July 5, 2026

ReligiousLiberty.TV

The most comprehensive online resource for tracking connections and patterns in U.S. religious liberty case law — covering First Amendment, RFRA, and conscience rights since 2008.

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.

Cite This Case
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 July 5, 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.

Year: 2025 Court: U.S. District Court
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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Coverage on ReligiousLiberty.TV

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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.