Administrative and Public Comments
The Lawyers’ Committee for Civil Rights Under Law regularly provides legal and policy analysis through rulemaking and public comment procedures to administrative agencies and other government entities. Our public comments and submissions highlight how policy proposals that touch on issues across our project areas would impact Black communities and other communities of color.
These submissions reflect our commitment to ensuring that laws and regulations preserve civil rights, protect against discrimination, and advance equal opportunity.
Below you can explore our recent public comments and policy submissions.
Review our Administrative and Public Comments: 2025 | 2026
April 2026
Comment Opposing American Bar Association Proposal to Repeal Diversity and Inclusion Standard 206
April 13, 2026 – The Lawyers’ Committee for Civil Rights Under Law, in collaboration with the Howard University School of Law Civil Rights Clinic, submitted comments opposing the American Bar Association’s proposed repeal of Standard 206, which supports diversity and inclusion in legal education. The comment argues that repeal is legally unnecessary, would undermine access to the legal profession, and would further chill diversity-related efforts at law schools. It also emphasizes that diversity and inclusion strengthen the legal profession, expand access to opportunity, and are essential to building a justice system that reflects and serves an increasingly diverse society. The comment urges the ABA to preserve Standard 206 as an important safeguard for equal opportunity, inclusion, and integrity of the legal profession.
March 2026
Comment Opposing General Services Administration Proposal Affecting Applicants for Federal Grants
March 30, 2026 – The Lawyers’ Committee for Civil Rights Under Law submitted comments opposing the General Services Administration’s (GSA) proposed changes to System for Award Management (SAM) registration requirements. The proposal would impose new certification obligations—including a provision related to diversity, equity, and inclusion (DEI)—on entities seeking federal funding. The Lawyers’ Committee argues that the proposed anti-DEI provision exceeds GSA’s authority, violates the Paperwork Reduction Act, and would impose vague and legally unsupported new requirements.The comment also highlights the significant burdens and chilling effects the proposal would impose on nonprofit organizations and communities that seek and rely on federal funding, ultimately urging GSA to withdraw the proposed rule.