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BALTIMORE, MD—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 data 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, 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, Hawaiʻi, Illinois, Maine, Massachusetts, Michigan, Minnesota, Nevada, New Mexico, Oregon, Rhode Island, and Vermont.
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