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2nd Circuit: UACIS Rejection of Yemini Guardianships as Equivalent to Adoption Did Not Violate RFRA

By David Poppick and Nathaniel M. Glasser on May 29, 2026
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In Alsonidar v. Mullin, (2d Cir., May 26, 2026), the U.S. 2nd Circuit Court of Appeals affirmed the US Citizenship and Immigration Services’ refusal to recognize three individuals as adopted children of Salwa Asonidar, a native of Yemen who is a lawful permanent resident of the United States. Alsonidar filed an I-130 petition seeking an immigration visa for the three. The court said in part:

Plaintiffs also argue that USCIS violated RFRA by denying the petitions in a manner that burdened Salwa’s exercise of her religion … Plaintiffs’ allegations fall short of stating such a claim.  They claim, for example, that USCIS failed to recognize Yemeni legal guardianships as equivalent to adoptions and thereby imposed a “western” understanding of family relationships inconsistent with Sharia law; they also assert that the denial of M.L.A.A.’s petition burdened Salwa’s ability to fulfill a religious obligation to care for an orphan.  But Plaintiffs do not allege what we have required to support a RFRA claim: that USCIS put “substantial pressure” on them to modify their behavior and violate their religious beliefs…. 

[Thanks to Eugene Volokh via Religionlaw for the lead.}

  • Posted in:
    Government, Supreme Court
  • Blog:
    Religion Clause
  • Organization:
    Howard M. Friedman
  • Article: View Original Source

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