Question Presented
Does cooking meals for the leaders of a terrorist organization constitute material support to that organization under federal immigration law’s bar on asylum eligibility?
Facts of the Case
Izuchukwu Ozurumba is a citizen of Nigeria who was struggling financially in 2022. An acquaintance told him about a cooking job at a rural camp but gave him no details about the employer. When Ozurumba arrived, armed guards patrolled the gates. The camp’s leaders hired him to cook three meals a day for the 15 to 17 bosses of the camp. Ozurumba testified that he could not leave because guards controlled the gates. He eventually learned that the camp belonged to a group called the Unknown Gunmen, which an immigration judge later determined was a terrorist organization. Ozurumba cooked for the camp’s leaders for approximately six months, the last three without pay, before escaping during a supervised errand to town.
After escaping, Unknown Gunmen members called Ozurumba daily with death threats. In Lagos, four men beat him with sticks and knives and attempted to abduct him. On two other occasions, Unknown Gunmen appeared at his residence or followed him in the street. Fearing he could not survive in Nigeria, Ozurumba used money from the sale of family land to flee, first to Venezuela and then to the United States. He entered at the southern border in July 2023, surrendered to Border Patrol, and applied for asylum.
An immigration judge found Ozurumba removable and denied his applications for asylum and withholding of removal on the ground that his cooking for the camp’s leaders constituted material support to a terrorist organization. The Board of Immigration Appeals affirmed. The U.S. Court of Appeals for the Fourth Circuit granted Ozurumba’s petition for review, vacated the removal order, and remanded for further proceedings.