The Legal Obligations That Continue After Deportation

When the United States removes a person it was bound to protect, the law does not simply lose sight of him. Federal courts have ordered the government to bring back people it sent abroad without the process the law requires, and the government accepts that a person who wins a petition for review after removal can have his return facilitated. What those orders require, where their limits lie, and what the Supreme Court’s review of removal to third countries, and of the risk of onward refoulement, may decide.

On 30 October 2026 a federal judge in Minnesota ordered the government to bring back a man it had flown to the Central African Republic. Kenis Adalberto Lopez Gonzalez, a citizen of Nicaragua, had been granted withholding of removal under the Convention Against Torture in August 2024, and neither side appealed. (He had been removed to Nicaragua once before, in 2005, and DHS reinstated that order in 2022.) He was released on an order of supervision, complied with its conditions, and was arrested in Minnesota on 15 January 2026. After moving him between detention centers in Texas and Louisiana, ICE removed him in late August to Bangui, where, the court found from his unrebutted declaration, he lives in a guarded building and depends on the International Organization for Migration for food and water. The court held that he was likely to succeed on his claim that ICE had revoked his supervision without following its own regulations, and ordered the government to “arrange for and facilitate Lopez’s return to the United States from the Central African Republic by taking all reasonable steps within their control to do so,” to bear the cost, and to restore him to the conditions of his supervision. It also set out the steps, relying on a declaration the government had filed: named ICE officials “shall approve the request” for parole within five business days, embassy staff “shall issue the parole letter,” and “[t]he Port of Entry Chief shall permit Lopez’s entry into the United States.” (Lopez Gonzalez v. Mullin, No. 0:26-cv-04507 (D. Minn. Oct. 30, 2026), ECF No. 30, at 2 n.1, 28-29 & n.16.)

The government has appealed. It moved for an emergency stay on 3 November, arguing, according to Fox 9 and MPR News, that the order interferes with foreign policy and diplomatic negotiations and that the Supreme Court’s stay in the D.V.D. class action should control. The court said it would decide the motion on the papers, and it had not ruled by the time of the first joint status report on the steps toward his return, filed on 6 November. The Eighth Circuit docketed the appeal as No. 26-3276 on 4 November (docket, ECF Nos. 31, 35, 36, 38, 40). The order is preliminary, and its author was careful to say what it does not decide: “Nothing in this Order shall be construed to, and does not, adjudicate the validity of the IJ’s order for Lopez’s removal or withholding of removal or DHS’s policy of third-country removals.” (ECF No. 30, at 30.) The Coalition’s register entry sets the case out in full.

This last part of the series sets out what the case, and others like it, show about the obligations that remain once a person has left American territory. The answer is measured. Removal does not end the government’s legal responsibility for an unlawful act, and the courts have the means to require it to repair some of what it can. But those means are narrower than the obligation, and the questions that matter most, including responsibility for what another country does next, remain undecided in American law.

Return as a remedy: what the government accepts, and what it disputes

The common ground is narrower than it may appear. In Nken v. Holder the Supreme Court said that people who are removed while their cases continue, and who later prevail, “can be afforded effective relief by facilitation of their return, along with restoration of the immigration status they had upon removal.” 556 U.S. 418, 435 (2009). The government relies on that passage. In the Washington case discussed in Part 6, its lawyers wrote this month that procedures to facilitate return “do exist,” citing ICE’s directive on facilitating the return of certain lawfully removed people. But they cited them for a particular purpose: to argue that a person’s remedy runs through a petition for review in a court of appeals, and that “§ 1252(b)(9) eliminates this Court’s jurisdiction” over claims of that kind (Defendants’ Motion to Dissolve, Iranian American Legal Defense Fund v. Rubio, No. 1:26-cv-02375 (D.D.C. Nov. 4, 2026), filed under seal and unsealed on 5 November, ECF No. 51, at 6-8). The government accepts, in other words, that a person who prevails on a petition for review may have his return facilitated under its own directive; it disputes that district courts may order return outside that channel. The question is not whether return can ever be ordered. It is when, on what legal footing, by which court, and how far that court may go.

The Supreme Court addressed those questions in April 2025. The United States had removed Kilmar Armando Abrego Garcia to El Salvador although, as the Court recorded, it “acknowledges that Abrego Garcia was subject to a withholding order forbidding his removal to El Salvador, and that the removal to El Salvador was therefore illegal.” The district court had ordered the government to “facilitate and effectuate” his return. The Supreme Court held that the order “properly requires the Government to ‘facilitate’ Abrego Garcia’s release from custody in El Salvador and to ensure that his case is handled as it would have been had he not been improperly sent to El Salvador,” but that the intended scope of “effectuate” was unclear “and may exceed the District Court’s authority,” and it directed the lower court to clarify its order “with due regard for the deference owed to the Executive Branch in the conduct of foreign affairs.” Noem v. Abrego Garcia, 604 U.S. ___, 145 S. Ct. 1017, 1018 (2025). The order was made on the government’s acknowledgment that the removal was illegal, and later courts have read it with that in mind. In D.A. v. Noem the court in Washington observed that it “provided little reasoning or instruction regarding the district court’s jurisdiction,” and distinguished it because the government there did “not concede that Plaintiffs were improperly removed” (ECF No. 41, at 14-15). Mr Abrego Garcia was brought back to the United States and charged with human smuggling. In May 2026 a federal judge dismissed the charges as presumptively vindictive; the Justice Department said it would appeal, and officials have said that they intend to remove him to a third country, most recently Liberia (Associated Press, as published by PBS, May 22, 2026).

Both halves of that ruling matter. A court may require American officials to do what lies within their power to undo an unlawful removal, and to treat the person’s case as if it had not happened; it must also respect the executive’s conduct of foreign relations. The further limit, that a court may not direct a foreign government, has been drawn by the lower courts: “This court cannot order the U.S. government to order a foreign government to take any action” (D.A. v. Noem, ECF No. 41, at 15). Most later orders use Abrego Garcia’s language. The California order in Mr Osahon’s case, discussed in Part 4, states that “[n]othing in this Order requires Defendants to command or control a foreign sovereign” (Osahon v. Mullin, ECF No. 19, at 4 (C.D. Cal. Sept. 10, 2026)). The Minnesota order goes further. It speaks of “reasonable steps within their control,” but it also directs named officials to approve parole, which the statute leaves to the Secretary’s discretion “on a case-by-case basis for urgent humanitarian reasons or significant public benefit” (8 U.S.C. § 1182(d)(5)(A)), and to admit him; the Colorado order described below directs his transfer outright. Whether orders of that kind facilitate a return or effectuate one, in the Supreme Court’s terms, is a question the pending stay motion and appeal in Minnesota present.

The orders since

The orders that have followed rest on different legal grounds, and the differences matter.

• O.C.G., May 2025. A Guatemalan man granted withholding of removal to Guatemala was put on a bus to Mexico two days later, and Mexico sent him on to Guatemala. Finding a likely violation of due process, the district court in Massachusetts ordered the government “to take all immediate steps, including coordinating with Plaintiffs’ counsel, to facilitate the return of O.C.G. to the United States.” The government had opposed the motion; five days after the order it reported that a parole packet had been approved, and he was returned. (D.V.D. v. U.S. Dep’t of Homeland Sec., 784 F. Supp. 3d 401, 412 (D. Mass. 2025); register entry.)
• Mr Osahon, September 2026. A Nigerian man protected by deferral was flown to Ghana and taken toward Nigeria. The court in California found a likely violation of the rules on revoking supervision and terminating deferral, and of due process, and ordered the government to facilitate his return. Its first order had not been followed, the court found (ECF No. 19, at 3). Under its later orders the government arranged his return, and his counsel told the court on 15 October 2026 that he was back in Los Angeles; a hearing on whether the government should be held in civil contempt in connection with the terms of his return is set for 4 December 2026. (Osahon v. Mullin, No. 2:26-cv-09121 (C.D. Cal.), ECF Nos. 19, 70, 73, 75; Part 4.)
• Brayan Omar Sanchez Servellon, September 2026. A Honduran man protected under the Convention as to Honduras was removed to the Central African Republic after filing a habeas petition on his own. Quoting an earlier decision of the same court, which drew on a 2025 order in the D.V.D. litigation describing the preliminary injunction the Supreme Court stayed in June 2025, the court in Colorado held that removals to third countries “must be preceded by written notice to both the non-citizen and the non-citizen’s counsel in a language the non-citizen can understand,” found that he had been given none, ordered the government “to transfer Petitioner from Central African Republic back to the District of Colorado,” and barred his re-detention unless the government first justifies it at a bond hearing. The judgment in D.V.D. was stayed eleven days later. The government has asked the court to reconsider, and his return has not been reported. (Sanchez Servellon v. Baltazar, No. 1:26-cv-02908 (D. Colo. Sept. 18, 2026), ECF No. 30, at 3-4 (quoting Pacheco v. Baltazar, No. 26-cv-01176 (D. Colo. May 5, 2026)); register entry.)
• A.M.A.S., October 2026. An Egyptian man holding deferral of removal to Egypt was removed to Equatorial Guinea, where, the court recorded, it is unrebutted that he has been “held under armed guard; threatened at gunpoint; and arrested, beaten, and held incommunicado by Equatorial Guinean authorities.” The court in Arizona held that his removal “without notice and a meaningful opportunity to raise a country-specific claim against removal there violated the Due Process Clause of the Fifth Amendment.” In words taken from Abrego Garcia, it ordered the government to facilitate his release and return and to “ensure his case is handled as it would have been had he not been improperly sent to Equatorial Guinea,” adding that “[n]othing in this Order directs the manner in which Defendants conduct diplomatic relations with Equatorial Guinea or directs any act by the Government of Equatorial Guinea.” It declined to treat ICE’s directive “as the measure of Defendants’ obligation.” (A.M.A.S. v. Mullin, No. 2:26-cv-06601 (D. Ariz. Oct. 6, 2026), ECF No. 14, at 1, 13, 18 n.3, 20-21.) His return has not been reported; an ICE declaration of 22 October said that the agency had not yet been able to verify where he was (ECF No. 24-1).
• Mr Lopez Gonzalez, October 2026. As above, on the ground that ICE revoked his supervision without the reasons and the interview its regulations require.

None of these orders holds the United States liable for what another country did after the transfer. They rest on what American officials did before it: removing people without the notice due process requires, or revoking their release without following the regulations. Those regulations are specific. When ICE revokes release under the regulation that governs people freed because their removal was not foreseeable, on either of the grounds it allows, the person “will be notified of the reasons for revocation” and given “an initial informal interview promptly” to answer them (8 C.F.R. § 241.13(i)(3)). The Tenth Circuit held in October that a man released under that regulation and later re-detained was entitled to the prompt informal interview it promises, and that denying it violated due process (Abedi v. Carter, No. 25-3179 (10th Cir. Oct. 21, 2026)), as the Coalition’s report on the case explains. In Minnesota, the court found that the government had “offered no reasons at all for detaining Lopez, whether in a notice to him or in written submissions in this action” (ECF No. 30, at 23).

What gives these orders their force is a simple proposition: completing the removal does not extinguish the wrong. The government argued in Minnesota that the questions about the revocation of supervision were moot once Mr Lopez Gonzalez had been removed. The court disagreed: “Nor is there any legal authority suggesting that a deportation cures a wrongful detention.” (ECF No. 30, at 25.) The point is less settled than that sentence suggests. The Ninth Circuit has held that removal moots a habeas petition that challenges only the length of detention (Abdala v. INS, 488 F.3d 1061, 1062 (9th Cir. 2007)), and the Eighth Circuit, sitting en banc, held a detention challenge “prudentially moot” after the person’s release, citing among other things “our inability to provide an effective remedy at this time” (Ali v. Cangemi, 419 F.3d 722, 724 (8th Cir. 2005) (en banc)). The orders discussed here proceeded as civil actions on claims about the revocation itself, and whether that distinction holds is open on appeal. The Minnesota court added that the government’s arguments, if correct, “would result in the creation of an unreviewable circumvention of legal procedures, as nothing prevents the Central African Republic from removing Lopez to Nicaragua” (at 20 n.7). The State Department had confirmed that it had received assurances from the Central African Republic that people removed there “will not be persecuted or tortured,” and had “determined those assurances to be credible and reliable” (at 11); the assurances extend to any country “to which CAR may further transfer the third-country nationals” (at 14). The court found that “the evidence presented includes no indication that any diplomatic assurances related specifically to the grave dangers known to the Department of State,” dangers it took from the Department’s own reports on crime and insecurity in the country (at 18-19).

The limits of what courts have held

The other side of the record deserves equal attention, because it is substantial. The immigration statute provides that “no court shall have jurisdiction to hear any cause or claim by or on behalf of any alien arising from the decision or action by the Attorney General to commence proceedings, adjudicate cases, or execute removal orders against any alien” (8 U.S.C. § 1252(g)), and it bars lower courts from enjoining the operation of the removal provisions except as to an individual (§ 1252(f)(1)). Courts have given those provisions real effect in cases about removal to third countries. In a published order of 10 October 2026 the Fifth Circuit treated a request to stay such a removal as falling within section 1252(g) and concluded, “we lack the power to entertain Gakou’s motion,” adding that the Supreme Court “has effectively ratified third-country removal of the sort that Gakou faces” (Gakou v. Warden, No. 26-10925 (5th Cir. Oct. 10, 2026)). The Sixth Circuit refused a stay to a member of the D.V.D. class on the ground that her claims were “squarely controlled” by the Supreme Court’s stays, and credited Ghana’s assurances to the State Department in doing so (Ojukwu v. Lyons, No. 26-3891 (6th Cir. Oct. 9, 2026)). A district court in Michigan held that “[p]rocedural challenges to a final order of removal are challenges to the Attorney General’s decision to execute orders of removal and such challenges are within the scope of the jurisdictional bar of § 1252(g)” (Rascol v. Raycraft, No. 2:26-cv-13534 (E.D. Mich. Oct. 2, 2026), at 14), and courts in Kansas and Louisiana reached similar results in Agowanji v. Mackey (D. Kan. Sept. 23, 2026), Kien Mbah v. Warden (W.D. La. Sept. 25, 2026) and Emetazi v. Warden (W.D. La. Oct. 16, 2026), although the Western District of Louisiana later granted Mr Agowanji a fourteen-day restraining order after his case was transferred there, as the Coalition’s survey of the case law records. The courts of appeals are also divided on removals already carried out. The Eighth Circuit, which will hear the Minnesota appeal, applied section 1252(g) to claims arising from a removal carried out in violation of a stay (Silva v. United States, 866 F.3d 938, 940 (8th Cir. 2017)); the Ninth Circuit has held that section 1252(g) did not bar such a claim (Arce v. United States, 899 F.3d 796, 800-01 (9th Cir. 2018)), and the Arizona court followed it (A.M.A.S., at 10). The government relies on Silva before the Supreme Court (Brief for the Petitioners at 17).

And when the person is already in the hands of another government, the courts’ reach shortens further. In D.A. v. Noem, the case about the first flight to Ghana, the court concluded that it “cannot order the U.S. government to order a foreign government to take any action,” although it found facts suggesting that the arrangement “may have been designed to evade Defendants’ obligations to Plaintiffs” (ECF No. 41, at 15). The government makes the same points in defending its guidance on removals to third countries: that removal decisions belong to the executive, that the statute channels review into individual proceedings, and that courts must not intrude on relations with other sovereigns. In individual cases it has added that the orders requiring return involved conceded errors, and that a court should not order return “before there has been any finding that the alien’s removal was unlawful” (as described in A.M.A.S., at 17). Those are serious arguments, and some courts have accepted them.

The two lines of authority can be partly reconciled. The orders granting relief address American officials and the lawfulness of American acts: a detention, a revocation, a removal without notice. Many of the decisions denying relief address attempts to stop a removal in progress, or to reach the conduct of a foreign government. Not all of them do: Silva applied section 1252(g) to a removal already carried out. And the Minnesota order rests on the supervision claims alone, the court having made no finding on the others (ECF No. 30, at 25-26 n.13); it treated section 1252(g) as not raised against those claims (at 21-22 n.8), and the government may press the point on appeal, since a limit on jurisdiction is not lost by failing to argue it. In the Coalition’s view, a remedy that asks officials to take steps within their own control to repair their own unlawful act sits on the firmer side of the line. Whether a given order stays on that side is for the courts of appeals.

International law: continuing responsibility

International law speaks more directly to the questions this series has examined. Article 3 of the Convention Against Torture forbids a State to “expel, return (refouler) or extradite a person to another State where there are substantial grounds for believing that he would be in danger of being subjected to torture,” and admits no exception. The Committee Against Torture reads it to forbid deportation to a 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); its general comments guide the reading of the Convention but do not bind States as the treaty does. The general law of State responsibility adds that a responsible State “is under an obligation to make full reparation for the injury caused by the internationally wrongful act” (art. 31), that reparation takes the form of “restitution, compensation and satisfaction” (art. 34), and that restitution means “to re-establish the situation which existed before the wrongful act was committed,” so far as that is not materially impossible or out of all proportion (art. 35) (ILC Articles on State Responsibility). Those articles describe what a State owes to other States, and leave aside rights that may accrue directly to individuals (art. 33(2)); applied to a person removed in breach of a protection obligation they are an analogy, though a close one. Facilitating that person’s return is restitution in its plainest form.

Those sources do not bind American courts in the way a statute does, and the United States applies its own standard of proof. But they show why the domestic remedy of return is not an anomaly. It is the ordinary consequence, in any legal order, of an act that should not have happened.

What the Supreme Court will and will not decide

On 29 September 2026 the Supreme Court stayed the district court’s order and judgment of 25 February 2026 in the D.V.D. class action, treated the government’s application as a petition for certiorari, granted it, and directed the parties to brief four questions: whether the district court had jurisdiction; whether it could enter classwide declaratory relief and vacatur under section 1252(f)(1); “[w]hether the Government’s Guidance on third-country removals is unlawful under 8 U. S. C. §1231(b), the Due Process Clause, or FARRA/CAT and its implementing regulations”; and “[s]uch other questions that the Government determines are appropriate for the proper disposition of the case.” Three Justices would have denied the stay. Argument is set for 9 December 2026. (Dep’t of Homeland Sec. v. D.V.D., No. 26-426.) The government’s brief defends the guidance as a response to cases in which the United States “is often unable to remove aliens to their home countries,” and as a policy that “fixes those longstanding failures, while also accounting for our humanitarian obligations” (Brief for the Petitioners at 2-3). Its first argument is jurisdictional: “A claim about where an alien will be removed is, ipso facto, a ‘claim’ ‘arising from the decision or action’ to ‘execute [a] removal order[].’” (Id. at 16.)

The Court’s answer will shape the notice and process due before a removal to a third country, and with it the protection against onward refoulement. A ruling on jurisdiction could also decide whether district courts may hear individual suits for return at all. The government told the Court, in seeking the stay, that the class “note[s] instances of chain refoulement, but neither their merits claims nor the judgment below is based on that concern” (reply, No. 26A406, at 18). How far the decision will reach the question of onward removal, and the remedy for a person already sent abroad, is not yet known.

What continuing responsibility requires

In the Coalition’s reading, the record supports five propositions about what remains owed after a removal. None depends on a finding that any official acted in bad faith.

First, the government should know where the people it removed under protection are, and what has happened to them, at least until the risk that the protection addressed has passed. Second, the records that would show whether onward removal was foreseeable, the manifests, the assurances, the communications with the governments concerned, should be kept and, where a court asks for them, produced. Third, when a court has found a removal unlawful, or likely so, return should be facilitated promptly, using the procedures the government’s own directive describes, as it was for O.C.G. and Mr Osahon; the same course would be warranted where the government itself concludes that a removal went wrong, without waiting for an order. Fourth, a person returned should be restored to the position he or she held before, as the Supreme Court said of Mr Abrego Garcia’s case, and should not be removed again without the process that was missing the first time. His own case shows that return does not end the dispute. Fifth, where the government has itself accepted that an arrangement is not being honoured, as it did in D.A. v. Noem, when it agreed that “it appears Ghana is violating the assurances it provided to the United States” (ECF No. 41, at 3), continued reliance on that arrangement calls for an explanation that the public record does not yet contain. Other courts have credited the same assurances, the Sixth Circuit among them.

The series in summary

The seven parts of this series have examined one program from several sides. Part 1 explained that a criminal conviction may bar asylum and withholding but does not end protection against torture. Part 2 explained that Nasrallah v. Barr settles the premise that removal to another country is possible, but not the procedures that must come with it. Part 3 examined the detainee locator policy and why notice and access to counsel are the conditions on which every other safeguard depends. Part 4 followed the people sent to Ghana and onward. Part 5 examined the payments to other governments and the safeguards that should come with them. Part 6 examined removals of Iranian nationals and the confidentiality of protection claims. This part has set out what remains owed after the aircraft has gone.

The common thread is not that every removal to a third country is unlawful, or that each ends in refoulement. Many are lawful, and the law permits them. It is that a final order of removal answers one question, whether a person may be removed, and leaves others open: where, by what route, on whose assurance, with what notice, and with what remedy if it goes wrong. Each of those questions has an answer in American or international law, and none is answered by the fact that a plane has landed somewhere else.

Conclusion: the law does not end at the border

The United States has broad authority to enforce its immigration laws, and it is entitled to use it. It is also bound by the protections Congress enacted and the treaty it ratified. A person outside the United States holds no rights under the Constitution, as the Supreme Court has said (Agency for Int’l Dev. v. Alliance for Open Soc’y Int’l, Inc., 591 U.S. 430, 436 (2020)), but obligations breached before the person left do not lapse when the aircraft crosses the border. The courts that have ordered return have framed their orders with care and with respect for the executive’s conduct of foreign affairs, and in two of the cases described here, O.C.G.’s and Mr Osahon’s, the person has been brought back. That record shows that repair is possible.

The officials who arrange these transfers are best placed to make repair unnecessary. They know who holds protection, and they are best placed to know how each arrangement has worked and what the people sent abroad have reported. In the Coalition’s view, that knowledge is best used before removal, and where a removal has gone wrong, the remedy the government’s own directive describes should not wait for a court to require it.

Authorities and references

• Supreme Court: Noem v. Abrego Garcia, 604 U.S. ___, 145 S. Ct. 1017 (2025) (order); Nken v. Holder, 556 U.S. 418 (2009) (opinion); Agency for Int’l Dev. v. Alliance for Open Soc’y Int’l, Inc., 591 U.S. 430 (2020) (opinion); Dep’t of Homeland Sec. v. D.V.D., No. 26-426, order of Sept. 29, 2026 (docket), and Brief for the Petitioners (Oct. 23, 2026), at 2-3, 16-17 (brief); Reply in Support of Application for Stay, No. 26A406, at 18 (Coalition copy).
• Courts of appeals: Gakou v. Warden of the Prairieland Detention Ctr., No. 26-10925 (5th Cir. Oct. 10, 2026) (order); Ojukwu v. Lyons, No. 26-3891 (6th Cir. Oct. 9, 2026) (order); Abedi v. Carter, No. 25-3179 (10th Cir. Oct. 21, 2026) (opinion; register entry); Silva v. United States, 866 F.3d 938 (8th Cir. 2017) (opinion); Arce v. United States, 899 F.3d 796 (9th Cir. 2018); Abdala v. INS, 488 F.3d 1061 (9th Cir. 2007) (opinion); Ali v. Cangemi, 419 F.3d 722 (8th Cir. 2005) (en banc) (opinion).
• District courts: Lopez Gonzalez v. Mullin, No. 0:26-cv-04507 (D. Minn. Oct. 30, 2026), ECF No. 30 (order; docket, including ECF Nos. 21, 31, 35, 40), appeal docketed, No. 26-3276 (8th Cir. Nov. 4, 2026); A.M.A.S. v. Mullin, No. 2:26-cv-06601 (D. Ariz. Oct. 6, 2026), ECF No. 14, and Declaration of Oct. 22, 2026, ECF No. 24-1 (order); Sanchez Servellon v. Baltazar, No. 1:26-cv-02908 (D. Colo. Sept. 18, 2026), ECF No. 30 (order); Osahon v. Mullin, No. 2:26-cv-09121 (C.D. Cal. Sept. 10, 2026), ECF No. 19 (order); D.V.D. v. U.S. Dep’t of Homeland Sec., 784 F. Supp. 3d 401, 412 (D. Mass. 2025) (order); D.A. v. Noem, No. 1:25-cv-03135 (D.D.C. Sept. 15, 2025), ECF No. 41 (opinion); Rascol v. Raycraft, No. 2:26-cv-13534 (E.D. Mich. Oct. 2, 2026), ECF No. 11 (order); Agowanji v. Mackey (D. Kan. Sept. 23, 2026; W.D. La. Oct. 7, 2026), Kien Mbah v. Warden (W.D. La. Sept. 25, 2026) and Emetazi v. Warden (W.D. La. Oct. 16, 2026), as collected in the Coalition’s survey; Iranian American Legal Defense Fund v. Rubio, No. 1:26-cv-02375 (D.D.C.), Defendants’ Motion to Dissolve (Nov. 4, 2026; filed under seal, unsealed Nov. 5, 2026), ECF No. 51 (motion).
• Statutes and regulations: 8 U.S.C. § 1182(d)(5)(A) (U.S. Code); 8 U.S.C. § 1252(f)(1), (g) (U.S. Code); 8 C.F.R. § 241.13(i) (eCFR).
• International law: Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment art. 3, Dec. 10, 1984, 1465 U.N.T.S. 85 (text); Comm. Against Torture, General Comment No. 4 (2017), ¶ 12, U.N. Doc. CAT/C/GC/4 (UN document); Int’l Law Comm’n, Articles on Responsibility of States for Internationally Wrongful Acts arts. 31, 33-35 (2001) (text).
• Reporting: Fox 9, “Minnesota immigrant stranded in Central African Republic as feds fight return” (Nov. 5, 2026) (report); MPR News, “Nicaragua man deported to Africa awaits return to Minnesota, amid legal battle” (Nov. 6, 2026) (report); Associated Press, “Federal judge dismisses human smuggling charges against Kilmar Abrego Garcia” (May 22, 2026), as published by PBS (report).
• On this site: Lopez Gonzalez v. Mullin, Sanchez Servellon v. Baltazar, the O.C.G. return order, the O.C.G. report, What United States Courts Have Held on Removal to a Third Country, and What They Have Not, Abedi v. Carter, the Coalition’s commentary of 26 October 2026, and Parts 1, 2, 3, 4, 5 and 6 of this series.