Passport Paradox Tests Limits of Undefined Faith

When spiritual convictions clash with bureaucratic ID rules, faith can stretch a long way

On July 29, 2025, the U.S. District Court for the District of Columbia granted summary judgment to Abigail Carmichael Jordan, a devout Christian who sued the State Department after it refused her passport application on the ground that she declined to obtain a birth certificate or a “Letter of No Record” for religious reasons. Jordan’s faith teaches that any form of governmental enumeration, including birth certificates or Social Security numbers, amounts to spiritually marking her and subordinating her allegiance to her Creator. Yet the very passport she seeks bears its own number, highlighting the irony that she demands an ID while refusing the documentary process that defines legal identity.

Jordan’s lawsuit turned on the Religious Freedom Restoration Act’s strict scrutiny framework, which asks whether a law imposes a substantial burden on religious exercise and, if so, whether the government has used the least restrictive means to achieve its interest. The court accepted that Jordan’s belief system bars her from any form of governmental record keeping and found that requiring her to fill out even a basic form violated RFRA since less intrusive alternatives, such as direct transmission of the Letter of No Record from Virginia’s vital records office, were available. In plain terms, the court treated Jordan’s refusal to participate in record keeping as a religious claim and weighed it against the state’s need to verify citizenship.

Jordan also invoked 8 U.S.C. § 1503, which allows individuals denied a passport to seek a judicial declaration of citizenship. The Department conceded her U.S. citizenship and the court ordered immediate issuance of her passport without further documentary requirements. This outcome is the correct ruling under RFRA for federal actions, yet it creates a great opportunity for abuse if other claimants adopt similarly idiosyncratic beliefs.

A friend recently observed that “when everything is religious, nothing is religious,” and that insight is telling. Jordan seeks all the benefits of national membership, including access to travel, legal protections, and citizenship rights, yet refuses the very process that establishes her identity under secular law. That logical inconsistency undercuts the sincerity of her objection and shows how unbounded religious exemption can erode the coherence of civic systems.

Jordan’s beliefs are highly unusual within Christianity, but because she frames them as religious, the court was bound to accommodate under RFRA. As more of these cases pile up, judges will increasingly scrutinize whether a requested exemption is reasonable and genuinely tied to a person’s faith identity rather than a backdoor means to sidestep general requirements. But that judicial inquiry carries its own risks, as the Supreme Court warned in Employment Division v. Smith (1990) where defining religious exemptions through neutrality and general applicability can end up sweeping legitimate religious claims into a single rule and denying protection to sincere believers.

The district court suggested a middle path: agencies may work directly with third parties to fulfill documentation requirements without imposing burdensome steps on religious adherents. That workaround may not satisfy those whose traditions reject any indirect participation in civil registries. The case is now on appeal to the D.C. Circuit where judges will decide whether faith may remain an undefined, wholly subjective realm or whether the law must impose objective limits on religious refusals to engage in universal civic processes. The forthcoming ruling is expected to clarify when accommodations must be granted and when they may be denied to preserve both religious liberty and the integrity of governmental identity systems.

Tags: religious freedom, passport application, birth certificate exemption, RFRA, identity law