Earlier this year, the Heritage Foundation’s Project 2025 released its Mandate for Leadership: The Conservative Promise, a 900-page policy agenda for conservative governance. The plan outlines a series of legislative and policy proposals around many core conservative issues, including gender and immigration.
Project 2025, as it is more commonly known, contains a number of policy recommendations catastrophic to the safety of migrant women and girls. Beneath the dense and often abstract policy language are policies that upend the basic protections migrant women rely on to meet their immediate needs and those of their children. Obscure sounding proposals that seem like bureaucratic adjustments would in practice empower abusers and place immigrant women at serious risk.
The Women’s Refugee Commission (WRC) has identified the Project 2025 proposed policies most harmful to migrant women and girls.
Project 2025 is dangerous for migrant women because it proposes to eliminate restrictions that prevent the US Immigration and Customs Enforcement (ICE) from detaining migrants in “sensitive” locations, including domestic violence shelters.
Since 2011, the Department of Homeland Security (DHS) has recognized certain kinds of locations as “sensitive zones,” meaning that they are considered so essential to life and health that ICE (the immigration enforcement arm of DHS) is largely forbidden from operating there. A recently expanded list includes schools, medical facilities, and places where social services are offered.
The practice of refraining from immigration enforcement in sensitive zones allows immigrant women to meet their own immediate health and safety needs, and those of their children. Knowing that these spaces are safe allows an immigrant parent to take their child to the emergency room, or victim of domestic violence to go a shelter, without fear that ICE will target them there. Eliminating sensitive zones would allow ICE agents to enter these locations at will, forcing women into impossible choices between their safety and arrest or deportation. It could also transform domestic violence shelters, hospitals, and other protected areas into routine sites of immigration enforcement, risking trauma to all people seeking help and safety there.
Project 2025 is dangerous for migrant women because it proposes to eliminate visas that allow victims of domestic violence and human trafficking to leave abusive situations.
Project 2025 proposes eliminating U and T visas, which allow victims of human trafficking (T visa) and violent crime (U visa) to report their abuse to the authorities, access medical care and other essential services, and get the work authorization they need to support themselves after abuse, without risking deportation. More than 75% of U visa applicants are victims of rape, domestic violence, child abuse, and human trafficking.
U and T visas are lifelines for immigrant victims of domestic violence and human trafficking, allowing them to leave an abusive situation and still provide for themselves and their children. Even the act of filing an application provides vital protection, triggering an internal government alert that prevents abusers from attempting to have their victims deported, a well-known coercion tactic. Law enforcement also depend on U and T visas to investigate crimes like human trafficking, because these efforts often turn on a victim’s safe cooperation.
Because Congress created U and T visas, only Congress can eliminate them entirely. However, a Presidential administration could change how visas are processed, or who qualifies for them, to achieve many of the same goals. For instance, a proposal to pause new applications in a backlogged visa category would likely halt new applications altogether because existing processing times can last years. Suspending new applications would also cut victims off from that vital notification function, handing a powerful tool for coercion back to abusers.
Project 2025 is dangerous for migrant women because it proposes to eliminate access to asylum for victims of gender-based persecution.
US and international law currently recognize five grounds, or reasons, why an individual fleeing persecution could qualify for asylum: race, religion, nationality, political opinion, and membership in a particular social group. Membership in a particular social group is the primary way U.S. asylum law recognizes gender-based persecution, like rape or domestic violence. Eliminating membership in a particular social group would leave women, children, and LGBTQI+ people with no path to asylum if they experience persecution because of their gender or sexual orientation. Project 2025 also proposes reinstating the Trump-era legal decision, Matter of A-B-, which defines particular social group so narrowly that it would exclude many gender-based claims, and nearly all those based on domestic violence.
Project 2025 is dangerous for migrant women because it proposes to reinstate the Trump-era Public Charge regulations.
In 2019, the Trump administration issued regulations making it easier for the federal government to deny green cards and visas to applicants who have used public benefits for which they were legally eligible, including Medicaid and food stamps. The regulation sowed chaos and confusion for low-income migrants.
Although the regulations technically excluded emergency services like domestic violence shelters, and did not apply to U and T visa applicants, its “more likely than not” test left many victims wondering if they could safely access these services. The regulation also cut victims off from healthcare, food assistance, and other lifesaving benefits that many relied on to support themselves and their children after abuse. Reinstating this regulation may force some victims to remain in abusive situations they might otherwise leave, to meet their or their children’s basic needs.
Project 2025 is dangerous for migrant women because it proposes repealing the policies and oversight bodies that protect against human rights abuses in immigration detention.
In addition to substantially increasing the number of migrants who would be placed in mandatory detention, Project 2025 proposes several policies that would expose families, and even unaccompanied children, to dangerous and unregulated detention conditions. These include allowing the government to use tents and “open air” facilities when there are not enough detention beds available.
At the same time as it would subject thousands more migrants to hazardous detention conditions, Project 2025 proposes rolling back the minimum care and safety standards that ensure detention facilities comply with human rights laws and consolidating or even eliminating the offices that monitor immigration enforcement activities for human rights abuses. Not only would this hobble the government’s efforts to comply with laws like the Prison Rape Elimination Act, it would leave migrant women with few avenues to report even systemic sexual abuses.
Building a humane, orderly, and sustainable migration system will take vision and leadership. In our study of reception practices in New York, Denver, Chicago, and Portland, ME, WRC saw that leadership on display, as political and community leaders came together to innovate new approaches for welcoming migrants. Though serious challenges remain, including in these cities, their experiences show that we can meet the needs of the moment without sacrificing safety and opportunity for all.
Solutions also exist at the federal level. Legislation like the Destination Reception Assistant Act would provide vital support to state and local communities welcoming migrants. The Case Management Pilot Program helps migrants navigate complex immigration proceedings, increasing compliance by providing support to migrants rather than placing them in detention. A new Bona Fide Determination process for U and T visa applicants helps overcome processing delays by granting good faith applicants access to work authorization and some services while they wait. These and other innovations reflect our core American values of dignity, humanity, and self-reliance. Project 2025 takes the opposite approach, pushing migrants outside of the law’s protection and beyond the reach of those principles.
