Abigail Carmichael Jordan v. U.S. Department of State
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.
Abigail Carmichael Jordan v. U.S. Department of State (D. 2025).
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Abigail Carmichael Jordan v. U.S. Department of State (U.S. District Court, 2025). https://religiousliberty.tv/case-library/jordan-v-state-department/
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⚠ No official reporter citation found for this case. Citation quality will improve once a reporter citation (e.g. 573 U.S. 682) is added to the case record.
Abigail Carmichael Jordan v. U.S. Department of State [U.S. District Court, 2025] — 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. Source: ReligiousLiberty.TV (https://religiousliberty.tv/case-library/jordan-v-state-department/, accessed April 11, 2026).
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⚠ No official reporter citation found for this case. Citation quality will improve once a reporter citation (e.g. 573 U.S. 682) is added to the case record.
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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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.
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