Liberia

The Coalition’s position. This state agreed to receive people who are not its nationals, moved against their will, under a programme United States federal courts have found punitive and whose purpose was stated publicly before the agreement was made. On the Coalition’s position it has knowingly facilitated that programme, and the wrong is complete at the moment of agreement. Nothing on this page is offered as mitigation. What a receiving state agrees to.

What has happened

Twenty people were flown to Monrovia on 20 August 2026. Six of them refused to leave the aircraft. They were flown on to Equatorial Guinea instead.

What the people being transferred understood about the destination is written in that refusal, and it is the only account of the arrangement that does not come from a government.

The refusal, and who they were.

The Associated Press reported: “Six people who were deported by the United States to Liberia last week resisted getting off the plane and instead were sent to Equatorial Guinea … The group who refused to get off the plane in Liberia on Thursday include four Cuban men, a Brazilian man, and a Cameroonian woman.”

AP, Dakar dateline, 24 August 2026. The American Prospect reports five rather than six, and dates the flight 19 August. Both stand; publish the conflict. Sources: AP, 24 August 2026 · The American Prospect, 31 August 2026

Liberia says the flight ran under the published agreement; a tracker reports a separate, undisclosed arrangement.

Third Country Deportation Watch reports a separate undisclosed arrangement with Liberia under which the August flight was carried out. That could not be corroborated, but a negative bears on it: a search of every State Department batch of qualifying non-binding instruments published from January 2025 through June 2026 found no Liberia entry at all. That is consistent either with no such instrument existing or with one that was never published.

The onward transfer is no longer an inference. On 8 September 2026 Reuters reported that five people the United States attempted to deport to Liberia resisted getting off the plane and were taken to Equatorial Guinea instead. Until that report the only account naming both countries was one this page could not reach, and the connection was left unstated. It is now stated. What happened to those people after they reached Malabo is recorded on the Equatorial Guinea page, and it includes armed police drawing weapons on them twice.

The arrangement, and what it cost

This agreement is binding, unlike most of the others, and its protection clause is narrower than it looks.

The instrument is in the Treaties and Other International Acts Series, TIAS 25-910, and carries the statutory note that TIAS texts “shall be competent evidence … in all the courts of law.” The operative clause: Sources: State Department text, TIAS 25-910 · Coalition copy (PDF)

“The Government of the Republic of Liberia agrees not to return any person transferred to Liberia by the Government of the United States of America to their home country or country of former habitual residence until a final decision has been made regarding any pending protection claims.” Sources: State Department text, TIAS 25-910 · Coalition copy (PDF)

Read it narrowly, because it will be read narrowly. It protects only while a claim is pending, and the agreement immediately provides that Liberia “shall determine a procedure … to resolve the status of those who may abandon pending claims or fail to seek protection.” It is not a general guarantee against refoulement.

State Department, TIAS 25-910, exchange of notes at Monrovia, entered into force 10 September 2025. Source: TIAS 25-910

The operating procedures that would say who may be transferred are not public.

The agreement provides that “The operating procedures shall be signed by both Parties before any transfers under the Agreement may begin.” Those procedures contain the actual screening and transfer criteria. They have never been published. Sources: State Department text, TIAS 25-910 · Coalition copy (PDF)

The two governments disagree about money.

Liberia’s Ministry of Information states: “The transfer of persons to Liberia is not a transaction with a quid pro quo. Liberia has not demanded or received any compensation or promise of reward in exchange for its consent.” Al Jazeera and Semafor, sourcing Reuters, report $5 million from the United States for “migration management activities”; Third Country Deportation Watch dates that commitment to December 2025. The agreement text disclaims any funding obligation. Sources: Liberia Ministry of Information, 18 August 2026 · Al Jazeera, 20 August 2026 · State Department text, TIAS 25-910

The $5 million figure is consistent across secondary sources; no US disbursement record was located.

What the record says about Liberia itself

Liberia has published almost nothing about the people it received.

Al Jazeera, 22 August 2026: the government “has not disclosed their full nationalities, where they are being housed, the legal documents under which they entered Liberia, or the identity of the international organisation paying for and managing their stay.” Source: Al Jazeera, 22 August 2026

Amnesty International has recorded the pattern the arrangement sits inside.

“after the conclusion of the respective third-country removals agreements, Liberia, Rwanda, and Uganda managed to secure US investments into their health sector under the US government’s America First Global Health Strategy.”

Amnesty International, oral statement to the African Commission, AFR 01/1031/2026, 12 May 2026. Source: Amnesty, AFR 01/1031/2026

The first days

Liberia has one thing no other country in this project has: a national mechanism against torture whose intended scope expressly includes immigration detention. It also does not yet exist. The Independent National Commission on Human Rights describes itself as the institution leading efforts toward establishing it, twenty-two years after Liberia accepted the obligation to have one.

There is no International Committee of the Red Cross presence in Liberia. Family links run through the national Red Cross society instead. There is no route by which an individual can complain to the United Nations Committee against Torture or to the African Court. The bar association publishes an emergency telephone line, which is the most immediately useful number on this page.

Who is reachable in Liberia

The United Nations refugee agency has an operational presence in Liberia, confirmed from its own data portal, but publishes no office address or telephone the Coalition could reach. That gap is recorded rather than filled from a directory. Source: UNHCR Operational Data Portal, Liberia

There is a court you can file in directly, and it is the strongest route in this project

This country is a member of the Economic Community of West African States, and the ECOWAS Community Court of Justice is open to individuals. Three features make it more useful than anything else available to a person transferred to any of the countries in this project.

You do not need permission from this country to use it.

Article 10 of the 2005 Supplementary Protocol gives access to “Individuals on application for relief for violation of their human rights”, subject only to two conditions: the application must not be anonymous, and the same matter must not already be before another international court. Source: ECOWAS Supplementary Protocol A/SP.1/01/05, articles 9 and 10

There is no equivalent of the declaration that closes the African Court. The African Court’s Protocol says at article 34(6) that it “shall not receive any petition” involving a state that has not made a special declaration, and this country has never made one. Seven African states have that declaration in force today, and the only one of them in this project is Ghana. The ECOWAS Protocol contains no such requirement at all. Access follows from this country’s membership of ECOWAS. Sources: Protocol establishing the African Court, article 34(6) (AU text) · AU status list, African Court Protocol

You do not have to go through the local courts first.

The Court has held this squarely:

“The rule of exhaustion of local remedies is not applicable before the Court.” Source: Koraou v Niger, ECW/CCJ/JUD/06/08, paragraph 49

“There is no requirement of the exhaustion of local remedies before accessing this Court.” Source: Federation of African Journalists v The Gambia, ECW/CCJ/JUD/04/18

For a person in detention with no lawyer and no status, that removes the obstacle that defeats most international claims.

It does not matter that you are not from here.

Article 10(d) says “Individuals” and attaches no nationality condition, and the Court has applied it that way. The applicant in Abbiusi v Ghana was a Belgian national who had lived in Ghana about five years. She answered an immigration summons on 4 December 2023, was detained, was charged two days later and was granted bail. On 19 December, the day the charges against her were withdrawn, immigration officers re-arrested her on the court premises without telling her why, took her to the National Investigations Bureau, held her more than twelve hours in an undisclosed place without access to her lawyer, and deported her. The Court declared that re-arrest and that detention arbitrary and in violation of article 6 of the African Charter, and ordered Ghana to pay her ten thousand United States dollars in cedis.

Read the rest of that judgment before relying on it. The Court upheld the first detention as lawful, finding it grounded in the Immigration Act and within the forty-eight hour limit in the Ghanaian Constitution. It rejected her claim that she had been held seven days by counting the days itself and finding two. And it dismissed her claims on fair hearing, freedom of movement, equality before the law and discrimination, for want of particulars and proof, saying that it “is not obliged to plead the case of a party”. She asked for one million dollars and recovered ten thousand. This is a court that decides against applicants on the parts they do not prove. Source: Abbiusi v Ghana, ECW/CCJ/JUD/41/24, paragraph 96

It did so here even though the state never defended the case. Ghana was served, its counsel appeared, but no defence was filed in time and its late response came without a reasoned application for extension, so the Court ruled the matter undefended and gave judgment by default. Even then it refused to enter judgment automatically, holding that it must reach “the same degree of certainty as in any other case” that the claim is sound in law and supported by convincing evidence. It also held that the burden of proving a detention lawful rests on the state, which is why the second detention failed: no reason was ever given for it, so the Court could not find a legal basis. Source: Abbiusi v Ghana, ECW/CCJ/JUD/41/24, paragraph 38

Here is the part that matters most for this page. Before any of that, the Court checked two things on its own motion. Jurisdiction, under article 9(4) of the Supplementary Protocol, which gives it power over human rights violations occurring in any member state. And admissibility under article 10(d), which it said has three requirements: the applicant’s status as a victim, an application that is not anonymous, and no same matter pending before another international court. Exhaustion of local remedies is not one of the three. The Court did not mention it, because it does not apply. That is the point on which this Court differs from every other forum in this project.

One caveat the Coalition will not bury. In dismissing the discrimination claim the Court said that a foreigner residing in Ghana is entitled to the human rights guarantees in the instruments Ghana has signed, “subject however to a possession of valid resident permit”. Taken at face value that condition would sit badly with people transferred here with no status at all, and it is in tension with rights the Charter grants to every individual. It was an aside in a claim the applicant lost on other grounds, not a holding, and the Coalition flags it because a state might one day quote it. Source: Abbiusi v Ghana, ECW/CCJ/JUD/41/24, paragraph 115

In Saab Moran v Cabo Verde, a judgment this Court relied on in Abbiusi, it found the detention of a Venezuelan national unlawful, ordered his release and quashed the extradition proceedings against him.

You must be the person harmed, or someone properly authorised by them. The Court has said it admits “only the victims”.

When to file: as early as you can.

This is the one part the Coalition cannot give a clean answer on, and it would be wrong to pretend otherwise. Article 9(3) of the Protocol says an action is “statute barred after three (3) years from the date when the right of action arose.” In 2018 the Court held that this does not apply to human rights claims against member states and overruled its earlier decisions. In October 2024, in a claim against Liberia, the Court rejected the time-bar objection, holding that “in matters of human rights violation, an Applicant cannot be barred by reason of effluxion of time”, and declined the case only because the events predated the Court’s existence and its human rights mandate. The Court has no appellate division to settle the conflict. Sources: ECOWAS Supplementary Protocol A/SP.1/01/05, articles 9 and 10 · Global Justice and Research Project v Liberia, ECW/CCJ/RUL/04/24, 17 October 2024

Do not rely on the 2018 position. File as early as possible.

What the judgment is worth, honestly.

Judgments are binding, and Article 24 of the Protocol provides for a writ of execution served on the member state and enforced under its own civil procedure. That is the law.

The practice is worse. The Court’s President, Justice Ricardo Cláudio Monteiro Gonçalves, told the inaugural meeting of Competent National Authorities in Lagos on 23 June 2025 that compliance “remains low and currently stands at about 22 per cent”. At the same meeting the Court’s Chief Registrar, Dr Yaouza Ouro-Sama, lamented, in Vanguard’s words, “the fact that the court was often viewed as a “toothless bulldog” due to its lack of enforcement power.” He was naming a perception he regrets rather than passing verdict on his own court, and the Coalition sets it out that way because the difference matters. In 2008 the Court ordered The Gambia to produce and release a detained journalist; he was never produced. In 2021 it ordered Cabo Verde to release a detained man and quashed the proceedings against him; four months later Cabo Verde flew him to the United States instead. Sources: Vanguard, 24 June 2025 · The Guardian Nigeria, 24 June 2025

A judgment from this Court is a real thing: it is binding, it is public, and it names what was done. It is not a guarantee of release.

Supplementary Protocol A/SP.1/01/05 of 19 January 2005 amending Protocol A/P.1/7/91, articles 9 and 10 as substituted, and article 24 as inserted. Hadijatou Mani Koraou v Republic of Niger, ECW/CCJ/JUD/06/08, 27 October 2008, at paragraph 49. Federation of African Journalists and 4 Others v Republic of The Gambia, ECW/CCJ/JUD/04/18, 13 February 2018. Shalimar Abbiusi v The Republic of Ghana, application ECW/CCJ/APP/03/24, judgment ECW/CCJ/JUD/41/24, 22 November 2024, judgment by default, read in full from the Court’s own published text, at paragraphs 2, 8, 19, 28, 31, 38, 55, 58, 67, 77 to 85, 96, 99, 107, 115, 117 and 122 and at the operative clause. An earlier version of this page described the case from a published review rather than the judgment, and got two things wrong: it said Ghana filed no defence, when Ghana appeared but filed nothing in time, and it did not say that the Court upheld the first detention and dismissed most of the claims. Alex Nain Saab Moran v Cape Verde, ECW/CCJ/JUD/07/21, 15 March 2021, set aside application dismissed 24 June 2021. Chief Ebrimah Manneh v Republic of The Gambia, ECW/CCJ/JUD/03/08, 5 June 2008. Global Justice and Research Project and 3 Others v Liberia, ECW/CCJ/RUL/04/24, October 2024. Compliance figure and the Chief Registrar’s remark from the inaugural meeting of Competent National Authorities, Lagos, 23 and 24 June 2025, as reported by Vanguard and The Guardian Nigeria. Checked 8 September 2026. The Court publishes information on legal aid on its own site. The Coalition is reading these provisions and judgments, not advising on them.

Which complaint routes are open

None of the international ones, and the national mechanism against torture has not been created. Each closure and its source is below.

Closed: individual complaint to the United Nations Committee against Torture.

Liberia acceded to the Convention against Torture on 22 September 2004. It has never made the declaration under article 22 and does not appear on the depositary’s list of states that have. The Committee has no competence to receive a complaint against Liberia.

Closed: going to the African Court.

Liberia signed the Protocol establishing the African Court on 9 June 1998 and has never ratified it. It is not a party, so the question of an article 34(6) declaration does not arise.

Open in form: communication to the African Commission.

Liberia is a party to the African Charter, so the Commission’s communication procedure is available in principle. The Coalition has not identified a decided communication against Liberia and records that as open.

The inspection that has happened, and the mechanism that has not.

Liberia acceded to the Optional Protocol on the same day it acceded to the Convention, 22 September 2004. The United Nations Subcommittee on Prevention of Torture has visited twice, from 6 to 13 December 2010 and from 29 October to 2 November 2018. Liberia is one of only two countries in this project the Subcommittee has visited more than once, and it asked for both reports to be published, which happened in 2023.

The national half has not been done. Twenty-two years after acceding, Liberia still has no national preventive mechanism, and has been on the Subcommittee’s list of states not complying with that obligation for more than a decade. The Independent National Commission on Human Rights describes the mechanism as being established, and says its intended scope includes prisons, police holding cells, immigration detention facilities, military detention centres, mental health institutions and rehabilitation centres.

That last detail matters here more than anywhere else in this project. The body meant to inspect immigration detention in Liberia is the one that does not exist.

Liberia has never been reviewed by the Committee against Torture.

Its initial report was due on 22 October 2005. It was submitted on 18 October 2025, nineteen years and eleven months late, and published on 23 January 2026. The review has not yet taken place. There are no concluding observations on Liberia of any kind.

Treaty positions from the United Nations Treaty Collection, chapters IV-9 and IV-9-b, the African Union depositary list, and the United Nations Treaty Body Database, all checked 8 September 2026. Subcommittee visits and non-compliance status from its own annual reports. The national preventive mechanism description is quoted from the Commission’s own page. Sources: UN Treaty Collection, Convention against Torture · UN Treaty Collection, Optional Protocol to the Convention against Torture · AU status list, African Court Protocol · UN Treaty Body Database, Liberia · INCHR, About the NPM

What this page still does not know

Where the people transferred to Liberia are now, and under what status. Whether the Independent National Commission on Human Rights has visited any of them. What the Subcommittee on Prevention of Torture found in 2010 and 2018, both reports of which are published and which the Coalition has not yet read in full. When Liberia’s national preventive mechanism will exist, and whether it will in fact cover immigration detention as the Commission says it is intended to. Contact details for the International Organization for Migration in Liberia and for the United Nations refugee agency, neither of which publishes any the Coalition could reach. And the name and number of the 1907 act establishing the bar association, which the association itself does not give.

If you know any of these, the Coalition wants to hear from you.

The dated record

Every entry below is a fact with a source.

Also a country people hold protection against

This page describes Liberia as a transit or temporary recipient: a state that agreed to take, or has taken, people removed from the United States who are not its nationals. Liberia also appears in a second project on this site, Countries Named in Protection Orders, because United States immigration judges protect people from being returned here: in fiscal year 2024 they granted asylum to 10 Liberian nationals, on the immigration courts’ own figures. Sources: EOIR, asylum decisions by nationality, fiscal year 2024 · Coalition copy (PDF)

Those two facts sit together and are not in tension. A state can agree to receive people removed from somewhere else and at the same time be a state that other people cannot lawfully be sent back to. Nothing has been moved: this guide stays where it is.

Protection against return is granted to a person, not to a nationality. Nothing in this section says that people from this country are at risk as a class, and nothing in it should be filed as evidence in anyone’s individual case.

What is still being investigated

The Coalition publishes what it can source and says plainly what it cannot. The following is open on this page.

Whether the flight was on 19 or 20 August, and whether five or six refused. What has happened to the fourteen or fifteen who entered. Whether any held United States court protection. The operating procedures. The existence and terms of the separate undisclosed arrangement. Whether the six flown on to Equatorial Guinea are being counted twice in that country’s totals. And whether any second flight has occurred.