Suit Challenges HHS's Rescission of Sensitive Locations Policy

Suit was filed yesterday in an Oregon federal district court by a group of churches, an interfaith council and a Latino organization challenging the Department of Homeland Security's reversal of its "sensitive locations" policy that had limited immigration enforcement activities in churches, health care clinics and social service agencies. The complaint (full text) in Pineros y Campesinos Unidos del Noroeste, (D OR, filed 4/28/2025), alleges in part:

112. Defendants’ rescission of sensitive locations protections enables immigration enforcement to target sensitive locations and events commonly associated with expression, directly and substantially interfering with the ability of Plaintiffs and their members to associate freely.

113. Following the rescission of protections for sensitive locations, Defendants have shown that immigration enforcement actions will be carried out to punish individuals at sensitive locations from engaging in expressive activity with which Defendants disagree. The rescission of sensitive locations protections has already led to fear and discouragement of participation in planned protests, events, and activities, as well as religious ceremonies....

121. Defendants’ rescission of protections for sensitive locations permits ICE and CBP agents to conduct immigration enforcement activity, including arrests, investigations, and surveillance, at and near houses of worship, locations where houses of worship provide community services, and during religious ceremonies.

122. Such conduct has deterred and will continue to deter membership, attendance, and participation in religious services and related events for all individuals, including lawful permanent residents and U.S. citizens. ICE enforcement will also be likely to disrupt activities and events held by places of worship, including religious ceremonies. The conduct has impacted the free exercise rights of members of the Augustana Lutheran Church; Our Lady of Guadalupe Parish, San Francisco Interfaith Council, and Westminster Presbyterian Church. Plaintiffs’ core work of carrying out religious ceremonies and providing pastoral care to parishioners to further their faith has been disrupted by the need to now prioritize maintaining the safety of their sanctuaries....

Oregon Live reports on the decision.

Court Refuses to Dismiss Megachurch Pastor's Defamation Suit Against Sex Offender

In Jakes v. Youngblood, (WD PA, April 25, 2025), a Pennsylvania federal district court refused to dismiss under Pennsylvania's anti-SLAPP law a defamation suit brought by megachurch pastor T.D. Jakes against convicted sex offender Duane Youngblood.  Jakes sued after Youngblood in a podcast accused Jakes of grooming and sexually abusing him some 40 years earlier when Youngblood was 18 to 19 years old. Anti-SLAPP laws are designed to allow rapid dismissal of suits filed to suppress protected speech. The court, applying the Erie doctrine, held that the Pennsylvania anti-SLAPP law is procedural and thus does not apply to diversity cases in federal court. Instead, dismissal is governed by Federal Rules of Civil Procedure, Rules 12 and 56.  The court said in part:

The Court does not believe that a procedural rule protecting a substantive right is, by virtue of the right it is protecting, transformed into a substantive law. The statute exists to spare those who exercise their free speech rights from unwarranted and harassing litigation. However, §8340.15 pursues this policy goal through procedural means.

Christian Post reports on the decision.

Recent Articles of Interest

From SSRN:

• Michael Conklin, Religious Law Schools, Rankings, and Bias: Measuring the Rankings Penalty at Religious Law Schools, (Florida Journal of Law and Public Policy (forthcoming, 2025)).
• Jeremy Ross, An Empirical Analysis of Tandon and Fulton, (February 20, 2025).
• Steven J. Heyman, Religious Liberty and the Constitution, (Chicago-Kent Law Review, Volume 100, No. 2 (forthcoming 2025)).
• Alan Edward Brownstein, Attempting to Protect the Liberty and Equality of Minority Faiths and Nonreligious Individuals When the Supreme Court Will Not Do So, (Forthcoming, 2025, Chicago-Kent Law Review, in Symposium: "In Search of Common Ground: Religion and Secularism in a Liberal Democratic Society").
• Dina Zingaro, "In the Image of God": Rereading Genesis 1-3 for LGBTQ+ Rights, (March 01, 2025).
• Amelia Miazad, Faith Investors, (November 01, 2024).
• Mark Movsesian, Status, Conduct, Belief, and Message, (Chicago-Kent Law Review (forthcoming 2025)).
• Abbe R. Gluck, The Mifepristone Case and the Legitimacy of the FDA, (Yale Law School, Public Law Research Paper (2023).

From SSRN (Non-U.S. Law):

• Dörthe Engelcke, Dominik Krell & Nadjma Yassari, Underage Marriage: Legal and Social Practice in Muslim Jurisdictions, (Arab Law Quarterly, Advance Articles, 2025).
• Darshan Datar, The Voice and Religious Freedom, (Australian Journal of Law and Religion. Volume 3, No. 1. Pp. 96-100 (2023)).
• Dashan Datar, Judicial Concept of Religion in India: An Analysis of the Relationship Between Religion and Culture in Indian Supreme Court Jurisprudence, (May 01, 2024).

From SmartCILP:

• Leah Calabro, A Decade of Impunity: Finding Justice for the Yazidi Women Victims of the Islamic State, 48 Fordham International Law Journal 1-52 (2024).

Tennessee Enacts Conscience Protections for Health Care Providers

On April 24, Tennessee Governor Bill Lee signed the Medical Ethics Defense Act, SB 955 (full text). The new law provides in part:

A healthcare provider must not be required to participate in or pay for a healthcare procedure, treatment, or service that violates the conscience of the healthcare provider....

[However, this] Does not permit a healthcare payer to decline payment for a healthcare procedure, treatment, or service it is contractually obligated to pay for under the terms of a contract with an insured party. 

 Any political subdivision ... shall not reprimand or sanction a healthcare provider, nor deny or revoke, or threaten to deny or revoke, a license, certification, or registration of a healthcare provider for engaging in speech, expression, or association that is protected from government interference by the First Amendment to the United States Constitution, unless the political subdivision demonstrates by clear and convincing evidence that the healthcare provider's speech, expression, or association was the direct cause of physical harm to a person with whom the healthcare provider had a practitioner-patient relationship within the three (3) years immediately preceding the incident of physical harm.

WBIR News reports on the new law.

New Website Catalogues Laws That Exclude Religious Organizations from Government Funding Opportunities

Earlier this month, Notre Dame Law School announced that it, along with two other organizations, has launched a new website which identifies state laws that exclude religious organizations from participating in a wide variety of social service, educational and cultural funding opportunities. The announcement says in part:

The new website provides a database highlighting state statutes and regulations that prohibit religious organizations from participating in public programs on equal footing with their secular counterparts. Although the database does not express a view on the ultimate constitutionality of any particular law, its authors hope that the repository may be the first step towards identifying—and finally changing—those that do violate First Amendment rights.

The website is available at this link: Religious Equality – Protecting Religious Organizations from Discrimination. The website is also now listed in the Religion Clause sidebar under "Resources". City Journal reports on the new website.

Muslim Woman Sues Over Violation of Her Religious Rights in Jail

The New York chapter of the Council on American-Islamic Relations yesterday announced the filing of a federal lawsuit by a Muslim woman who alleges violation of her free exercise rights by Orange County, New York sheriff officers and jail officials.  The complaint (full text) in Green v. Orange County, (SD NY, filed 4/24/2025), alleges in part:

On February 2, 2024, a group of predominantly male officers at the Orange County Sheriff’s Office forced Ms. Green to remove her hijab twice: first, for post-arrest processing photographs and second, for her jail identification card. 

6. They also prohibited Ms. Green from wearing her hijab for more than 12 hours as she awaited arraignment....

9.  While incarcerated in the Orange County Jail, officials required Ms. Green to carry and present her identification card with a photo of her uncovered without her hijab for several months—which, for Ms. Green, was akin to being naked. 

10. Orange County Jail officers also confiscated Ms. Green’s hijab and purposefully broke her misbahah, or prayer beads, during a targeted cell sweep in late August 2024....Without her hijab, Ms. Green was unable to pray for herself or her family, including her six daughters, her mother (who passed away in November 2024), and her sister (who had been recently diagnosed with a brain tumor)...

13. In addition ... Defendants have failed to accommodate Ms. Green’s dietary requirements as a Muslim, often leaving her no choice but to go without food for extended periods of time.....

Convicted Cardinal Claims Eligibility to Vote for New Pope

In the Vatican, an unusual legal dispute has surfaced over the eligibility of the former deputy Vatican Secretary of State, Cardinal Giovanni Angelo Becciu, to vote at the upcoming Conclave to select a new Pope.  Article 36 of Apostolic Constitution Universi Dominici Gregis on the Vacancy of the Apostolic See and the Election of the Roman Pontiff provides:

A Cardinal of Holy Roman Church ... has the right to elect the Pope, in accordance with the norm of No. 33 of the present Constitution....On the other hand, Cardinals who have been canonically deposed or who with the consent of the Roman Pontiff have renounced the cardinalate do not have this right....

According to the National Catholic Register yesterday: 

[Becciu] lost all cardinal privileges in September 2020 after Vatican prosecutors presented Pope Francis with findings from an investigation into alleged financial crimes. 

As a consequence, Pope Francis required him to resign ... his position at that time, and “the rights connected to the cardinalate.” He duly agreed to comply, retaining the title of cardinal while being stripped of the rights and privileges associated with the office.

...  In 2021, he became the first cardinal to ever be tried by the Vatican’s criminal court.

In 2023, the court convicted the cardinal of embezzlement, aggravated fraud, and abuse of office.... He has always maintained his innocence and is currently appealing against the conviction through the Vatican’s Court of Appeal, which began hearings last October but has yet to give a ruling. 

Pope Francis invited Cardinal Becciu to attend a consistory in August 2022, an invitation that was described as a “private act of pastoral mercy” but not a step toward his rehabilitation or reinstatement of his cardinalatial rights. 

But speaking Tuesday, Cardinal Becciu gave that 2022 invitation as a reason for his eligibility to vote, saying that it showed “the Pope recognized that my cardinal prerogatives remain intact.”

Indiana Enacts Parental Rights Law

On April 22, Indiana Governor Mike Braun signed Senate Bill 143 protecting Parental Rights. The new law (full text) provides in part:

... A governmental entity may not substantially burden a parent's fundamental right to direct the: (1) upbringing; (2) religious instruction; (3) education; or (4) health care; of the parent's child, unless the burden, as applied to the parent and the child, is required to advance a compelling governmental interest and is the least restrictive means of advancing the governmental interest.

... A governmental entity may not: (1) advise, direct, or coerce a child to withhold information from the child's parent; or (2) deny a child's parent access to information that: (A) is in the control of the governmental entity (B) is requested by the child's parent; and (C) relates to the child's health care or social, emotional, and behavioral well-being.

ADF issued a press release supporting the enactment of the new law.

DOJ Hosts First Meeting of Task Force to Eradicate Anti-Christian Bias

 A Department of Justice press release reports that yesterday the DOJ hosted the inaugural meeting of the Task Force to Eradicate Anti-Christian Bias.  The Task Force was created by an Executive Order of President Trump. Yesterday's press release described the Task Force meeting, saying in part:

The witnesses included:

Michael Farris: First Amendment Litigator and Founding President of Patrick Henry College. Farris spoke on behalf of Senior Pastor Gary Hamrick to discuss how Cornerstone Church was under investigation and charged by the Internal Revenue Service (IRS) for so-called Johnson Amendment violations....

Dr. Scott Hicks: Provost and Chief Academic Officer, Liberty University. Hicks described how Liberty University and Grand Canyon University were singled out by the Biden Administration for fines due to the schools’ Christian worldview.

Phil Mendes: Navy Seal. Mendes was relieved of duty during Biden Administration for not taking the COVID-19 vaccine due to religious exemption requests that were denied by the Department of Defense.

 “As shown by our victims’ stories today, Biden’s Department of Justice abused and targeted peaceful Christians while ignoring violent, anti-Christian offenses,” said Attorney General Pamela Bondi. “Thanks to President Trump, we have ended those abuses, and we will continue to work closely with every member of this Task Force to protect every American’s right to speak and worship freely.”

Additionally, members of the Task Force highlighted specific cases within their own agencies where the Biden Administration unfairly and harshly punished Christian Americans for their religious beliefs.

UPDATE: The DOJ has posted video of opening remarks at the meeting by Attorney General Bam Bondi and  Deputy Attorney General Todd Blanche.

Christian Foster Care Ministry Can Limit Hiring to Those of Its Own Faith

In Gracehaven, Inc. v. Montgomery County Department of Job and Family Services, (SD OH, April 21, 2025), an Oho federal district court issued a preliminary injunction restoring contracting and funding by the county to a Christian ministry that provides foster care services to girls who are victims of sex trafficking and abuse. The county had refused to renew its contract with Gracehaven because of the ministry's policy of hiring only employees that shared its religious faith.  The court said in part:

Gracehaven will likely succeed on the merits of its claim that Montgomery County’s actions violated the Free Exercise Clause because it excluded Gracehaven from an otherwise available public benefit based on Gracehaven’s choice to employ those who share the same faith....

“When otherwise eligible recipients are disqualified from a public benefit ‘solely because of their religious character,’” the Court must apply strict scrutiny to the reason the benefit was denied.

President Responds to Death of Pope Francis

President Trump issued a Proclamation (full text) yesterday ordering flags to be flown at half-staff on the day of the late Pope Francis' funeral. The President announced yesterday on Truth Social that he and the First Lady will attend the Pope's funeral in Rome.

Supreme Court Hears Arguments on Permissive Opt-Out of Children from Exposure To LGBTQ-Friendly Books

The U.S. Supreme Court this morning will hear oral arguments in Mahmoud v. Taylor. In the case, the U.S. 4th Circuit Court of Appeals affirmed a Maryland federal district court's denial of a preliminary injunction in a challenge to a school board's refusal to allow parents to opt their children out of exposure to a group of LGBTQ inclusive books. The parents contended that refusal to provide an opt out alternative violates their religious free exercise rights. (See prior posting). The SCOTUSblog case page has links to the numerous amicus briefs filed in the case as well as to other pleadings and relevant news coverage of the case.  Oral arguments will be streamed live here at 10:00 AM today. A transcript and audio recording of the arguments will be posted here by the Court later today. A SCOTUSblog article has further background on the case.

Religious Corporation Exemption to Maryland Anti-Discrimination Law Does Not Excuse LGBT Discrimination Against Data Analyst

In Doe v. Catholic Relief Services, (D MD, April 21, 2025), a Maryland federal district court held that the religious corporation exemption from the Maryland Fair Employment Practices Act does not apply to the termination of spousal health care benefits of the same-sex spouse of a data analyst and advisor working for Catholic Relief Services. The Maryland Supreme Court had previously held that "in order for the exemption to apply, the employee’s duties must directly further the core mission(s) – religious or secular, or both – of the religious entity." Finding the exemption inapplicable here, the court said in part:

... [T]he evidence preponderantly demonstrates that Doe’s ... duties and responsibilities were sufficiently apart from effectuating CRS goals (and core mission) such that his ... job activities and responsibilities were far attenuated from, and not reasonably capable of bringing about (or preventing effectuation of), CRS goals or missions.  Doe did not directly serve the poor and vulnerable overseas, solicit or secure funding for projects, or possess authority to determine how CRS would pursue its mission through its programs.  Nor did Doe manage or supervise any employee with such responsibilities.... The evidence is that from time to time, he may have been called upon to assist those who were responsible for undertaking actions that effect CRS’s goals; yet he was always one or more steps removed from taking action that effect CRS goals or that bear such responsibility. ...

Because the court concludes that none of Doe’s five full-time positions with CRS directly furthered a CRS mission, and that each of his positions was one or more steps removed from taking the actions that effect CRS goals, the court similarly concludes that CRS has not met its burden to show that MFEPA’s religious entity exemption applies here. ...

Assuming without deciding that CRS has made the threshold showing of a burden on its free exercise rights by operation of MFEPA,.., the court concludes that CRS fails to demonstrate that MFEPA is not neutral and generally applicable in its application to CRS here.

Parents Lack Standing to Challenge Law Barring Schools from Disclosing Child's Change of Name or Pronoun

In Chino Valley Unified School District v. Newsom, (ED CA, April 18, 2025), a California federal district court held that plaintiffs, parents of school children, lack standing to challenge a California law that prohibits public schools from requiring disclosure to parents, without their child's consent, of their child's change of name or gender pronoun at school. Plaintiffs are "devout Christians and believe that God created man and woman as distinct, immutable genders." They contend that the law violates their free exercise rights and their right to control the upbringing and medical care of their children.  The court said in part:

While the Court has no doubt as to the concern that Plaintiff Parents have toward the implementation of AB 1955, Plaintiff Parents have not shown that they have suffered or will imminently suffer any form of harm as a result the Act.  For example, Plaintiff Parents do not allege that their own child has gone or goes by a different name at school, that their children’s school has deprived the parents of relevant information about their child, or that this is something that is likely to happen in the future....

Supreme Court Hears Arguments Today on Mandated Insurance Coverage for Anti-HIV Drugs Over Religious Objections

The U.S. Supreme Court hears oral arguments this morning in Kennedy v. Braidwood Management, Inc. Plaintiffs in the case objected on religious grounds to providing their employees the U.S. Preventive Services Task Force's mandated insurance coverage for pre-exposure drugs that prevent the transmission of HIV. Plaintiffs contended that this coverage makes them complicit in facilitating homosexual behavior, drug use and sexual activity outside of marriage. In the case, the U.S. 5th Circuit Court of Appeals held that the structure of the U.S. Preventive Services Task Force violates the Appointments Clause of the U.S. Constitution. That is the issue before the Court today. Oral arguments will be streamed here at 10:00 AM. A transcript and audio recording of the arguments will be posted later today at this web page. See prior related posting.

UPDATE: Here is a link to the transcript and audio of the oral arguments. Vox reports on the oral arguments.

Recent Articles of Interest

From SSRN:

• R. Shawn Gunnarson, James Cleith Phillips & Christopher Bates, Religions Employment and the Tensions Between Liberty and Equality, (Brigham Young University (accepted forthcoming)).
•  Joel Alicea, Constitutional Theory at a Catholic University, (75 Cath. U. L. Rev. (forthcoming 2025)).
• Edward L. Rubin, The Biblical Concept of Mercy as a Pragmatic Decision Protocol, (Vanderbilt Law Research Paper No. 25-07 (2025).
• Irene-Marie Esser, Iain MacNeil & Catriona Cannon, The Legal Dimension of 'Corporate Purpose': A Study of Companies with a Religious Influence, (forthcoming: European Business Law Review).
• L. Ali Khan, The Ministry of Jesus: A Comparative Study of the Qur'an and New Testament, (March 30, 2025).
• Jay Wexler, The Endorsement Test’s Early Years, 1983-1985: Notes from the O’Connor Files, (Boston Univ. School of Law Research Paper No. 25-7 (2025)).
• Jill Wieber Lens, Stillbirth & the Law (Book Introduction), (March 25, 2025).
• B. Sullivan, The Myth of Legal Neutrality and Its Role in Undermining Abortion Rights in The United States, (McGill Undergraduate Law Review No. 10 (2025)).
• Mark David Hall, Ten Commandments in the Public Square and Public Schools, (William and Mary Bill of Rights Journal (forthcoming)).

From SSRN (Non-U.S. Law):

• Thomas Latendresse, Evaluating the Constitutionality of Bill 21 Amid Restricted Judicial Review, (McGill Undergraduate Law Review No. 10 (2025)).
• L. Ali Khan, Rigveda as a Proto-Islamic Scripture of the Indus Valley, (March 26, 2025). 
• Soliu Dagbo Abdulllahi, An Overview of Legal and Regulatory Framework for Islamic Finance in Nigeria, (March 18, 2025).
• Ashlynn Kendzior,  Remaining Barriers to Abortion Access in Post-Repeal Ireland, (15 Creighton Int'l. & Compar, L. J. (forthcoming 2025).

From SmartCILP:

• Nicole V. Godfrey, Group Prayer in Federal Prison, 103 Nebraska Law Review 19-44 (2024).
• Michael Allan Wolf, "Zoning" Matters: RLUIPA and the New Normal of Religious Discrimination, 61 San Diego Law Review 343-406 (2024).

"Religious" Belief Defined Broadly in Title VII Claim

Numerous cases challenging employers' refusal to grant exemptions to Covid vaccine mandates during the height of the Covid epidemic continue to wend their way through the courts. Here is the latest.

In Huber v. TIAA, (WD VA, April 17, 2025), a Virginia federal district court refused to dismiss a former employee's Title VII failure to accommodate claim and allowed the parties to move on to discovery.  The employer had refused to grant a religious accommodation, claiming that the employee's objections were secular, not religious.  According to the court:

... [Plaintiff] subscribes to “a faith based holistic healing process” promoted by the Optimum Health Institute in Southern California....  A page from the Optimum Health Institute’s website, which Huber attaches as an exhibit to the amended complaint, describes the Institute as “a healing ministry of the Free Sacred Trinity Church, which promotes healing through the use of non-medical, all-natural, holistic healing practices.”...

Shortly after Huber filed her amended complaint, the Fourth Circuit clarified that courts evaluating religious discrimination claims should not rigorously examine whether a plaintiff’s beliefs are “religious in nature.”...  It confirmed that courts should limit the inquiry to “whether ‘the beliefs professed . . . are, in the claimant’s own scheme of things, religious[.]’”...  An employee’s claim that her belief “is an essential part of a religious faith must be given great weight” in this analysis....

... [T]his court finds that Huber has plausibly alleged the beliefs she communicated to TIAA were “religious in nature.” Huber’s asserted faith, which “comes from the belief in a universal force and energy” and focuses on holistic healing ... is different than the biblical Christianity employees often invoke when seeking exemptions to COVID-19 vaccine requirements....  But Title VII protects nonconventional as well as conventional religious beliefs—courts “are not free to reject beliefs because they consider them ‘incomprehensible.’...

The amended complaint does not provide a clear or complete account of Huber’s conversation with the TIAA interviewer, and it is possible that later fact development will show she did not communicate an objection that was based on a sincerely held religious belief.  But the court finds that her allegations are sufficient to allow for discovery on this issue....

Catholic Employers Get Permanent Injunction Against EEOC

In Catholic Benefits Association v. Lucas, (D ND, April 25, 2025), a North Dakota federal district court converted a preliminary injunction granted last September to a Catholic diocese and a Catholic employers' organization (see prior posting) into a permanent injunction. At issue are rules and guidance documents issued under the Pregnant Workers' Fairness Act and Title VII of the Civil Rights Act.  The permanent injunction provides in part:

(1) The EEOC and its agents are permanently enjoined from interpreting or enforcing the Pregnant Workers Fairness Act and any implementing regulations ... against the Diocese of Bismarck and the CBA, including present and future members, in a manner that would require them to accommodate abortion or infertility treatments that are contrary to the Catholic faith, speak in favor of the same or refrain from speaking against the same.  

(2) The EEOC and its agents are permanently enjoined from interpreting or enforcing Title VII of the Civil Rights Act of 1964, any implementing regulations or guidances, including the Enforcement Guidance on Harassment in the Workplace, against the Diocese of Bismarck and the CBA, including present and future members, in a manner that would require them to speak or communicate in favor of abortion, fertility treatments, or gender transition when such is contrary to the Catholic faith; refrain from speaking or communicating against the same when such is contrary to the Catholic faith, use pronouns inconsistent with a person’s biological sex; or allow persons to use private spaces reserved for the opposite sex.

ABC News reports on the decision.

Appellate Court Upholds $1.2M Fine Against Church for Violating Covid Public Health Orders

In People of the State of California v. Calvary Chapel San Jose, (CA App., April 15, 2025), a California state appellate court affirmed the imposition of administrative fines totaling $1,228,700 on defendant church for violating Covid public health orders requiring face coverings and submission of a social distancing protocol. The court rejected Calvary Chapel's Free Exercise defense. The court said in part:

...  [T]he People have met their burden to establish as a matter of law that the face covering requirements set forth in the orders are neutral and of general applicability, and Calvary Chapel has failed to submit admissible evidence sufficient to create a triable issue of fact. 

First, the text of the revised risk reduction order and the safety measures order shows that these orders are neutral because they are not specifically directed at religious practice, do not discriminate on their face, and religious exercise is not the object of the orders....

Having reviewed the very limited exemptions that Calvary Chapel asserts show that the face covering requirements in public health orders are not of general applicability, we decide that Calvary Chapel has provided no evidence to create a triable question of fact regarding general applicability.

The court also rejected Calvary Chapel's due process claims and additionally held:

... [T]he undisputed facts show that Calvary Chapel’s level of culpability due to violating the public health orders requiring face coverings is high, and therefore the fines in the amount of $1,228,700 do not violate the excessive fines clause of the Eighth Amendment.

USCIS Is Screening Immigration Applicants for Antisemitic Activity

Last week (April 9), the Department of Homeland Security announced that it will begin screening the social media of aliens applying for immigration benefits to determine whether they have been engaged in antisemitic activity. A News Release (full text) posted by the U.S. Citizenship and Immigration Services reads in part:

Today U.S. Citizenship and Immigration Services (USCIS) will begin considering aliens’ antisemitic activity on social media and the physical harassment of Jewish individuals as grounds for denying immigration benefit requests. This will immediately affect aliens applying for lawful permanent resident status, foreign students and aliens affiliated with educational institutions linked to antisemitic activity.

... DHS will enforce all relevant immigration laws to the maximum degree, to protect the homeland from extremists and terrorist aliens, including those who support antisemitic terrorism, violent antisemitic ideologies and antisemitic terrorist organizations such as Hamas, Palestinian Islamic Jihad, Hezbollah, or Ansar Allah aka: “the Houthis.”

... USCIS will consider social media content that indicates an alien endorsing, espousing, promoting, or supporting antisemitic terrorism, antisemitic terrorist organizations, or other antisemitic activity as a negative factor in any USCIS discretionary analysis when adjudicating immigration benefit requests....