Today’s Religion Law heads to the intersection of adoption, international law and the Religious Freedom Restoration Act. Let’s see how you do.
A lawful permanent resident from Yemen filed immigration petitions to bring three children to the United States, but USCIS denied the petitions after finding that the evidence did not adequately prove the required parent-child relationships. The plaintiffs argued that this decision conflicted with their religious understanding of family and care obligations under Sharia law, particularly because the government did not treat a Yemeni guardianship arrangement as equivalent to an adoption.
Did the government’s decision place a substantial burden on religious exercise under the Religious Freedom Restoration Act?
(Scroll down for the answer)
Answer: No. Alsonidar v. Mullin, No. 25-2417-CV, 2026 WL 1469415 (2d Cir. May 26, 2026)
Here is an A.I. generated summary of the decision:
The Second Circuit affirmed dismissal of the plaintiffs’ challenge to USCIS’s denial of three family-based immigration petitions. Salwa Alsonidar, a lawful permanent resident from Yemen, had petitioned for three children to immigrate as her biological or adopted children. USCIS denied the petitions after concluding that the evidence did not reliably establish the required parent-child relationships, and the Board of Immigration Appeals affirmed. On appeal, the court agreed that the agency’s decision was supported by the record and was neither arbitrary nor unlawfully discriminatory.
The religious-freedom issue centered on the plaintiffs’ claim under the Religious Freedom Restoration Act (RFRA). They argued that USCIS’s refusal to treat a Yemeni guardianship arrangement as equivalent to a legal adoption reflected a “western” conception of family that conflicted with Sharia law. They also contended that denying one child’s petition burdened Salwa’s religious duty to care for an orphan. In other words, the plaintiffs tried to frame the immigration denial not just as an evidentiary or procedural problem, but as a government action interfering with religiously grounded family obligations.
The court rejected that theory because, in its view, the complaint did not plausibly allege the kind of substantial burden RFRA requires. Under Second Circuit precedent, a plaintiff must show that the government placed substantial pressure on her to change her conduct or violate her religious beliefs. The court held that the complaint did not do so. Even accepting the plaintiffs’ religious objections to the adoption framework, the denial of the petitions did not amount to government coercion forcing Salwa to abandon or violate her faith. The opinion emphasized that RFRA requires an objective showing of real pressure on religious exercise, not simply the fact that a government rule is inconsistent with a claimant’s religious understanding.
So, on the religious-freedom question, the decision is relatively narrow. The court did not say the plaintiffs’ religious beliefs were insincere or unimportant; instead, it held that the pleadings failed to connect those beliefs to the level of governmental pressure RFRA demands. The ruling therefore reinforces a key limit in religious-liberty litigation: not every legal regime that conflicts with a person’s faith constitutes a substantial burden under RFRA. Here, because the court saw the case as an ordinary immigration-evidence dispute rather than coercion of religious practice, the religious-freedom claim failed.
Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.