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Md. A.G. Brown Opposes Trump's Latest Effort to Funnel Americans' Personal, Sensitive Information Into Mass Surveillance Machine
BALTIMORE, Maryland, Dec. 3 -- Maryland Attorney General Anthony G. Brown issued the following news release:* * *
Attorney General Brown Opposes Trump's Latest Effort to Funnel Americans' Personal, Sensitive Information into Mass Surveillance Machine
Attorney General Anthony G. Brown joined a coalition of 18 attorneys general in opposing the Trump administration's expansion of the Systematic Alien Verification for Entitlements (SAVE) program to include the information of U.S. born citizens who have never interacted with our immigration system and who never consented to the use of their personal ... Show Full Article BALTIMORE, Maryland, Dec. 3 -- Maryland Attorney General Anthony G. Brown issued the following news release: * * * Attorney General Brown Opposes Trump's Latest Effort to Funnel Americans' Personal, Sensitive Information into Mass Surveillance Machine Attorney General Anthony G. Brown joined a coalition of 18 attorneys general in opposing the Trump administration's expansion of the Systematic Alien Verification for Entitlements (SAVE) program to include the information of U.S. born citizens who have never interacted with our immigration system and who never consented to the use of their personaldata in this manner. In the letter, Attorney General Brown and the coalition argue that, taken alongside Department of Homeland Security's (DHS) well-documented efforts to acquire massive troves of personal data from a variety of sources, the expansion of the SAVE program is an ill-advised, massive invasion of privacy that exposes millions of individuals to possible data breaches, pools vast swaths of sensitive data, and furthers the administration's efforts to create a national surveillance database.
SAVE is an online service administered by the U.S. Citizenship and Immigration Services for state and local government agencies to verify immigration status of applicants seeking benefits or licenses, such as driver's licenses, eligibility to serve in the armed forces, Supplemental Nutrition Assistance Program (SNAP), or Medicaid. On October 31, 2025, DHS published a "Systems of Record Notice" (SORN) expanding SAVE to allow access to information for all natural-born U.S. citizens and will allow searches based on 1) Social Security numbers; 2) U.S. passport numbers; and 3) driver's license numbers. DHS also added two new "routine uses" that allow for the disclosure of data to federal organizations and agencies to audit federal programs at the state and local level as well as allowing searches for multiple cases at once. The SORN reflects a belated effort to legitimize the federal government's efforts to modify the SAVE program, as evidence shows the SAVE modifications began months ago.
In the letter (https://oag.maryland.gov/News/Documents/pdfs/SAVE%20SORN%20multistate%20comment%20letter%20-%20final%20%2812.1.25%29.pdf), Attorney General Brown and the coalition urge DHS to rescind these changes, arguing that adding multiple new data sources will increase the likelihood of inaccurate, stale, or conflicting information, particularly with regards to an individual's immigration or citizenship status. Inaccurate verifications will require states like Maryland to engage in burdensome fact gathering to re-verify inaccurate SAVE responses, an individualized and time-consuming process. These inaccurate verifications likely will also lead to delay or denial of benefits for constituents, wrongly flag individuals for investigation, or wrongly remove individuals from voter rolls.
Additionally, the coalition highlights that a system with access to information about all individuals in the United States, including their citizenship status, their Social Security numbers, their passport information, and their drivers' license information will be a highly attractive target for hackers and hostile foreign powers. Security concerns are even greater when federal agencies enlist the help of unknown third parties and provide them with access to Americans' sensitive personal information.
Finally, the coalition explains how the expansion of SAVE violates the Privacy Act of 1974 by adding the records of natural-born U.S. citizens without providing them with an opportunity to individually participate in or consent to how USCIS uses their information.
In submitting the comments Attorney General Brown is joined by the attorneys general of California, New York, Colorado, Connecticut, the District of Columbia, Delaware, Hawaii, Illinois, Maine, Massachusetts, Michigan, Minnesota, Nevada, New Mexico, Oregon, Rhode Island, and Vermont.
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Via Federal eRulemaking Portal
TO: Roman Jankowski, Chief Privacy Officer, Privacy Office, Department of Homeland Security, Washington, DC 20528-0655
December 1, 2025
Re: Objections to DHS's proposal to modify and reissue the "DHS/USCIS-004 Systematic Alien Verification for Entitlements Program System of Records" [Docket number USCIS-2025-0337]
Dear Mr. Jankowski:
We the Attorneys General for the undersigned States write to object to the updates and modifications to the Systematic Alien Verification for Entitlements (SAVE) Program as set forth in the System of Record Notice (SORN) Update, 90 Fed. Reg. 48948 (October 31, 2025).
The Administration's expansion of SAVE uses the information of U.S.-born citizens who have never interacted with our immigration system and who never consented to the use of their personal data in SAVE. Alongside Department of Homeland Security's (DHS's) welldocumented efforts to acquire massive troves of personal data from a variety of sources, this project is ill-advised and a massive privacy overreach. It exposes millions of individuals to possible data breaches, pools vast swaths of sensitive and otherwise-segregated data, and furthers the Administration's efforts to create a national surveillance database for use in immigration enforcement, voter list maintenance, and other purposes. Moreover, because there is evidence that DHS implemented the SAVE program modifications months ago, this SORN clearly reflects a belated effort to legitimize the federal government's unlawful modifications to those systems.
To be clear: the undersigned States already spend significant time and resources to ensure that they are only providing public benefits to individuals who qualify, including by having the required immigration status. And our States ensure that citizenship requirements are met when registering voters. We remain committed to these efforts, which in some instances already involve the use of SAVE, as well as substantial record gathering and review at the state and local level. However, we object to the Administration's expanded use of SAVE (and other data collection efforts) to audit these state programs in a manner that is contrary to law, overly burdensome, does not protect public resources, and risks potential harm to our residents.
DHS's U.S. Citizenship and Immigration Services (DHS-USCIS) division should therefore withdraw the proposed updates to SAVE as set forth in its SORN, as the changes exceed the federal government's statutory authority under federal law including the Privacy Act of 1974; impose significant burdens on States and our residents; risk exposing residents to frivolous immigration enforcement and unlawful purges from state voter rolls; and create unprecedented risks to the security, integrity, and privacy of Americans' most sensitive information. The federal government's "overhaul" of SAVE puts our States' data at risk, imposes significant burdens, damages our efforts to build trust with our residents, and harms the health and welfare of our communities.
I. The SORN's change to include personal data on U.S.-born citizens within SAVE should be withdrawn because it creates a system that fails to meet the requirements of the Privacy Act of 1974.
When the Privacy Act was enacted by Congress in 1974, its principal sponsor, Judiciary Chairman Senator Sam Ervin declared, "[i]f we have learned anything in this last year of Watergate, it is that there must be limits upon what the Government can know about each of its citizens."/1 Since then, the federal government's use of Americans' private personal data has been restricted by the Privacy Act./2 Core to the Privacy Act is that no agency may disclose the protected personal information of American citizens or lawful permanent residents without their consent, unless it is for a specific purpose described by the Act./3 Among those purposes are "routine uses" of the data, but those uses must be announced by a federal agency in advance, and the use must be "compatible with the purpose for which [the record] was collected."/4 The Privacy Act also dictates that federal agencies should maintain in their records "only such information about an individual as is relevant and necessary" to accomplish a lawful agency purpose./5 Disclosing or using an individual's data in violation of the Privacy Act exposes federal agencies and their employees to civil and criminal liability./6
DHS-USCIS's expansion of SAVE, as reflected in its October 31, 2025 SORN, violates these critical legal restrictions. In particular, the SORN states that "DHS/USCIS is adding individuals that are U.S. citizens by birth to the categories of individuals covered by the...
1 U.S. Dep't of Justice, Introduction to Overview of the Privacy Act (2020 Edition), available at https://www.justice.gov/opcl/overview-privacy-act-1974-2020-edition/introduction (quoting S. Comm. on Gov't. Operations & H.R. Comm. on Gov't. Operations, 94th Cong., Legislative History of the Privacy Act of 1974 S. 3418 (Public Law 93-579)).
2 Subsequent statutes have also updated the Privacy Act for the modern data age. For example, the Computer Matching and Privacy Protection Act of 1988, codified at 5 U.S.C. Sec. 552a(o), amended the Privacy Act to require procedural protections when federal agencies engage in computer-matching activities, including by providing matching subjects with opportunities to receive notice and to refute adverse information before having a benefit denied or terminated. See id.
3 See 5 U.S.C. Sec. 552a(b).
4 See 5 U.S.C. Sec. 552a(b)(3); id. Sec. (a)(7); id. Sec. (e)(4)(D).
5 See 5 U.S.C. Sec. 552a(e)(1).
6 See 5 U.S.C. Sec.Sec. 552a(g), (i).
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...system."/7 But SAVE has not been authorized to provide information on U.S.-born citizens./8 Furthermore, the Privacy Act of 1974 requires a request or consent from the individual to whom the record pertains to disclose federal records systems data, unless disclosure falls under enumerated exceptions that are not applicable here, or unless the individual has been notified in advance that such disclosure would be considered a "routine use" of their data./9 Here, there was no such request or consent from the affected individuals at the time their information was given to the participating agencies that must now share information with DHS-USCIS. Nor was there the required notification of routine use. In fact, no U.S.-born citizens could have known until now that their personal data would be shared with DHS-USCIS for SAVE query purposes.
DHS-USCIS is well aware of this problem. Its Privacy Impact Assessment acknowledges the "risk that the new category [of] individuals covered by this assessment/notice, specifically, United States born citizens do not have the opportunity to individually participate or consent in how the U.S. Citizenship and Immigration Services uses their information."/10 But rather than address this legal error, and potential willful Privacy Act violation, the federal government throws up its hands and simply states that DHS-USCIS "cannot mitigate this risk."/11 Instead, the federal government shifts the burden back on state, local and other government agencies, stating that DHS-USCIS "assumes that each user agency factors in the principles of notice, individual participation, and consent prior to providing information to the U.S. Citizenship and Immigration Services."/12 However, not only is this purported solution burdensome to States, it is also unavailing given that States were neither notified nor could have foreseen that DHS-USCIS would incorporate information of U.S.-born citizens into SAVE in time to provide them notice.
Further, DHS-USCIS does not seem to be concerned with the Privacy Act ramifications of accumulating and using data from millions of U.S.-born citizens. As an example, DHS-USCIS reports it has "updated its SAVE Participation poster" so that user agencies can display a notice that purportedly informs "the public that the information they provide may be used by SAVE, as required by the SAVE Memorandum of Agreement, SAVE Program Guide, and the Privacy Act of 1974."/13 But a catch-all poster does not fulfill DHS-USCIS's legal obligations or the...
7 DHS-USCIS [Docket No. USCIS-2025-0337], Privacy Act of 1974, System of Records Notice, 90 Fed. Reg. 48948, 48949 (Oct. 31, 2025) (hereafter SORN).
8 See 42 U.S.C. Sec. 1320b-7(d); see also DHS-USCIS, Guide to Understanding SAVE Verification Responses (April 2022) available at https://www.uscis.gov/sites/default/files/document/guides/SAVEGuide%20to%20Understanding%20SAVE%20Verification%20Responses.pdf ("Note: SAVE does not verify the citizenship of native-born United States citizens. SAVE cannot verify United States citizenship using a United States passport or birth records."),
9 See Privacy Act, 5 U.S.C. Sec. 552a.
10 Dep't of Homeland Sec., Privacy Impact Assessment for the Systematic Alien Verification Entitlements Program, DHS Ref. No. DHS/USCIS/PIA-006(d) at 21 (Oct. 31, 2025) (hereafter SAVE PIA).
11 Id. (emphasis in original).
12 Id.
13 DHS-USCIS, Updated SAVE Participation Poster (last updated Aug. 26, 2025), available at https://www.uscis.gov/save/current-user-agencies/news-alerts/updated-save-participation-poster.
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...participating agencies' legal obligations to the individuals whose data is being shared. DHSUSCIS and the participating agencies must do more to comply with the Privacy Act.
II. The SORN's new Routine Uses should be withdrawn because they would allow unknown third-party "entities" to access Americans' most sensitive data.
DHS should also withdraw its new Routine Use L and Routine Use M. According to the SORN, Routine Use L "support[s] sharing with Social Security Administration and other federal organizations," while Routine Use M "support[s] sharing with federal agencies (e.g., the Department of Health and Human Services) to support auditing of federal programs administered by state, local, and tribal governments (e.g., Medicaid)."/14 But the SORN's actual new routine use language is far broader than that: both Routine Use L and M permit data sharing with any entity so long as it is a party to a "DHS-approved agreement."/15 This deliberately vague language would effectively allow DHS to share data--without any notification to the affected individuals--with any party it chooses for the purported purposes of immigration or voter fraud enforcement. But this unfettered use of Americans' private personal data is anathema to the Privacy Act and other data privacy and security statutes enacted by Congress.
This is particularly concerning where federal agencies enlist the help of third parties, making it possible that unidentified actors will have access to sensitive personal information without notice to or consent from the affected individual. This is not a speculative concern; as recently as April 2025, the Department of Government Efficiency enlisted a third-party technology company and gave it access to a massive repository of data./16 DHS-USCIS has also signaled its interest in privatizing its law enforcement functions, for example by recently issuing an RFI seeking private vendors to assist with tracking down individuals and serving process../17
Routine Uses L and M also demonstrate a substantial and unwarranted expansion of the federal government's use of SAVE to audit public benefit programs and voting rolls. As explained further below, the undersigned States are fully committed to ensuring that public benefits are provided only to eligible individuals, including by using SAVE and other methods to determine immigration status when required. And our States are committed to protecting the rights of our citizens to vote. But Routine Uses L and M signal the federal government's move toward auditing state programs in a manner that is outside the scope of the federal government's...
14 SORN, supra 6, at 48949.
15 Id.
16 See, e.g., Priscilla Alvarez, et al., DOGE is Building a Master Database for Immigration Enforcement, Sources Say, CNN (Apr. 25, 2025), available at https://www.cnn.com/2025/04/25/politics/doge-building-master-databaseimmigration; Makena Kelly & Vittoria Elliott, DOGE Is Building a Master Database to Surveil and Track Immigrants (Apr. 18, 2025), available at https://www.wired.com/story/doge-collecting-immigrant-data-surveiltrack/.
17 See Request for Information Notice, 26-SS-DCR-01 (Oct. 31, 2025), available at https://sam.gov/workspace/contract/opp/ba672b1263504509be2fa823ee9b6725/view (DHS contract opportunity was published on October 31, 2025.); See also Alex Woodward, ICE wants to spend $180M on bounty hunters to track down thousands of immigrants, The Independent (Nov. 13, 2025), available at https://www.independent.co.uk/news/world/americas/us-politics/ice-skip-tracers-bounty-hunters-contractsb2864688.html.
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...role, overly burdensome, does not protect public resources, and risks potential harm to our residents. See infra, Sec. IV.
DHS should withdraw the "routine uses" in this SORN and instead partner with the States to ensure that SAVE is accurate, effective, and protects all individuals' privacy and security.
III. The SORN's expansion of SAVE may worsen inaccuracies or errors within SAVE verifications.
DHS is adding more data sources without providing information on the execution of the integration and what safeguards it is using to ensure the system will produce accurate matches. Failure to engage in data matching will increase errors. Even without the SORN's amendments, SAVE is an imperfect system. Many applicants' immigration statuses cannot be verified during an initial SAVE query due to a variety of data-related errors, including "an issue electronically locating the records"; "conflicting data" within the databases used by SAVE; or "the nature of the applicant's status."/18 Analysts have emphasized the shortcomings in SAVE's data, including the lack of comprehensive or up-to-date information on all individuals' citizenship or immigration status./19
In recognition of SAVE's imperfections, and to protect individuals who are lawfully seeking public benefits, DHS-USCIS has required user agencies to request additional verification steps, starting with a manual search by SAVE of immigration databases (including "databases that were not automatically searched during the initial [verification] step")./20 When that does not work, a user agency moves on to "Third Step Verification," in which the "agency MUST submit photocopies (front and back) of the applicant's relevant immigration documents" to SAVE./21 Use of SAVE plus manual verification results in high accuracy in ensuring that only eligible residents obtain services.
These additional verification steps are time-consuming: DHS-USCIS states that the "additional verification" process should be complete "within 3-5 federal working days," but the Third Step Verification process can require "extensive research" and "may take 10-20 federal working days."/22 This becomes especially onerous when multiplied by the significant number of required additional verifications. Of 86.6 million initial SAVE queries logged by DHS-USCIS...
18 DHS-USCIS, Guide to Understanding SAVE Verification Responses 2, available at https://www.uscis.gov/sites/default/files/document/guides/SAVEGuide%20to%20Understanding%20SAVE%20Verification%20Responses.pdf(last visited Nov. 13, 2025) (hereafter "USCIS Verification Response Guide").
19 Jasleen Singh and Spencer Reynolds, Homeland Security's "SAVE" Program Exacerbates Risks to Voters (July 21, 2025), available at https://www.brennancenter.org/our-work/research-reports/homeland-securitys-save-programexacerbates-risks-voters.
20 USCIS Verification Response Guide at 1-2.
21 Id. at 2 (emphasis in original).
22 Id.
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...during fiscal years 2012-2016, over 14 million (or 16.3%) returned a response requiring additional verification./23
DHS now risks making SAVE less accurate by connecting SAVE to new data sources without properly grappling with the inevitable problems that arise when matching records between multiple, often incomplete, data systems. And it is unclear whether DHS has a plan to adjudicate collisions in records or place guardrails prior to irrevocably combining the data. The SORN announces that DHS-USCIS is "updating the categories of records in the system to include collecting both full and truncated (last four digits) Social Security number (other than those collected on Form G-845, Verification Request), U.S. passport number, driver's license number, and information from the Social Security Administration."11 This expansion will increase the likelihood that conflicting, mismatched, or unclear data will impede the ability of SAVE to accurately verify an individual's immigration status. Matching records is a complicated process that has its own branch of data science known as entity resolution. For example, past problems in data matching have included:
* In 2024, the Department of Education encountered numerous issues in attempting to match federal student aid data with IRS data. Approximately 15% of FAFSA applications were matched to incorrect income information, affecting the amount of financial support awarded to students./24
* A hospital has successfully shown that the Centers for Medicare & Medicaid Services' matching process failed to properly match Medicare patients with their Supplemental Security Income (SSI) benefits./25
Here, the SORN and its accompanying PIA offer nominal and insufficient explanations regarding what, if any, safeguards or manual checks will ensure that the system will produce accurate matches. Further, DHS has not assured States that DHS's errors in implementation of matching rules will not lead to errors in program administration.
Even DHS-USCIS has acknowledged that the use of new data sources that were not intended for this purpose may create new inaccuracies--and that it cannot fix the inaccuracies generated when searching by SSN. In the Privacy Impact Assessment accompanying the new SORN, DHS-USCIS acknowledges the "risk that the U.S. Citizenship and Immigration Services may share inaccurate information with registered agencies, which could in turn impact a registered user agency's eligibility determination for an individual."/26 Shockingly, DHS-USCIS...
23 U. S. Government Accountability Office, Immigration Status Verification Benefits: Actions Needed to Improve Effectiveness and Oversight, Table 1 (Published March 2017), available at https://www.gao.gov/assets/gao-17204.pdf. See also Institute for Responsive Government, An Updated Federal System to Verify Voter Citizenship (May, 23, 2025), available at https://responsivegov.org/research/uscis-save-system-overhaul/.
24 Maria Carrasco, FSA Releases Details on Three Additional Issues with FAFSA Applicant Records, NASFAA, available at https://www.nasfaa.org/newsitem/33264/FSA_Releases_Details_on_Three_Additional_Issues_With_FAFSA_Applicant_Records (last visited November 14, 2025).
25 Pomona Valley Hosp. Med. Ctr. v. Becerra, 82 F.4th 1252, 1259 (D.C. Cir. 2023)
26 SAVE PIA, supra 8, at 19.
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...also acknowledges that it cannot mitigate the risks caused by its new incorporation of SSNs into SAVE:
Generally, the SAVE Program has a 3-step process. The first step is a general query of the system. However, due to misspelling of names, transposed numbers, or incomplete information, the SAVE Program may produce inaccurate results. To mitigate this, the SAVE Program has a manual step process where a U.S. Citizenship and Immigration Services staff member will try to reconcile the request manually. The third step is for the U.S. Citizenship and Immigration Services to get additional documentation from the registered agency. However, this only partially mitigates the risk since the new request using Social Security numbers does not allow for a second and third step review. The U.S. Citizenship and Immigration Services does not have direct access to the Social Security Administration system to support these additional steps./27
In short: if the use of SSNs (or just the last four digits of SSNs) in bulk SAVE queries leads to inaccurate results, then DHS-USCIS cannot fix that problem. It will be up to the States or the affected individuals to fix these errors.
IV. The SORN's expansion of SAVE will impose significant burdens on States and harm eligible residents seeking public assistance or registering to vote.
Despite these accuracy risks, the Administration is moving forward with expanding the use of SAVE. For example, the Centers for Medicare and Medicaid Services (CMS) in August announced a new initiative where it would check State Medicaid rolls against SAVE./28 But States already have comprehensive systems in place to ensure that federal Medicaid dollars are only used to serve individuals with an eligible immigration status, and those systems already use SAVE for limited purposes where appropriate. Notably, CMS's expanded use of SAVE began months before the issuance of the new SORN, which purports to seek public comments on a new "Routine Use M" that would cover such audits, evidence that DHS has no intent to meaningfully review and consider these public comments in its decision-making process./29
As explained above and acknowledged in the new SORN, when SAVE is unable to verify an individual's immigration status it provides "instructions on actions the user agency may take, including requesting additional verification."/30 This process is time-consuming for individual cases. But despite States' long-standing work to verify individuals when registering them to vote or approving public benefit applications, in its SORN, DHS-USCIS announces its intent to use...
27 Id. at 19-20 (emphasis added).
28 CMS, CMS Launches Nationwide Push to Remove Ineligible Medicaid Enrollees, Uphold Citizenship Requirements (Aug. 19, 2025), available at https://www.cms.gov/newsroom/press-releases/cms-launchesnationwide-push-remove-ineligible-medicaid-enrollees-uphold-citizenship-requirements
29 SORN, supra 6, at 48949 (describing "routine use M" as "to support sharing with federal agencies (e.g., the Department of Health and Human Services) to support auditing of federal programs administered by state, local, and tribal governments (e.g., Medicaid)").
30 SORN, supra 6, at 48950.
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...SAVE to "audit benefits granted or voter registration records."/31 If used by the federal government to audit state programs--particularly when combined with the new SAVE functionality that permits bulk upload of thousands of cases at a time--States will be asked to painstakingly, and at times manually, assess the immigration statuses of thousands of individuals due to faulty or incomplete data.
This would generate intolerable costs for States and risks for their residents. It will be incredibly costly (if not impossible) for States to verify immigration status accurately for the significant number of individuals for whom SAVE will not provide an immediate and clear response in these new (and potentially unnecessary) audits. DHS-USCIS brags that its unprecedented expansion of SAVE has "resulted in more than 205 million status verifications queries as of October 2025 compared to 25 million status verification queries in all of calendar year 2024."/32 Assuming a 5-10% error or uncertainty rate based upon DHS-USCIS's own prior assessment,/33 that means SAVE might wrongly call into question the immigration status of 10 to 20 million individuals. The costs of addressing these errors will be overwhelming for States and the increased costs of the expansion are unfunded and will be borne by the States.
Further, these inaccuracies will harm States by creating the false impression that States are failing to engage in robust checks to ensure that only eligible individuals receive public services or are registered to vote. This is not true. Incidents of fraud by public benefit recipients are rare, and state and local governments have long partnered with federal agencies to protect against them./34 Incidents of fraudulent voter registrations are infinitesimally rare and similarly protected against by state voter registration processes./35 But if SAVE creates lists full of errors, it...
31 See SORN, supra 6, at 48949-51 (describing voter list maintenance, voter registration, and voter verification of U.S. citizens by birth as purpose of SAVE); cf. Privacy Act Notice of Modified System of Records, 85 Fed. Reg. 31798 (May 27, 2020)(failing to list voter list maintenance, voter registration, or voter verification as purpose of SAVE); see also Privacy Act Notice of Modified System of Records, 76 FR 58525 at 58527 (Sept. 21, 2011) (describing voter registration but not voter list maintenance or voter verification as lawful purpose of SAVE).
32 DHS-USCIS, SAVE Optimization: New Option to Create Cases with the Last Four Digits of an SSN, available at https://www.uscis.gov/save/current-user-agencies/news-alerts/save-optimization-new-option-to-create-cases-withthe-last-four-digits-of-an-ssn (last updated Nov. 3, 2025).
33 Undated computer matching agreements with state agencies posted to DHS's website state that information within the DHS-USCIS Verification Information System database used by SAVE to verify immigration status "is 9095% accurate in reflecting immigration status." See Computer Matching Agreement (CMA) between DHS-USCIS and California Department of Healthcare Services, at 11, available at https://www.dhs.gov/sites/default/files/publications/7-uscis ca-dhcs cma.pdf; CMA between DHS-USCIS and New York Department of Labor, at 11, available at https://www.dhs.gov/sites/default/files/publications/10-uscis nydol cma.pdf.
34 See, e.g., Congressional Research Service, Supplemental Nutrition Assistance Program: Errors and Fraud (Updated Apr. 7, 2025), available at https://www.congress.gov/crs-product/IF10860 (noting that in "FY2021, state agencies attempted to collect $54 million in overpayments resulting from recipient trafficking and recipient application fraud," out of over $100 billion in SNAP benefits delivered that fiscal year).
35 See, e.g., Fish v. Kobach, 309 F. Supp. 3d 1048 (D. Kan. 2018), aff'd sub nom. Fish v. Schwab, 957 F.3d 1105 (10th Cir. 2020) (describing how in action challenging documentary proof of citizenship law Secretary of State failed to demonstrate that substantial number of noncitizens successfully registered to vote under prior attestation regime as evidence illustrated no more than 39 noncitizens successfully registered to vote in Kansas between 1999 and 2013, representing .002% of registered voter population, and several of those registrations were result of errors on part of state employees or confusion on applicants' part); Kobach v. U.S. Election Assistance Comm'n, 772 F.3d 1183, 1197-98 (10th Cir. 2014) (upholding Election Assistance Commission decision to add Arizona and Kansasspecific documentary proof of citizenship instructions on National Mail Voter Registration Form because Kansas and Arizona had failed to meet their evidentiary burden of providing substantial evidence noncitizens registered to vote using National Form); Memorandum of Decision Concerning State Requests to Include Additional Proof-ofCitizenship Instructions on the National Mail Voter Registration Form, 79 Fed. Reg. 7439 (Jan. 7, 2014) (determining Kansas and Arizona failed to demonstrate that substantial number of noncitizens registered to vote in their states as they respectively provided evidence that only 21 out of 1,762,330 registered voters in Kansas, representing .001% of the registered voter population, and 196 of 2,706,223 registered voters in Arizona, representing .007% of the registered voter population, may have been unlawfully registered, which could have been attributed to human error); Justin Levitt, The Truth About Voter Fraud, Brennan Center for Justice at 19-20 (Nov. 9, 2007), available at https://www.brennancenter.org/media/179/download/Report_Truth-About-VoterFraud.pdf?inline=1(reviewing elections and finding incident rates of possible noncitizen voter fraud between 0.0002% and 0.017 % at most).
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...creates an incorrect perception that there are many non-citizens voting or ineligible individuals who are obtaining public benefits. Such misinformation creates the unacceptable risk that the public will lose faith in government and the integrity of our elections.This loss of faith will deter eligible voters from registering or voting and eligible recipients from seeking public benefits to which they are entitled.
In short, SAVE's inevitable inaccuracies, when used in the manner envisioned by this SORN, will likely delay or deny benefits for constituents, wrongly flag Americans for removal from state voter rolls and investigation, waste taxpayer resources, and undermine public trust. DHS has turned a blind eye to these problems. Federal and state governments have an obligation to ensure that individuals' rights are protected, and that government agencies do not take action to deny public benefits--much less the right to vote--based solely on an initial data query./36 The expansions and new routine uses of personal data envisioned by this SORN threaten to flip these presumptions on their head.
V. The SORN's expansion of SAVE creates risks to the privacy and security of Americans' data.
The SAVE modifications reflected in the new SORN also raise data privacy and security concerns.
As discussed above, SAVE user agencies may now bulk upload social security numbers, driver's licenses, and dates of birth through the SAVE program./37 Through this new functionality, SAVE users will have the capacity to upload whole voter files, potentially including millions of individual entries./38 The SORN suggests that SAVE or the USCIS Verification Data Integration Service, its underlying data composite, stores this bulk sensitive information, noting "records collected in the process of enrolling in SAVE and in verifying U.S. citizenship or immigration status are stored and retained in SAVE for ten (10) years from the date of the completion of verification."/39 Given DHS's well-documented demands for individuals' healthcare records and...
36 See National Voter Registration Act, 52 U.S.C. Sec. 20507.
37 SAVE PIA, supra 8, at 5-6.
38 Id. at 6.
39 SORN, supra 6, at 48954-55.
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...other private personal data,/40 these new bulk data collection functions raise important questions about whether DHS will commit to preserving the privacy of this personally identifying information--or whether it will use voter rolls and public benefit files to augment its ability to surveil both U.S. citizens and non-citizens.
In addition, all of these transactions and activities raise potential risks for data security. This risk is borne out in recent events. For example, in 2023, the Centers for Medicare & Medicaid Services (CMS) suffered a data breach that compromised data from millions of individuals./41 In 2015, the Office of Personnel Management (OPM) likewise suffered a data breach which affected approximately 21.5 million individuals./42 Recently, the U.S. federal court filing system was also compromised and as a result documents that were filed under seal may have been leaked including some with the names of witnesses and defendants who were cooperating with law enforcement./43 These incidents highlight the difficulties of robustly protecting data when it is rapidly consolidated and warn against the hasty collection, storage, and centralization of vast amounts of sensitive information.
The Administration has thus far shown insufficient attention to these critical issues, as evidenced by such lapses as a recent whistleblower report alleging that a DOGE employee created "a live copy of the country's Social Security information in a cloud environment that circumvents oversight."/44 Given the substantial privacy and security risks at stake, the Administration must commit to the safe, secure and lawful use of data by the SAVE program.
Conclusion
For the foregoing reasons, we urge DHS to withdraw its incorporation of U.S. citizen data as well as its new Routine Uses. We also call upon DHS to reconsider all other changes to the SAVE Program set forth in its October 31, 2025, SORN, which as described above would impose undue burdens on state and local governments and would jeopardize the rights of individuals.
40 See, e.g., Kimberly Kindy & Amanda Seitz, Trump Administration Gives Personal Data of Immigrant Medicaid Enrollees to Deportation Officials, AP News (June 14, 2025), https://apnews.com/article/medicaid-deportationimmigrants-trump-4e0f979e4290a4d10a067da0acca8e22; Priscilla Alvarez, et al., DOGE is Building a Master Database for Immigration Enforcement, Sources Say, CNN (April 25, 2025), https://www.cnn.com/2025/04/25/politics/doge-building-master-database-immigration; Makena Kelly & Vittoria Elliott, DOGE Is Building a Master Database to Surveil and Track Immigrants (April 18, 2025), https://www.wired.com/story/doge-collecting-immigrant-data-surveil-track/.
41 See Steve Adler, CMS Confirms 3.1 Million Individuals Affected by MOVEit Hack on Wisconsin Physicians Service, HIPAA Journal (Sept. 25, 2024), available at https://www.hipaajournal.com/cms-wisconsin-physiciansservice-moveit-hack/.
42 See Congressional Research Service,Cyber Intrusion into U.S. Office of Personnel Management: In Brief (July 17, 2015), available at https://www.congress.gov/crs_external_products/R/PDF/R44111/R44111.4.pdf.
43 See John Fritze, Federal judiciary says it is the victim of 'escalated cyberattacks,' CNN (Aug. 7, 2025), available at https://www.cnn.com/2025/08/07/politics/federal-judiciary-says-it-is-the-victim-of-escalated-cyberattacks (last visited Nov. 17, 2025).
44 See Letter from Gov't Accountability Project, Protected Whistleblower Disclosure of Charles Borges Regarding Violation of Laws, Rules & Regulations, Abuse of Authority, Gross Mismanagement, and Substantial and Specific Threat to Public Health and Safety at the Social Security Administration, at 3 (Aug. 26, 2025).
Sincerely,
Letitia James, Attorney General of New York
Rob Bonta, Attorney General of California
Philip J. Weiser, Attorney General of Colorado
William Tong, Attorney General of Connecticut
Kathleen Jennings, Attorney General of Delaware
Brian L. Schwalb, Attorney General of the District of Columbia
Anne E. Lopez, Attorney General of Hawaii
Kwame Raoul, Attorney General of Illinois
Aaron M. Frey, Attorney General of Maine
Anthony Brown, Attorney General of Maryland
Andrea Joy Campbell, Attorney General of Massachusetts
Dana Nessel, Attorney General of Michigan
Keith Ellison, Attorney General of Minnesota
Aaron D. Ford, Attorney General of Nevada
Matthew J. Platkin, Attorney General of New Jersey
Raul Torrez, Attorney General of New Mexico
Dan Rayfield, Attorney General of Oregon
Peter Neronha, Attorney General of Rhode Island
Charity R. Clark, Attorney General of Vermont
Nicholas W. Brown, Attorney General of Washington
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Original text here: https://oag.maryland.gov/News/pages/Attorney-General-Brown-Opposes-Trump%e2%80%99s-Latest-Effort-to-Funnel-Americans%e2%80%99-Personal,-Sensitive-Information-into-Mass-Surveil.aspx
Ariz. A.G. Mayes Sues Online Shopping Platform Temu for Stealing Arizonans' Data and Misleading Consumers
PHOENIX, Arizona, Dec. 3 -- Arizona Attorney General Kris Mayes issued the following news release on Dec. 2, 2025:* * *
Attorney General Mayes Sues Online Shopping Platform Temu for Stealing Arizonans' Data and Misleading Consumers
Attorney General Kris Mayes today announced the filing of a lawsuit against Temu, the Chinese online shopping platform, for violations of the Arizona Consumer Fraud Act, including unlawful data collection, violations of customers' privacy, and counterfeiting some of Arizona's most iconic brands.
"We allege that Temu has repeatedly and willfully violated the Arizona ... Show Full Article PHOENIX, Arizona, Dec. 3 -- Arizona Attorney General Kris Mayes issued the following news release on Dec. 2, 2025: * * * Attorney General Mayes Sues Online Shopping Platform Temu for Stealing Arizonans' Data and Misleading Consumers Attorney General Kris Mayes today announced the filing of a lawsuit against Temu, the Chinese online shopping platform, for violations of the Arizona Consumer Fraud Act, including unlawful data collection, violations of customers' privacy, and counterfeiting some of Arizona's most iconic brands. "We allege that Temu has repeatedly and willfully violated the ArizonaConsumer Fraud Act and put the privacy of Arizonans, including minors, at extreme risk," said Attorney General Mayes. "Arizonans should be aware that behind Temu's low prices and shiny advertising, there is real danger. The Temu app can infect users' devices with malware to steal their private data while carefully hiding its tracks."
The complaint, filed yesterday in Maricopa County Superior Court, alleges that Temu deceives customers in multiple ways after luring them in with hard-to-beat prices.
After aggressive marketing efforts in Arizona and across the United States, Temu's mobile app rose in popularity to become the most-downloaded shopping app in the U.S. in 2023 on both Apple iOS and Google Android operating systems. Temu is responsible for tens of millions of shipments to the United States each year--including purchases made, finalized, and received in Arizona--through a network of more than 80,000 China-based sellers.
However, the complaint alleges that Temu does much more than provide Arizonans access to cheap goods. Modeled after an earlier Chinese app, Pinduoduo, the Temu app is allegedly designed to harvest sensitive user data without users' knowledge or consent and to evade detection.
Temu allegedly collects an alarming amount of sensitive user data and personally identifiable information (PII) that goes far beyond what is necessary for a typical online shopping app. According to the lawsuit, the app secretly infiltrates users' devices to access and harvest sensitive information, including the user's precise physical location, the phone's microphone and camera, and the user's private activity on other apps installed on the phone, all without their knowledge or consent.
A review of the Temu app's code allegedly shows that it is purposely designed to evade front-end security review, using multiple layers of encryption to shield its processes from forensic inspection. The app is even able to edit its own code once downloaded to a consumer's phone, potentially allowing it to exploit users' PII and other data--or otherwise control the device--in unknown and unknowable ways.
These serious privacy risks are compounded by the fact that Temu is wholly owned by a Chinese company and subject to Chinese law, including laws that mandate secret cooperation with the Chinese Communist Party's intelligence apparatus.
In addition to the alleged privacy violations, the complaint also alleges that Temu has engaged in deceptive and unfair trade practices in the offer and sale of products and in the resolution of consumer complaints, including:
* Advertising items that look nothing like the items that eventually arrive;
* Faking customer reviews;
* Using consumer payment information to order items the consumer never asked for;
* Misappropriating the intellectual property of U.S.-owned companies, including some of Arizona's most iconic brands including the Arizona Cardinals, Fender Guitars, the University of Arizona, Arizona State University, and Northern Arizona University;
* Charging for goods not ordered or not delivered;
* Using bait and switch signup schemes to lure users to invite their friends to the app in exchange for the promise of prizes and rewards that never arrive; and
* Using forced labor in clear violation of U.S. trade policies.
"I will not stand by while a Chinese company vacuums up reams of sensitive data from Arizonans' phones and profits from deception and abuse," said Attorney General Mayes. "We are taking Temu to court to stop these practices, protect Arizonans' privacy, and hold Temu fully accountable under Arizona law."
If you believe you have been a victim of consumer fraud or unfair practices, you can file a consumer complaint by visiting the Attorney General's website at www.azag.gov/consumer. If you need a complaint form sent to you, you can contact the Attorney General's Office in Phoenix at (602) 542-5763, in Tucson at (520) 628-6648, or outside the Phoenix and Tucson metro areas at (800) 352-8431.
Read the Attorney General's complaint here (https://azag.us5.list-manage.com/track/click?u=cc1fad182b6d6f8b1e352e206&id=0c186748f5&e=9153ff6c96).
See links to photos from the Attorney General's complaint (https://azag.us5.list-manage.com/track/click?u=cc1fad182b6d6f8b1e352e206&id=61184915f0&e=9153ff6c96).
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Original text here: https://www.azag.gov/press-release/attorney-general-mayes-sues-online-shopping-platform-temu-stealing-arizonans-data-and
Washington's AI Task Force delivers policy recommendations to promote innovation and protect individual rights
OLYMPIA, Washington, Dec. 2 -- Washington state Attorney General Nick Brown issued the following news release:* * *
Washington's AI Task Force delivers policy recommendations to promote innovation and protect individual rights
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The Washington State Artificial Intelligence (AI) Task Force released its interim report on Monday, which delivers eight key policy recommendations to the governor and the legislature aimed at balancing the immense potential of AI with the critical need to protect the rights, privacy, and economic well-being of Washingtonians. The AI task force was established by the ... Show Full Article OLYMPIA, Washington, Dec. 2 -- Washington state Attorney General Nick Brown issued the following news release: * * * Washington's AI Task Force delivers policy recommendations to promote innovation and protect individual rights * The Washington State Artificial Intelligence (AI) Task Force released its interim report on Monday, which delivers eight key policy recommendations to the governor and the legislature aimed at balancing the immense potential of AI with the critical need to protect the rights, privacy, and economic well-being of Washingtonians. The AI task force was established by theLegislature and is administered by the Attorney General's Office.
"AI has the potential to create enormous benefits for our state, but unregulated deployment of this technology can entrench discrimination, erode personal privacy, and displace workers," said Attorney General Nick Brown. "This report provides sensible policy recommendations for the legislature and the governor that strive to balance innovation and economic growth with the protection of individual rights, particularly the rights of historically marginalized or disadvantaged groups."
As the federal government has shown little interest in pursuing meaningful regulation of this transformative technology, states are increasingly responsible for establishing robust AI policy.
The interim report, which follows the task force's preliminary findings from late 2024, is the result of collaboration among 19 members from government, business, civil rights, and community groups. The core recommendations are:
* Establish the National Institute for Standards and Technology (NIST) ethical and trustworthy AI principles as the guiding framework for AI development and use in Washington.
* Require AI developers to publicly disclose information about the provenance, quality, quantity, and diversity of datasets used for training AI models.
* Mandate that developers and deployers of high-risk AI systems (those impacting health, safety, or fundamental rights) implement and publicly disclose robust AI governance frameworks and risk management strategies.
* Increase investments to improve K-12 STEM education, integrate AI tools, and expand access to broadband.
* Require that any decision to deny, delay, or modify health services be made only by qualified clinicians, even when AI is used in the process, and that AI systems apply the same clinical criteria as licensed professionals.
* Create an independent, multi-stakeholder advisory group to establish guiding principles for the ethical use of AI in employment.
* Mandate that law enforcement agencies publicly disclose the use of AI technologies and require officers to attest to the accuracy of AI-assisted reports.
* Establish a grant program utilizing public and private funding to promote AI innovation by small businesses that serves the public interest.
The interim report is the second of three reports required by ESSB 5838, which established the task force. The Final Report is due to the legislature on July 1, 2026.
The full Washington State Artificial Intelligence Task Force Interim Report can be accessed on the Attorney General's Office website.
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Original text here: https://www.atg.wa.gov/news/news-releases/washington-s-ai-task-force-delivers-policy-recommendations-promote-innovation
Mo. A.G. Hanaway Delivers On Promise To Protect Children With Age-Verification Rule Now In Force
JEFFERSON CITY, Missouri, Dec. 2 -- Missouri Attorney General Catherine Hanaway issued the following news release on Dec. 1, 2025:* * *
Attorney General Hanaway Delivers On Promise To Protect Children With Age-Verification Rule Now In Force
Today, Missouri Attorney General Catherine Hanaway announced that Missouri's new age-verification rule for pornographic websites is now fully in force, delivering one of the most significant online child-protection victories in state history. The rule, promulgated under the Missouri Merchandising Practices Act, requires commercial pornographic websites to ... Show Full Article JEFFERSON CITY, Missouri, Dec. 2 -- Missouri Attorney General Catherine Hanaway issued the following news release on Dec. 1, 2025: * * * Attorney General Hanaway Delivers On Promise To Protect Children With Age-Verification Rule Now In Force Today, Missouri Attorney General Catherine Hanaway announced that Missouri's new age-verification rule for pornographic websites is now fully in force, delivering one of the most significant online child-protection victories in state history. The rule, promulgated under the Missouri Merchandising Practices Act, requires commercial pornographic websites toverify that users are adults before granting access to explicit content.
Within hours of the rule taking effect, Pornhub announced it would shut down access to its website in Missouri rather than comply with the regulation, confirming that one of the world's largest pornography companies finds it easier to abandon the Missouri market than to ask users to prove they are 18 years or older.
"Pornhub's decision proves exactly why this rule is necessary," said Attorney General Hanaway. "If a billion-dollar corporation would rather leave Missouri than verify that children are not accessing graphic sexual content, that tells you everything you need to know about its priorities. We are proud to stand on the side of parents, families, and basic decency. Missouri will not apologize for protecting children."
Under Missouri's rule, now fully enforceable, any commercial website or platform with one-third or more pornographic content must implement robust, meaningful age-verification measures. This rule balances privacy rights of adults, while protecting Missouri children from the devastating harms of online pornography. Platforms that refuse to comply are subject to penalties, injunctive relief, and enforcement actions for engaging in unfair and deceptive practices.
Research shows that the average age of first exposure to pornography is just 11 or 12 years old, with the overwhelming majority of teenagers encountering violent, degrading, or explicitly misogynistic material online. These harms contribute to exploitation, distort young people's understanding of sex, and undermine healthy relationships. Neuroscientific studies show that pornography can have addictive effects similar to dangerous substances, leaving children especially vulnerable.
Despite these devastating realities, Pornhub published a statement to Missouri users claiming that asking adults to provide basic age verification is "not the most effective solution." Instead of implementing protections, Pornhub chose to turn off its website statewide.
"Pornhub is welcome to leave Missouri. What is not welcome is any company that puts profit above the safety of our children," Attorney General Hanaway said. "Protecting Missouri's children is of the greatest importance. If companies choose to walk away instead of complying with the law, that is their decision, but it is absolutely a victory for Missouri families."
Missouri families can expect immediate enforcement of the rule, and the Attorney General's Office stands ready to investigate and hold violators accountable.
"Our message is simple: If you want to operate in Missouri, you must prove your users are adults. If that is too much to ask, then you will not operate here," said Attorney General Hanaway. "Missouri is leading the nation in protecting children online, and today's development shows that our leadership is working."
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Original text here: https://ago.mo.gov/attorney-general-hanaway-delivers-on-promise-to-protect-children-with-age-verification-rule-now-in-force/
Consumer Alert: Be Aware of Charity Scams on Giving Tuesday
RALEIGH, North Carolina, Dec. 2 -- North Carolina Attorney General Jeff Jackson issued the following news release:* * *
Consumer Alert: Be Aware of Charity Scams on Giving Tuesday
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RALEIGH - This Giving Tuesday, Attorney General Jeff Jackson is warning North Carolinians to be on alert for potential charity scams. Scammers may impersonate legitimate charities in an attempt to take advantage of people who want to donate to a good cause.
"Helping each other out is what the holiday season is all about," said Attorney General Jeff Jackson. "But don't let these bad actors abuse your kindness. ... Show Full Article RALEIGH, North Carolina, Dec. 2 -- North Carolina Attorney General Jeff Jackson issued the following news release: * * * Consumer Alert: Be Aware of Charity Scams on Giving Tuesday * RALEIGH - This Giving Tuesday, Attorney General Jeff Jackson is warning North Carolinians to be on alert for potential charity scams. Scammers may impersonate legitimate charities in an attempt to take advantage of people who want to donate to a good cause. "Helping each other out is what the holiday season is all about," said Attorney General Jeff Jackson. "But don't let these bad actors abuse your kindness.Know what a charity scam looks like, and file a report with my office if you come across one."
If you're looking to donate to charity, here's how to help ensure that your money goes where you intended.
* Make sure you're giving to a legitimate charity. Before you give, check the charity's license with the Secretary of State. You can also research a charity's ratings through the Better Business Bureau's (BBB) Wise Giving Alliance, Charity Navigator, Charity Watch, or GuideStar.
* Don't respond to unsolicited fundraising calls, emails, and text messages. Messages might look or sound legitimate, but actually be phishing scams that direct you to copycat websites to get your money or personal information. If you're receiving unsolicited calls, contact your cellphone provider and ask if they have a spam call-blocking app or service that can block unwanted calls. All providers should offer this service at no additional charge to you.
* Watch out for social media and crowdfunding scams. While crowdfunding platforms like GoFundMe can help people share and support causes, scammers sometimes use them to trick you into donating to a cause that doesn't exist. Before you give, take time to research the organizer. If you can't find them online or if their details don't match up with the post, don't contribute. Only give to a crowdfunding campaign if you can verify the identity of the organizer.
* Pay by credit card or check. Paying by a credit card is easier for security and tax records. If you're paying by check, make out the check to the charity, not a fundraiser or specific person. Remember that legitimate charities will never ask you to donate by purchasing or redeeming gift cards for themselves or any individual affiliated with them. Do not make any donations in cryptocurrency without first fully vetting the charity.
* And if you're feeling pressured to give immediately, don't. A legitimate charity will encourage you to give, but won't press you into donating.
For additional resources to help you avoid charity scams, please click here. You may also consider donating to North Carolina's food banks, which are still struggling to keep up with the demand for food amidst higher costs and recovery from the SNAP benefits pause. Find a local food bank here.
Scammers will often target members of our community who are older and more vulnerable to these types of manipulative acts. If you or someone you know has been the victim of a scam, file a complaint with our office's Consumer Protection Division at http://www.ncdoj.gov/complaint or by phone at 1-877-5-NO-SCAM. Together, we can help each other enjoy this special time of year without scammers taking advantage of our generosity.
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Original text here: https://ncdoj.gov/consumer-alert-be-aware-of-charity-scams-on-giving-tuesday/
Attorney Stefanie Lambert and Former Adams Township Clerk Scott to Stand Trial for Alleged 2020 Election Voter Data Breach
LANSING, Michigan, Dec. 2 -- Michigan Attorney General Dana Nessel issued the following news release:* * *
Attorney Stefanie Lambert and Former Adams Township Clerk Scott to Stand Trial for Alleged 2020 Election Voter Data Breach
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LANSING - Yesterday, former Adams To wnship Clerk Stephanie Scott, 53, and her private attorney Stefanie Lynn Junttila, 44, also known as Stefanie Lambert, were bound over to stand trial in the 1st Circuit Court in Hillsdale County for allegedly permitting an unauthorized computer examiner access to voter data, including non-public voter information, concerning ... Show Full Article LANSING, Michigan, Dec. 2 -- Michigan Attorney General Dana Nessel issued the following news release: * * * Attorney Stefanie Lambert and Former Adams Township Clerk Scott to Stand Trial for Alleged 2020 Election Voter Data Breach * LANSING - Yesterday, former Adams To wnship Clerk Stephanie Scott, 53, and her private attorney Stefanie Lynn Junttila, 44, also known as Stefanie Lambert, were bound over to stand trial in the 1st Circuit Court in Hillsdale County for allegedly permitting an unauthorized computer examiner access to voter data, including non-public voter information, concerningthe 2020 General Election, announced Michigan Attorney General Dana Nes sel. Scott was bound over on:
* One count of Using a Computer to Commit a Crime, a seven-year felony;
* One count of Computers - Unauthorized Access, a five-year felony;
* One count of Conspiracy to Commit the Offense of Computers -Unauthorized Access, a five-year felony; and
* One count of Misconduct in Office, a five-year felony.
Scott additionally faces one count of Disobeying a Lawful Instruction or Order of the Secretary of State as Chief Election Officer, a 90-day misdemeanor.
Lambert was bound over on:
* One count of Using a Computer to Commit a Crime, a seven-year felony;
* One count of Computers - Unauthorized Access, a five-year felony; and
* One count of Conspiracy to Commit the Offense of Computers -Unauthorized Access, a five-year felony.
"The deliberate violation of voter privacy to push a false agenda and spew misinformation is reckless and illegal," Nessel said. "My office takes these allegations very seriously and looks forward to further pursuing this case through the judicial process to defend the rights of Michiganders and protect their personal election data."
The Michigan State Police referred this matter to the Department of Attorney General, following its investigation into possible election law violations by the former Adams Township Clerk. Attorney General Nessel announced charges against Lam b ert and Scott in Ma y 2024.
Please note: For all criminal proceedings, a criminal charge is merely an allegation. The defendant is presumed innocent unless and until proven guilty. The Department does not provide booking photos.
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Original text here: https://www.michigan.gov/ag/news/press-releases/2025/12/02/attorney-stefanie-lambert-and-former-adams-township-clerk-scott
ATTORNEY GENERAL RAOUL OPPOSES TRUMP ADMINISTRATION'S NEW RULE PUTTING ILLINOIS WORKERS AT RISK OF LOSING THEIR JOBS
CHICAGO, Illinois, Dec. 2 -- Illinois Attorney General Kwame Raoul issued the following news release:* * *
ATTORNEY GENERAL RAOUL OPPOSES TRUMP ADMINISTRATION'S NEW RULE PUTTING ILLINOIS WORKERS AT RISK OF LOSING THEIR JOBS
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Chicago - Illinois Attorney General Kwame Raoul, as part of a coalition of 16 attorneys general, submitted comments opposing the U.S. Department of Homeland Security's (DHS) interim final rule that eliminates the automatic extension of Employment Authorization Documents (EADs) for up to 540 days for eligible workers who filed timely renewal applications. Now, immigrant ... Show Full Article CHICAGO, Illinois, Dec. 2 -- Illinois Attorney General Kwame Raoul issued the following news release: * * * ATTORNEY GENERAL RAOUL OPPOSES TRUMP ADMINISTRATION'S NEW RULE PUTTING ILLINOIS WORKERS AT RISK OF LOSING THEIR JOBS * Chicago - Illinois Attorney General Kwame Raoul, as part of a coalition of 16 attorneys general, submitted comments opposing the U.S. Department of Homeland Security's (DHS) interim final rule that eliminates the automatic extension of Employment Authorization Documents (EADs) for up to 540 days for eligible workers who filed timely renewal applications. Now, immigrantworkers, including refugees, asylees, and others who have already been vetted to work legally in the United States, may face a gap in their employment authorization - and lose their jobs - because DHS cannot process the renewal application in a timely manner.
"This change will punish workers who have followed all of the rules simply because the Department of Homeland Security has a backlog of renewal applications," Raoul said. "This new rule puts up to 100,000 Illinois workers at risk of losing their jobs. It will harm state economies and be devastating for people who rely on timely renewals of their work authorization documents to maintain their ability to support their families."
DHS implemented regulations in 2016 that automatically extended employment authorization once the applicant filed a renewal application. The automatic 180-day extension aimed to address chronic processing backlogs by giving DHS more time to review renewal applications without unfairly penalizing applicants. This was subsequently expanded to 540 days to address further backlogs caused by the COVID-19 pandemic, a hiring freeze, and an increase in the number of filings necessary to receive work authorization. According to DHS' own estimates, between 306,000 and 468,000 employment authorizations would have lapsed if not for the rule authorizing automatic renewals.
On Oct. 30, DHS published an interim final rule ending its policy of automatically extending employment authorization for up to 540 days for those who filed timely renewal applications. DHS already takes more than six months to process many employment authorization document renewals for asylum seekers, and even longer for many other groups.
DHS alleges that the automatic extension "poses a security vulnerability," yet it provides no evidence that the automatic renewal of work authorization for already-vetted immigrant workers poses any safety threat. DHS' new rule ends automatic extensions for pending renewal applications even as the agency continues to face serious backlogs and processing delays and shows no plans to address the additional strain this will place on the system.
In their comment letter, Attorney General Raoul and the coalition explain the rule will inevitably lead to job losses and economic instability. They argue it will harm immigrant workers by negatively impacting their physical and mental health, food security, ability to secure stable housing, and access to employer-sponsored health insurance. In addition, the rule will harm Illinois and other states by decreasing tax revenue and the spending power of residents, increasing health care costs, increasing the burden on state-funded nonprofits, and increasing law enforcement challenges.
The coalition argues that the rule is arbitrary and capricious in violation of the Administrative Procedures Act. They also assert that DHS illegally implemented the rule immediately without giving the public an opportunity to comment.
Attorney General Raoul is joined in sending the letter by the attorneys general of California, New York, Connecticut, the District of Columbia, Hawaii, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, Oregon, Vermont and Washington.
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Original text here: https://www.illinoisattorneygeneral.gov/news/story/attorney-general-raoul-opposes-trump-administrations-new-rule-putting-illinois-workers-at-risk-of-losing-their-jobs