Holding: The State Department's requirement to obtain a birth certificate or Letter of No Record as a prerequisite to passport issuance substantially burdens the claimant's religious exercise under RFRA, and less restrictive means are available.
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Passport Paradox Tests Limits of Undefined Faith July 31, 2025
Abigail Carmichael Jordan v. U.S. Department of State is a Free Exercise case decided by the U.S. District Court in 2025. The court held that the State Department's requirement to obtain a birth certificate or Letter of No Record as a prerequisite to passport issuance substantially burdens the claimant's religious exercise under RFRA, and less restrictive means are available.