President Trump Issues Message on International Holocaust Remembrance Day

Today is International Holocaust Remembrance Day, the 81st anniversary of the liberation of Auschwitz-Birkenau. The White House today posted a Presidential Message on International Holocaust Remembrance Day (full text) which reads in part:

Today, we pay respect to the blessed memories of the millions of Jewish people, who were murdered at the hands of the Nazi Regime and its collaborators during the Holocaust— as well as the Slavs and the Roma, people with disabilities, religious leaders, persons targeted based on their sexual orientation, and political prisoners who were also targeted for systematic slaughter.  We renew our resolve that freedom, justice, and the dignity of the human person will always conquer the forces of evil, tyranny, and oppression....

... After I took office as the 47th President of the United States, I proudly made it this administration’s priority directing the Federal Government to use all appropriate legal tools to combat the scourge of anti-Semitism.  My Administration will remain a steadfast and unequivocal champion for Jewish Americans and the God-given right of every American to practice their faith freely, openly, and without fear....

Florida Church Seeks Stay of Trial Court's Injunction Barring Use of Its Strip Mall Unit for Religious Services

Yesterday, a Florida church filed an emergency motion with a Florida state trial court asking it to stay a temporary injunction that it issued on January 23 while the church files an appeal. The emergency motion and the memorandum in support of it in Flagler Square-JAX, Inc. v. Palmer, (FL Cir. Ct., filed 1/26/2026) (full text) says in part:

The Order constitutes a prior restraint in speech, assembly, and religious exercise, prohibiting Defendant and Coastal Family Church from holding religious services. The Order has already prevented Defendant form hosting in-person religious services on Sunday, January 25, 2026. Each additional Sunday that passes inflicts continuing irreparable harm upon Defendant, the Church, and its congregants.

An October press release from Liberty Counsel provides background:

In July 2025, Pastor Roderick Palmer purchased a unit in the Flagler Square strip mall to serve as the home for Coastal Family Church. However, after the church began holding services, Flagler Square – JAX, Inc, the condominium association that oversees the mall’s four units, sued Pastor Palmer for holding “public assemblies” that allegedly violate a “condominium declaration” which prohibits such assemblies. In the complaint, the association claims the church’s services “would overwhelm available parking at all times” despite Sunday services leaving more than 160 parking spots available....

A January 26 Liberty Counsel press release summarizes the Church's arguments on appeal.

3rd Circuit Hears Arguments in Yeshiva's Zoning Dispute

Last Thursday, the U.S. Third Circuit Court of Appeals heard oral arguments (audio and transcript of full oral arguments) in Anash, Inc. v. Borough of Kingston, (3d Cir., argued 1/22/2026). In the case, a Pennsylvania federal district court refused to grant a preliminary injunction to an Orthodox Jewish Yeshiva whose property was condemned.  The Borough of Kingston contended that the property was being used for a school and dormitory in violation of zoning ordinances. The district court concluded that plaintiff was not suffering irreparable harm, and that it was not likely that plaintiff would succeed on the merits of its challenge to the relevant zoning ordinance. (See prior posting.)  On appeal, the Yeshiva claimed violations of RLUIPA and of the due process clause.

Recent Articles and Books of Interest

From SSRN:

• Lael Daniel Weinberger & Branton Nestor, Church Autonomy and Interlocutory Appeals, (January 14, 2026).
• Michael A. Helfand, Mapping Carson: New Frontiers of Religious Exclusion in Government Programs, (Notre Dame Law Review, forthcoming).
• Ekaterina Ryzhkova, The Influence of the Islamic Legal Tradition on the Institution of Public Finance in the Countries of the East, (December 06, 2025).
• Dennis Wieboldt, "Shall We Settle for Anything Less Than Complete Equality?" Catholic Power and the First National Fight for Parental Rights in Education, 1947-1962, (34 Rel. & Am. Cul. __ (2026)).
• Oruj Ismayilov, Was Adam the First Biological Human? A Qur'anic Account of Human Origins as a Metaphysical Turning Point, (December 28, 2025).
• Pranav Ankush Jadhav SP, The Hindu Minority Crisis: Understanding Recent India-Bangladesh Tensions, (December 26, 2025).
• Zahir Khan, Application of Islamic Law of Tort in Pakistan's Legal System: A Critical and Comparative Analysis, (December 29, 2025).
• John M. Bickers, A Tale Told in Reverse: Military Retirees and the Benefit of Clergy, (January 09, 2026).

Recent and Forthcoming Books:

• Andrew T. Hayashi & Allen Calhoun (eds.), Justice in Taxation: Christian Perspectives, (Routledge, June 2026).
• Konrad Dyda, The Legal System of the Vatican City State: Between Secular and Canon Law, (Routledge, October 2025).
• Jonathan Crowe, Constance Youngwon Lee & Joshua Neoh, Jurisprudence and Theology: The Australian School, (Routledge, November 2025).
• Brandon Vaidyanathan, Sara Perla and Stephen White, Rebuilding Trust: Clergy Morale in the Wake of the Abuse Crisis, (Catholic University Press, Nov. 2025).

NIH Ends Funding of Research Using Human Fetal Tissue from Elective Abortions

On Thursday, the National Institute of Health announced (press release) that it will no longer fund research involving human fetal tissue from elective abortions, saying in part:

“This decision is about advancing science by investing in breakthrough technologies more capable of modeling human health and disease. Under President Trump’s leadership, taxpayer-funded research must reflect the best science of today and the values of the American people.”

NIH-supported research using human fetal tissue has declined steadily since 2019, with only 77 projects funded in Fiscal Year 2024. At the same time, advances in organoids, tissue chips, computational biology, and other cutting-edge platforms have created robust alternatives that can drive discovery while reducing ethical concerns. The updated policy ensures that limited public resources are directed toward research approaches that offer the greatest potential to improve health outcomes for all Americans.

Catholic Vote reports on the NIH announcement.

HHS Says Illinois Right to Conscience Act Violates Federal Law

On January 21, the Department of Health and Human Services Office of Civil Rights sent a Notice of Violation (full text) to the state of Illinois. The Notice informs the state that HHS has found that the Illinois Health Care Right of Conscience Act violates federal bans on discrimination against pro-life health care entities that do not refer patients elsewhere for abortions. The Illinois law generally provides a shield from liability to health care personnel that refuse on conscience grounds to perform abortions, but only if the objecting provider either refers or transfers the patient elsewhere or at least furnishes the patient written information about other health care providers who likely offer abortion services. In its Notice of Violation, HHS takes the position that discriminating against entities that do not "refer" out for abortions includes denying legal defenses to entities that do not either transfer patients to another provider or give patents written information about alternative providers. ADF issued a press release discussing HHS's action.

Anti-Abortion Sidewalk Counselor Loses Challenge to City's Sign Ordinance

In Hamann v. City of Carbondale, Illinois, (SD IL, Jan. 21, 2026), an Illinois federal district court refused to preliminarily enjoin the city of Carbondale's sign ordinance. The Ordinance prohibits plaintiff, a Christian minister, from temporarily placing his anti-abortion signs in the ground on public property near an abortion clinic while he is attempting to persuade women not to have an abortion. Under the Ordinance, he can carry or wear the signs but cannot place them into the ground. The court rejected plaintiff's claims that the Ordinance is unconstitutionally vague and violates his free speech rights. It concluded that the Ordinance is a permissible time, place and manner regulation of speech in a public forum. The court went on in part:

Hamman’s final argument advances a theory of viewpoint discrimination based on the City’s “policy of inaction” towards signs that share messages other than his.... He submitted photos of three temporary signs he found throughout Carbondale which, he believes, were placed in the public right of way and not removed the way his were. From there, he contends that the City engaged in a “targeted campaign of enforcement” against his signs based on their anti-abortion messages....

Hamman acknowledges that he does not know how long these signs had been in the public right of way when he photographed them. This, then, leaves open the possibility that the City had not had time to remove them—something that, Lenzini explained, can happen from time to time. Surely, if these signs had been placed in the public right of way with the City’s permission, or been left there after the City became aware of them, such evidence would support Hamman’s claim of selective enforcement. But the record reveals no such evidence....

Pope Leo Is Invited to Join Trump's Board of Peace

Speaking to the press on Wednesday, Vatican Secretary of State Cardinal Pietro Parolin confirmed that Pope Leo XIV has been invited by President Donald Trump to join the Board of Peace for Gaza.  According to Vatican News:

Turning to the topic of the Board of Peace for Gaza, the Cardinal reflected on how President Trump is inviting a number of countries to participate.

“I believe I read in the newspaper this morning that Italy, too, is considering whether or not to join,” he continued, “We also received the invitation to the Board of Peace for Gaza; the Pope has received it, and we are considering what to do.”

He argued, “It is an issue that requires some time to be properly assessed and to provide a response.”

Speaking about the Board of Peace for Gaza, the Cardinal said that the Holy See would not take part financially, noting, “We are not even in a position to do so.”

However, he pointed out that the Vatican is in a different situation from other countries, and therefore the analysis will be different. But, the Cardinal said, “I believe the request will not be for economic participation.”

Samoa's Prime Minister Suggests Restricting Religious Liberty for Non-Christians

 Australian Broadcasting Corp. reported this week that in the Southern Pacific island nation of Samoa, with a population of 220,000, religious liberty is being threatened. According to ABC's report:

... [T]he country's prime minister has thrown the future of its religious minorities into doubt after flagging potential restrictions on non-Christian faiths last month.

Laaulialemalietoa Polataivao Fosi Schmidt said he wanted to stop Samoa encountering the same religious divisions as "neighbouring countries", and in the Middle East.

"It may not be happening now, but there will come a time when a large number could gather under a non-Christian religion in Samoa. Then we will face what we do not wish to see," he said....

Laaulialemalietoa has asked the nation's peak Christian body, the Samoa Council of Churches, to advise him on the country's religious freedom laws....

"I am prepared to take the necessary actions on what Samoa decides — perhaps through a referendum or national discussion — to consider amending the constitution regarding the freedom of religion," he said.

The prime minister, who has gained a loyal voting base with his devout Christian public persona, is moving quickly to stamp his religious agenda on other parts of Samoan society since his August election victory.

His government has made weekly fasting and prayer mandatory for public servants. ...

And as the prime minister raised the potential restrictions on non-Christian faiths last month, he announced a ban on construction work on Sundays....

5th Circuit En Banc Hears Challenges To 2 States' Laws Requiring Posting of 10 Commandments in Classrooms

The U.S. 5th Circuit Court of Appeals yesterday, sitting en banc, heard oral arguments in two cases raising the question of the constitutionality of state laws requiring the posting of the Ten Commandments in public school classrooms. (Audio of full oral arguments.)   Roake v. Brumley challenges the Louisiana statute.  In that case a 3-judge panel of the 5th Circuit affirmed a district court's grant of a preliminary injunction, after which the 5th Circuit granted en banc review. In Nathan v. Alamo Heights Independent School District, a Texas federal district court issued a preliminary injunction barring 11 Texas school districts from complying with Texas SB 10 that requires posting of a particular version of the Ten Commandments in every classroom. On appeal, the 5th Circuit consolidated it for argument with the previously granted en banc hearing on the Louisiana law without a prior 3-judge panel hearing the appeal. NOLA reports on the cases.

Certiorari Denied in Chabad's Suit Against the Russian Federation

The U.S. Supreme Court today denied review in Agudas Chasidei Chabad v. Russian Federation, (Sup. Ct., Docket No. 24-909, certiorari denied 1/20/2026) (Order List). The case is part of the long-running attempt by Chasidei Chabad of the United States to force Russia to return two collections of valuable Jewish religious books and manuscripts which it expropriated decades ago. In 2010, Chabad obtained a default judgment against the Russian Federation. (See prior posting.) In 2013, the D.C. federal district court held the Russian Federation in contempt for failing to comply with the order to return the books and imposed $50,000 per day sanctions on the Russian Federation. (See prior posting.) Those sanctions have now accrued to over $175 million. Most recently, Chabad has attempted to collect these amounts by attaching the property of three companies it claims are owned and controlled by the Russian Federation. In a 2024 opinion (full text), the D.C. Circuit Court of Appeals held that the Russian Federation had sovereign immunity under the Foreign Sovereign Immunities Act so that the default judgment entered in 2010 was invalid. Without a valid judgement, according to the D.C. Circuit "there is no predicate for Chabad to attach the property of companies the Federation allegedly owns and controls." It is this decision that the Supreme Court today refused to review.

This may not end the case, however, because the D.C. Circuit said that it was not reversing the district court's finding of jurisdiction over the Russian State Library and the Russian State Military Archive which currently hold the book collections. The D.C. Circuit also said that Chabad may be able to sue the Russian Ministry of Culture and Mass Communications.

Media Report U.S. Is Considering Offering Asylum to British Jews

Media in Britain, the U.S. and Israel are reporting that the U.S. State Department is considering offering asylum to British Jews because of antisemitism present in Britain. The reports are based on an interview by The Telegraph with Donald Trump's personal lawyer, British-born Robert Garson. As reported by The Guardian in part::

Discussions are reportedly under way within Donald Trump’s administration about the US possibly granting asylum to Jewish people from the UK, according to the Telegraph, citing the US president’s personal lawyer.

Trump lawyer Robert Garson told the newspaper that he has held conversations with the US state department about offering refuge to British Jews who are leaving the UK citing rising antisemitism....

Garson, 49, said he felt the UK was “no longer a safe place for Jews”. He added that recent events – namely an Islamist attack on a synagogue in Manchester and what he described as widespread antisemitism following the Hamas attack on Israel on 7 October 2023 – had led him to believe that British Jews should be given the option of sanctuary in the US....

Garson said he raised the idea of the US acting as a refuge for British Jews with Trump’s special envoy to monitor and combat antisemitism, Yehuda Kaploun....