and alleged criminal conduct, without consideration of proportionality. In our comment, CLINIC describes how the proposed rule is contrary to our obligations under the United Nations Refugee Convention, and how its implementation will result in the separation of families and the wrongful return of asylum seekers to harm.