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Comment in Opposition, RIN 1105–AB80, Certification Process for State Capital Counsel Systems, 91 Fed. Reg. 12525 (Mar. 16, 2026), Docket (DOJ-OAG-2026-0034)
The National Lawyers Guild (“NLG”) submits this comment in strong opposition to the Department of Justice’s proposed rule amending 28 CFR Part 26 (“Proposed Rule”). The NLG is the nation’s oldest and largest progressive bar association, and our members across the country regularly represent individuals fighting capital punishment. Hence, the Proposed Rule directly affects our […] The post Comment in Opposition, RIN 1105–AB80, Certification Process for State Capital Counsel Systems, 91 Fed. Reg. 12525 (Mar. 16, 2026), Docket (DOJ-OAG-2026-0034) first appeared on National Lawyers Guild.
As a concerned taxpayer, I find the proposed certification process for state capital counsel systems overly bureaucratic and potentially costly. The involvement of federal agencies seems unnecessary and could lead to unnecessary delays in providing critical services to those in need. I hope that this process can be streamlined to ensure that those who need legal representation receive it promptly and without undue burden.
The certification process for state capital counsel systems outlined in RIN 1105-AB80 raises serious concerns about potential conflicts of interest and the ability to provide impartial representation. As a long-time advocate for fair legal systems, I find the requirement for rigorous background checks and conflict-of-interest disclosures troubling, as it could limit access to legal representation for those who need it most.
As someone who has closely followed the legal landscape, I must say that the certification process for state capital counsel systems outlined in the RIN 1105–AB80 seems overly burdensome and potentially stifling for innovative legal strategies. The extensive documentation and review required could delay crucial assistance that might otherwise be available to those in need.
I find the new certification process for state capital counsel systems to be overly bureaucratic and time-consuming. It will likely stifle innovation and flexibility in how these important roles are filled.
I find it troubling that the certification process for state capital counsel systems is being rubber-stamped without thorough review. This could have serious implications for the legal rights of individuals involved in capital cases.