Iranian Nationals and the Risk of Return to Torture

Since September 2025 the United States has returned more than a hundred Iranians to Iran, and it has sent others, among them people its own judges protected against return there, to the Central African Republic. In October its lawyers told a federal court that further removals to Iran were planned, by way of a third country. What the record shows, what the law requires of each route, and why the confidentiality of a protection claim is part of the protection itself.

On 15 October 2026, at a hearing in Washington in a case about the handling of Iranian asylum seekers’ files, government counsel returned to a question the court had asked in August: whether any removals to Iran were planned. He answered in a closed session, held under seal and without the plaintiff’s lawyers; its transcript has since been unsealed. “The answer in August was no,” he said. “Today that answer has changed and it is yes.” He described the route: the United States would “facilitate the travel to the third country,” and the Government of Iran would arrange the journey from there into Iran. “It’s going to be through a third country,” he said, “but it’s not a third-country removal, it is still a removal to Iran.” Asked whether the United States was going to remove people in its custody “to a country with which we are at war,” he said that plans were in the works but that “nothing has been finalized yet. There’s no specific date.” When the judge then put it to him that the people sent back would face what anyone would recognize as “a serious threat of certain death,” he answered, “Yes, Your Honor,” and went on: “the government is executing lawful orders of removal.” (Transcript of Oct. 15, 2026, at 8:18-11:4.) When the open hearing resumed, the plaintiff’s counsel objected on the record that they “had no notice” of the closed session (at 22:2-4).

Judge Ana C. Reyes entered a written order the same day. It requires the government to notify the court within 24 hours of the finalization of any plan to remove Iranians to Iran, “including any plan to remove Iranians present in the United States to third countries where Iran, or any official acting on behalf of Iran, will later coordinate the individuals’ travel to Iran,” and to give five business days’ written notice before any such removal. The order adds: “This order should be read broadly to include any removal of Iranians present in the United States that could result in those individuals being sent to Iran.” (Order of Oct. 15, 2026, ECF No. 45.) A week later the government told the court that ICE had “finalized a plan to remove certain Iranian nationals subject to a final order of removal” (ECF No. 47). On 4 November it moved to dissolve the notice order. The same day it withdrew its request that any part of the transcript stay sealed. Public release of specific removal plans, it said, “could jeopardize operational security,” but its review of the transcript “reveals that no such operational details were discussed”; it did not object to unsealing the related filings, and asked only that a notice it had filed on 3 November, which “contains operational specifics,” remain sealed (ECF No. 52, at 1-2). On 5 November the court unsealed the order, the motion and the transcript. The legal organization that brought the case told the Associated Press that at least a dozen detained Iranians had been told in the preceding week of a coming flight to Iran through Pakistan. As of 8 November 2026 the Coalition has found no report that the flight has taken place.

This part does not argue that Iranian nationality entitles anyone to remain in the United States. It does not. It sets out what the record shows about the removals of Iranians since 2025, what American law requires before a person is sent toward Iran by any route, and the part that confidentiality plays in that protection. Part 1 explained why a criminal conviction does not end protection against torture; Part 2 explained that a final order of removal settles whether a person may be removed, not where.

Three flights, and the channel that arranged them

On 20 August 2026 the Associated Press reported that hundreds of emails obtained by the National Iranian American Council showed how the United States and Iran “worked together to arrange for more than 100 Iranians to be flown back to Iran on three separate immigration flights in September and December 2025 and January 2026.” The emails, the report said, show that Iranian officials “had some influence over which Iranian immigrants in the U.S. were sent back to their home country,” although requests Iran was still making on the day the first flight left were, one official wrote, denied. “Per request from the Iran Embassy I added a few cases,” one ICE official wrote in August 2025. Messages were sometimes passed through Qatari officials, who helped charter flights through Doha. The report was careful about what the emails did not show: “It is not clear whether the people Iran put on the list had volunteered to repatriate or if they were forced.” (Associated Press, as published by CP24.) The Coalition set out the emails and the litigation in its report of 5 November.

Twelve Democratic senators wrote to the Secretary of State on 11 February 2026 (JNS, Feb. 13, 2026). Citing press reports and Iranian American advocates, their letter states that “the administration sent 45 people to Tehran via Qatar in late September or early October,” that on 7 December 2025 it deported “approximately 50 Iranian citizens to Iran, this time through Kuwait,” and that on 25 January “yet another flight deported approximately 14 Iranians,” a number the senators said would have been higher but for a measles outbreak at the detention site and “widespread bipartisan pushback.” It records that some of those returned said they had been “made to fill out forms explaining why they had left Iran and sought asylum in America” and later “called in for interrogation by the intelligence wing of the Revolutionary Guards Corps.” (Letter of Feb. 11, 2026.) Those are accounts attributed to returnees, for which the letter cites The New York Times of 7 December 2025; they are not findings. According to the complaint in the Washington case, a State Department official replied on 27 February 2026 and referred the senators to the Department of Homeland Security and the White House (Complaint ¶ 48).

The government has given its own account of the third flight. The Department of Homeland Security said that three of the fourteen people aboard were former members of the Islamic Revolutionary Guard Corps, and the White House said that everyone removed had “Executable Final Orders, meaning a federal judge has ordered their removal from the United States.” (Fox News, Jan. 27, 2026.) Human Rights First, which tracked the flights, has said that those deported “have included Christian converts, ethnic minorities, and political dissidents” (statement of Oct. 29, 2026). Both accounts can be true at once. A flight may carry people whose removal raises no protection question and people whose removal raises a grave one; the law asks the question of each person, not of the flight.

Coordination of this kind is not in itself unlawful. As the Associated Press put it, “The U.S. government is allowed to work with government officials of foreign countries to coordinate deportation logistics. However, federal regulations passed in the late 1990s prohibit the government from sharing information that could reveal that the person getting deported applied for asylum.” That distinction, between arranging travel documents and disclosing a protection claim, runs through the rest of this part.

What the record shows about Iran

Iran is not a party to the Convention Against Torture and never signed it, so nothing here describes a breach of that treaty by Iran. It is bound by the International Covenant on Civil and Political Rights, whose article 7 prohibits torture in absolute terms, as the Coalition’s Iran guide explains. The record of what happens inside the country comes from inquiries and monitoring rather than judgments, and it is grave. The United Nations fact-finding mission on Iran found in 2024 that many of the violations it documented “amount to crimes against humanity, specifically those of murder, imprisonment, torture, rape and other forms of sexual violence, persecution, enforced disappearance and other inhumane acts, that have been committed as part of a widespread and systematic attack directed against a civilian population, namely women, girls and others expressing support for human rights” (A/HRC/55/67, ¶ 108). The State Department’s own human rights report on Iran for 2023 states that “use of physical and mental torture to coerce confessions was prevalent, especially during pretrial detention, including in cases of detained protesters” (Country Reports on Human Rights Practices for 2023, Iran). Human Rights Watch reported, in a dispatch of June 2026, that Iran’s authorities had executed at least 44 men since March on politically motivated charges, “at least two of whom were sentenced to death after returning from abroad” (Human Rights Watch, June 29, 2026).

None of this means that every Iranian would more likely than not be tortured on return, and American law does not assume it. An immigration judge must consider “all evidence relevant to the possibility of future torture,” including evidence of past torture and of “gross, flagrant or mass violations of human rights within the country of removal” (8 C.F.R. § 1208.16(c)(3)), and decide the claim of the person before the court. The accounts in the record suggest that the questions put to Iranians on return, why they left and whether they sought asylum, are the very questions on which the risk turns. That is why the confidentiality of a claim matters as much as its merits.

A route through a third country is still a route to Iran

The flights in this record have passed through third countries: Qatar and Kuwait, and, on the plan the legal organization described in November, Pakistan. Where the third country is a point of transit and Iran the destination, the removal is a removal to Iran, and government counsel described the October plan in exactly those terms: “it’s not a third-country removal, it is still a removal to Iran” (Tr. 9:11-14). The statute that implements withholding forbids removal “to a country” where the person’s life or freedom would be threatened (8 U.S.C. § 1231(b)(3)(A)), and Congress made it the policy of the United States not to “expel, extradite, or otherwise effect the involuntary return” of any person to a country where he or she would be in danger of torture, “regardless of whether the person is physically present in the United States” (Foreign Affairs Reform and Restructuring Act of 1998, § 2242(a)). A stop for fuel or a change of aircraft alters the route, not the destination.

The harder case is a removal to a third country that is not presented as a stop on the way to Iran. One sworn account in the federal record describes how quickly the distinction can collapse. An Iranian man granted withholding of removal to Iran in April 2025 was flown by ICE to Nicaragua on 16 October 2025. He states that a Nicaraguan immigration officer told him “that the Nicaraguan government had already agreed with the U.S. government that I would be sent to Nicaragua so that Nicaragua could send me back to Iran,” that he was flown on to Caracas, and that “[t]he Venezuelan officers put me on a Turkish Airlines flight to Tehran, Iran, with transit in Istanbul, Turkey.” His ticket from Caracas to Tehran, he states, had been issued on 15 October, while he was still in ICE custody. He left the airport in Istanbul. (Declaration, D.V.D. v. DHS, ECF No. 233-18, ¶¶ 15, 20, 22-24, Coalition copy.) Before he was removed he had been given an interview about his fear of Nicaragua, in which, he states, he was told that Nicaragua would not jeopardize its relationship with the United States by deporting him to Iran (¶¶ 7-8). The government’s Supreme Court filings do not address his account by name; its reply said that the class members “note instances of chain refoulement, but neither their merits claims nor the judgment below is based on that concern,” and that they “do not identify any case in which the additional procedures they and the district court seek to impose would have prevented the harms they recite” (reply, No. 26A406, at 18, Coalition copy). The Coalition’s Record sets out the account in full. The Coalition’s register records twelve matters, in nine cases, in which Iranian nationals have resisted removal on a variety of grounds; the Iran guide lists them.

The UN Committee Against Torture reads the Convention to forbid that sequence: a person at risk “should never be deported to another State from which the person may subsequently face deportation to a third State in which there are substantial grounds for believing that the person would be in danger of being subjected to torture” (General Comment No. 4, ¶ 12). That reading does not bind American courts, and the government reads the law differently. A federal regulation provides that nothing in the rules on withholding and deferral “shall prevent the Service from removing an alien to a third country other than the country to which removal has been withheld or deferred” (8 C.F.R. § 1208.16(f)), and the government has told the Supreme Court that where a third country has provided the requisite assurances, it “has necessarily made the substantive determination that the alien will not be persecuted or tortured in that country” (reply, No. 26A406, at 13-14). On 29 September 2026 the Supreme Court stayed the judgment that had set the government’s guidance aside and agreed to review it; argument is set for 9 December (docket, No. 26-426). Part 4 explained how far the lower courts have gone. For Iranian nationals the practical point is narrower. Where Iran is to coordinate a person’s onward travel, as government counsel described in October, arrival in Iran is not a risk to be estimated. It is the arrangement as described, and counsel himself called it a removal to Iran.

Not every Iranian facing removal holds protection, and for those who do not, the law permits removal to Iran. Their question is different: whether circumstances have changed since their cases were decided. The statute and the regulations lift the usual time limits on a motion to reopen that is “based on changed country conditions arising in the country of nationality,” if the evidence “is material and was not available and could not have been discovered or presented at the previous proceeding” (8 C.F.R. § 1003.23(b)(4)(i); see 8 U.S.C. § 1229a(c)(7)(C)(ii); 8 C.F.R. § 1003.2(c)(3)(ii)). Such a motion may be filed at any time, but filing it “shall not automatically stay the removal”; a stay must be asked for and granted. In practice, motions of this kind follow notice that removal is near. The legal organization told the Associated Press that the detainees had been contacted about the planned flight by the Iranian Interests Section, the office in Pakistan’s embassy in Washington that handles Iran’s consular affairs, that some had also been told by DHS officials, and that none had been given information in writing by immigration authorities. Part 3 explained why notice is the condition on which every other safeguard depends.

Confidentiality is part of the protection

Federal regulations forbid disclosure of information “contained in or pertaining to” an application for asylum, withholding of removal or protection under the Convention without the applicant’s written consent, subject to exceptions, and protect from disclosure other records that “indicate that a specific alien has applied” for any of them (8 C.F.R. § 208.6(a)-(b)). The rule on consular notification is more specific still: “When notifying consular or diplomatic officials, Service officers shall not reveal the fact that any detained alien has applied for asylum or withholding of removal.” (8 C.F.R. § 236.1(e).) That sentence names asylum and withholding of removal, not protection under the Convention, and Iran is not among the countries for which the same rule makes consular notification mandatory. The current text of § 208.6 also contains paragraphs, added in December 2020, under which protected information “may be disclosed” in several settings, among them “[a]s part of any proceeding arising under the immigration laws,” and the confidentiality provisions then “shall not apply” (§ 208.6(d)(1)(v), (d)(2)). A federal court enjoined the rule that added them on 8 January 2021, before it took effect (Pangea Legal Servs. v. U.S. Dep’t of Homeland Sec., 512 F. Supp. 3d 966 (N.D. Cal. 2021)); according to counsel in that case, the injunction remains in place, and the government, in ratifying the rule in October 2025, acknowledged that it cannot be implemented while the injunction stands. The decisions that follow were reached under the earlier text.

The government’s own long-standing interpretation, on which the Second Circuit relied, is that confidentiality is breached when protected information “is disclosed to a third party in violation of the regulations, and the unauthorized disclosure is of a nature that allows the third party to link the identity of the applicant to: (1) the fact that the applicant has applied for asylum; (2) specific facts or allegations pertaining to the individual asylum claim contained in an asylum application; or (3) facts or allegations that are sufficient to give rise to a reasonable inference that the applicant has applied for asylum.” Lin v. U.S. Dep’t of Justice, 459 F.3d 255, 263 (2d Cir. 2006) (quoting a USCIS fact sheet). The consequences are concrete. The Fourth Circuit, adopting the government’s own description, said that the regulations “safeguard information that, if disclosed publicly, could subject the claimant to retaliatory measures by government authorities or non-state actors in the event that the claimant is repatriated,” and held that “if an asylum applicant’s confidentiality has been breached in violation of § 208.6, the applicant must be given the opportunity to establish a new claim for asylum, withholding of removal, or relief under CAT based on the breach.” Anim v. Mukasey, 535 F.3d 243, 253 (4th Cir. 2008). The Fifth Circuit has joined them (Dayo v. Holder, 687 F.3d 653, 657 (5th Cir. 2012)). The same courts set the limits. The applicant “is entitled to relief for the confidentiality violation only if she succeeds on this new claim” (Anim, 535 F.3d at 253), and the breach must first be shown: the Eighth Circuit upheld a finding that there had been none, resting on the State Department’s confirmation that an embassy “did not identify the respondent as an asylum applicant,” and noted that the applicant bears the burden of establishing eligibility (Rafiyev v. Mukasey, 536 F.3d 853, 858 (8th Cir. 2008)).

Those principles meet the Iranian cases directly. In Iranian American Legal Defense Fund v. Rubio, filed on 7 July 2026, the plaintiff alleges that since March 2025 the government has followed a policy of providing Iran with confidential information from the immigration files of Iranians seeking asylum, and asks the court to require that people whose information was shared be told, so that they can move to reopen their cases (Complaint ¶¶ 1, 3). It also asks the court to vacate the alleged policy, to appoint a special master to review the files shared with Iran, and to bar the removal of any Iranian held by ICE until the special master’s work is done (Prayer for Relief ¶¶ c, d, f). The Department of Homeland Security has called the allegation that ICE shared asylum application records with Iran “FALSE,” and has said that ICE facilitates “consular access to detained individuals, in accordance with applicable laws, regulations, and agency policy” (Associated Press, as published by PBS).

The court has so far sided with the government on the question of policy. After hearing two officials at the evidentiary hearing of 15 October, Judge Reyes denied preliminary relief: “I don’t have any basis to find a likelihood of success on the claim. I find the two individuals who testified before me are relevant individuals, who would have knowledge of a policy if it existed. I find them to be entirely credible.” (Hearing transcript at 67, as quoted in the government’s motion to dissolve, ECF No. 51, at 3.) The same testimony also records a lapse, and its limits. One of the officials, Noah Adams, a deputy assistant director in ICE’s removal division, said that his investigation had found confidential information provided to Iran: in a travel document request sent to the Iranian Interests Section this year, there was “some information that wasn’t properly redacted,” an item on the charging document “related to a credible fear claim or something like that.” He had reviewed one request, chosen, he said, because “[i]t’s just what was available”; he described such errors as “generally a training issue”; there was no audit, he explained, “because there’s no central repository” of the requests; and he believed the request “had already gone out” (transcript of Oct. 15, 2026, at 27-50). The other official, Gerald Edwards, Jr., testified that “[w]e don’t disseminate that information, it’s protected” (at 56:22). The judge’s own assessment ran both ways. “[T]here may well have been a breach,” she said, “[b]ut that doesn’t mean that there was a policy” (at 64:20-22). She thought it “as equally likely, if not more likely,” that what had happened was the result of misredaction (at 63:21-23), and told the plaintiff, “I’m not sure how you would even survive summary judgment” (at 64:2-4). She has asked to see one official’s meeting notes in chambers, and the case continues.

The distinction the court drew matters, and it cuts both ways. Whether a policy exists decides the plaintiff’s claim under the Administrative Procedure Act. It does not decide whether a particular person’s information reached Iran. A disclosure need not be a policy to change the risk for the person disclosed, and the remedy three courts of appeals have recognized is individual: once a breach is shown, an opportunity, before removal, to show that it created a new danger. For an Iranian whose travel-document request disclosed protected information, that question should be answered before the flight, not after it.

The Central African Republic

Some Iranians have been sent not toward Iran but to a country with which they have no connection. Human Rights Watch reported that the eighteen people flown to Bangui on 12 June 2026 included people from Iran, “almost all of whom had US court-ordered protections against deportation to their countries of origin due to fears of persecution or torture,” and that this was the first time an African state participating in a United States third-country transfer agreement had accepted people from Iran and Afghanistan. Accounts of the Iranians on that flight differ, as the Coalition’s Central African Republic guide records. For the flight of late August, the plaintiff in the Washington case told the court that the United States planned to remove “at least eight Iranians to the Central African Republic (CAR),” that “[a]t least six of these individuals had been granted withholding of removal, preventing their removal to Iran,” and that six of the eight were removed while two were returned to detention (Notice of Factual Developments, ECF No. 36, ¶¶ 4-6). Other accounts of the same flight give different numbers of Iranians, and the guide sets the four accounts side by side. Third Country Deportation Watch lists Iranians among the nationalities of the 78 people sent on 23 October, without saying how many.

The understanding between the two governments, effective 4 April 2026, contains the assurance that people transferred “would not be subjected to persecution on account of race, religion, nationality, membership in a particular social group, or political opinion, or torture in the Central African Republic or in any country to which the Central African Republic may further transfer them.” It also provides that, with each flight manifest, the United States intends to give the Central African Republic “the names of the individuals on the manifest, their criminal history to the extent known to the Government of the United States of America, and the reason for their removal from the United States.” (Diplomatic notes of Mar. 26 and Apr. 4, 2026, Coalition copy.) The understanding does not say what, if anything, is to be shared about a person’s protection against return home, and what has been shared in practice is not public; the plaintiff in the Washington case has told the court that it “does not know what information the United States shared with Iran or CAR about these eight individuals.” No source the Coalition has found reports that any Iranian sent to the Central African Republic has been sent on to Iran, and the Coalition does not suggest otherwise.

The government’s position

The government’s case deserves to be stated in full. It holds that the notice order “operates as an injunction against Defendants given the possibility of sanctions and contempt dangling overhead,” and was entered without the findings an injunction requires; that the organization lacks standing; that 8 U.S.C. § 1252(g) deprives the court of jurisdiction over the execution of removal orders, that §§ 1252(a)(5) and 1252(b)(9) channel any challenge into petitions for review, and that § 1252(f)(1) bars restraint of removals beyond an individual case; that on the merits “[t]here is no policy for Plaintiff to challenge”; that an order requiring notice of plans coordinated with a foreign government intrudes on the conduct of foreign relations and exceeds the court’s jurisdiction; and that a person removed who later prevails on a petition for review can have his or her return facilitated. It relies on the Supreme Court’s statements that “[t]here is always a public interest in prompt execution of removal orders” and that people who prevail after removal “can be afforded effective relief by facilitation of their return.” (ECF No. 51, at 1-15 (quoting Nken v. Holder, 556 U.S. 418, 435-36 (2009)).) The statute implementing the Convention points the same way on jurisdiction: it gives no court power to review claims under the Convention “except as part of the review of a final order of removal” (Foreign Affairs Reform and Restructuring Act of 1998, § 2242(d)). The government filed the notice the order required (ECF No. 47) and a further notice under seal on 3 November. The plaintiff has asked for time to respond until 16 November.

Much of that is right as far as it goes. The executive branch conducts foreign relations. Final orders of removal are meant to be executed. The people on these flights include some whom the government regards as security risks, and the law gives such people no right to remain. Individual protection claims are decided in individual proceedings. But each of those propositions assumes that the individual proceedings are available in time. In the Coalition’s view, an order requiring the government to tell a court what it intends to do does not prevent it from doing anything lawful; the government contends that the order operates as an injunction, and the court has yet to rule. And a final order of removal resolves whether a person may be removed. It does not resolve whether he or she may be sent to Iran, by a direct flight or by way of Doha, Kuwait, Pakistan or Caracas, when an American judge has ruled that out.

What the law asks before an Iranian national is sent toward Iran

Four propositions follow from the record and the law, and none depends on a finding that any official acted in bad faith. First, a person who holds withholding of removal or deferral under the Convention as to Iran may not be sent to Iran by any route, and for such a person an arrangement under which Iran coordinates the onward journey from a third country is barred outright: in substance it is a removal to Iran, and refoulement by another route. Nothing in the record shows that the plan described in October includes anyone protected as to Iran; government counsel described “individuals who have final orders of removal” and said he did not know whether they had sought asylum (Tr. 9:22-10:2). Second, in the Coalition’s view, which matches the UN Committee’s reading, a removal to a genuinely safe third country remains lawful, but its safety has to be judged on what is known about where the person is likely to be sent next; the government’s position is that the third country’s assurances settle that question, and the lawfulness of the government’s guidance on such removals is now before the Supreme Court. Third, where a breach of confidentiality is shown, three courts of appeals have held that the person must have the chance to establish the new danger that the disclosure created. Fourth, an Iranian without protection whose case was decided before the strikes of June 2025 and the war that began at the end of February 2026 may ask, by a motion to reopen, whether changed conditions now warrant protection. Each of these depends on notice and time, and the information needed to answer them, the manifests, the travel-document requests, the communications with the Interests Section, is in the government’s hands.

Conclusion: the route does not change the destination

The United States has authority to remove Iranian nationals under final orders, and it has used that authority through channels that have reached Tehran by way of Doha and Kuwait and may soon do so by way of Pakistan. That authority is real. So are the limits on it. American judges have found that some Iranians in the United States would face persecution or torture in Iran; federal regulations protect from disclosure, outside stated exceptions, the fact that anyone has asked for protection; and three courts of appeals have held that a breach of that rule, once shown, may itself ground a new claim. None of those limits disappears because a flight stops somewhere else first.

The record so far gives no ground to say that every Iranian sent home was at risk, and the Coalition does not say so. It does show a channel through which travel-document requests pass, one of which was not properly redacted, and a stated plan to use a third country as the threshold of return. The officials who manage that channel are best placed to know which of the people on a manifest hold protection. The law requires that each person’s protection be respected whatever the route, and the time to apply that knowledge is before the flight, person by person.

Authorities and references

• Treaties and treaty bodies: Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment art. 3, Dec. 10, 1984, S. Treaty Doc. No. 100-20, 1465 U.N.T.S. 85 (UN Treaty Series text; status); International Covenant on Civil and Political Rights art. 7 (status); Comm. Against Torture, General Comment No. 4 (2017), ¶ 12, U.N. Doc. CAT/C/GC/4 (Sept. 4, 2018) (UN document).
• Statutes and regulations: 8 U.S.C. § 1231(b)(3)(A) and Foreign Affairs Reform and Restructuring Act of 1998, Pub. L. No. 105-277, div. G, § 2242(a), (d), 112 Stat. 2681-822 (note to 8 U.S.C. § 1231) (U.S. Code); 8 C.F.R. § 208.6, including paragraphs (d) and (e) added by 85 Fed. Reg. 80,274, 80,386 (Dec. 11, 2020) (eCFR); 8 C.F.R. § 236.1(e) (eCFR); 8 U.S.C. § 1229a(c)(7)(C)(ii) (U.S. Code); 8 C.F.R. § 1003.2(c)(3)(ii) (eCFR); 8 C.F.R. § 1003.23(b)(4)(i) (eCFR); 8 C.F.R. § 1208.16(c)(3), (f) (eCFR).
• Courts of appeals and district courts: Lin v. U.S. Dep’t of Justice, 459 F.3d 255 (2d Cir. 2006) (opinion); Anim v. Mukasey, 535 F.3d 243 (4th Cir. 2008) (opinion); Dayo v. Holder, 687 F.3d 653 (5th Cir. 2012) (opinion); Rafiyev v. Mukasey, 536 F.3d 853 (8th Cir. 2008) (opinion); Pangea Legal Servs. v. U.S. Dep’t of Homeland Sec., 512 F. Supp. 3d 966 (N.D. Cal. 2021) (counsel’s case page); Nken v. Holder, 556 U.S. 418 (2009) (opinion).
• Iranian American Legal Defense Fund v. Rubio, No. 1:26-cv-02375-ACR (D.D.C.): Complaint (July 7, 2026), ECF No. 1 (complaint); Notice of Factual Developments (Sept. 1, 2026), ECF No. 36 (notice); Order (Oct. 15, 2026), ECF No. 45 (order); Defendants’ Notice (Oct. 23, 2026), ECF No. 47 (notice); Defendants’ Motion to Dissolve (Nov. 4, 2026), ECF No. 51 (motion); Defendants’ Response to the Court’s Order (Nov. 4, 2026), ECF No. 52 (response); Plaintiff’s Unopposed Motion for Extension of Time (Nov. 6, 2026), ECF No. 54 (motion); Transcript of Proceedings (Oct. 15, 2026), ECF No. 53, with the sealed ex parte session at 8:19-21:11, unsealed Nov. 5, 2026, as published by the Associated Press (transcript); docket (CourtListener).
• D.V.D. v. U.S. Dep’t of Homeland Sec., No. 1:25-cv-10676 (D. Mass.), Declaration of Iranian class member (executed Nov. 28, 2025; filed Dec. 8, 2025), ECF No. 233-18 (Coalition copy); Reply in Support of Application for Stay, Dep’t of Homeland Sec. v. D.V.D., No. 26A406 (U.S.), at 13-14, 18 (Coalition copy).
• United Nations and United States reporting on Iran: Report of the Independent International Fact-Finding Mission on the Islamic Republic of Iran, ¶ 108, U.N. Doc. A/HRC/55/67 (Feb. 2, 2024) (UN document); U.S. Dep’t of State, Iran 2023 Human Rights Report (report); the complaint (¶ 36) cites the 2024 edition, which the Coalition has not quoted.
• Arrangements with other governments: Diplomatic notes between the United States and the Central African Republic (Mar. 26 and Apr. 4, 2026), State Department file 2026-0038QN; the United States note is dated March 26, 2025 on its face, while its number and the Central African Republic’s reply give 2026 (Coalition copy).
• Congress: Letter from Sen. Tim Kaine and eleven other senators to Secretary of State Marco Rubio (Feb. 11, 2026) (letter).
• Reporting and monitoring: Associated Press, Safiyah Riddle, “A quiet channel between ICE and Iran shaped deportation flights, newly released emails show” (Aug. 20, 2026), as published by CP24 (report); Associated Press, Safiyah Riddle, “Lawsuit says U.S. immigration agencies illegally shared confidential information on Iranian asylum seekers with Iran” (July 7, 2026), as published by PBS (report); Associated Press, Michael Kunzelman and Rebecca Santana, “Trump administration held talks with Iran on deporting Iranians during the war, court documents show” (Nov. 5, 2026), as published by PBS (report) and WKMG (report); ABC News, “Judge blasts administration for planning to deport Iranian immigrants back to Iran during wartime” (Nov. 5, 2026) (report); Fox News, Morgan Phillips, “US deports 3 former Iranian Guard members amid rising tensions with Tehran” (Jan. 27, 2026) (report); JNS, Mike Wagenheim, “Halt deportation flights to Iran, 12 Democratic senators tell Rubio” (Feb. 13, 2026) (report); Human Rights Watch, dispatch on the Central African Republic (June 29, 2026) (report); Human Rights First, statement of Oct. 29, 2026 (statement); Third Country Deportation Watch, Central African Republic (record).
• On this site: Iran, Emails Show ICE Worked With Iran on Three Deportation Flights, the register entry for Iranian American Legal Defense Fund v. Rubio, Central African Republic, The Record, Part 1, Part 2, Part 3, Part 4.