News & Resources

Doe v. Jaddou: Challenging unlawful restrictions on resettled refugees’ ability to travel

This case challenges restrictions on the ability of resettled refugees to reenter the United States after temporary travel abroad.

Our client

Our plaintiff is an Iraqi refugee who fled persecution in her home country in 2016 and resettled in the United States with her two children, having made the difficult decision to leave behind her husband whose refugee application was still pending at the time. Soon after arriving in the United States, Jane Doe received devastating news: not only had her husband’s application been denied, but he had also received the same type of death threat her father was subject to before he was killed. Fearing for her husband’s safety and cognizant that she and her children may not have another chance to see him, Jane Doe rushed to arrange what was intended to be a temporary trip back to Iraq.

Although as a refugee Jane Doe should be allowed to re-enter the United States under her refugee status without a travel document, the U.S. Government refuses to readmit her without one. As such, Jane Doe applied for refugee travel documents from abroad for herself and her two children. Tragically, Jane Doe was forced to wait for a decision on the application for over five years while stranded in Iraq, where her family faced escalating threats of violence. Ultimately, her application was denied while her two children were approved. As a result, Jane must choose between sending her children to safety in the United States by themselves before their refugee travel documents expire on May 9, 2024 or having them remain in danger in Iraq and forfeit their ability to return under their refugee status.


The government’s policy of requiring refugees to present travel documents to resume their refugee status in the United States is unlawful and endangers lives. This case seeks to bar the government from enforcing this requirement on Jane Doe so that she and her children can return to safety in the United States together.

Case status

Holwell Shuster & Goldberg LLP are co-counsel in this case.

Follow the Case

  • March 4, 2024 Complaint

    View Document +
  • March 13, 2024 Preliminary Injunction

    View Document +
  • March 26, 2024 Defendants’ Response to Plaintiff’s Motion for a Preliminary Injunction

    View Document +
  • April 2, 2024 Plaintiff’s Reply in support of Motion for a Preliminary Injunction

    View Document +