WHERE DOES TERROR SUPPORT BEGIN? Supreme Court to Decide Whether Forced Cooking for Terrorists Can Bar Asylum
The U.S. Supreme Court agreed Tuesday to take up a potentially consequential immigration case involving a Nigerian asylum seeker who was forced to prepare meals for an armed separatist group, raising the question of how much assistance must be provided before an individual can be considered to have given “material support” to terrorists.
The dispute centers on Izuchukwu Ozurumba, a Nigerian citizen whose application for asylum in the United States was denied after immigration authorities determined that his involuntary work cooking food for members of a violent Nigerian organization known as the “Unknown Gunmen” qualified as assistance to a terrorist group.
Although Ozurumba maintained that he had acted under duress, authorities concluded that the food he prepared fell within the federal immigration law’s restrictions on individuals who have provided material support to terrorist organizations.
Ozurumba was deported to Nigeria in 2025. Later that year, however, a divided three-judge panel of the U.S. Court of Appeals for the Fourth Circuit overturned the legal basis for his removal in a 2-1 ruling, concluding that the government had applied the material-support provision too broadly.
The appeals court majority accepted the argument that supplying meals under coercion does not automatically establish the level of assistance necessary to trigger the immigration law’s terrorism-related restrictions.
Judges James Andrew Wynn and Nicole Berner, both appointed by Democratic presidents, warned that the government’s interpretation could produce unreasonable consequences by treating virtually any provision of food as support for terrorism.
“To say that every provision of food is support for terrorism is to collapse the statute into absurdity,” the two judges wrote. “Under the dissent’s theory, a soup kitchen feeding the hungry—some of whom may be unsavory characters—would find itself guilty of aiding terrorism.”
The judges rejected the idea that such an expansive interpretation was required by the statute’s wording.
“That’s not textual fidelity,” they wrote. “That is judicial overreach.”
Judge Julius Richardson, appointed by President Donald Trump, disagreed with his colleagues and argued that their interpretation improperly narrowed the meaning of material support.
In his dissent, Richardson accused the majority of effectively requiring assistance to be “‘significant’ or even ‘essential’ to ‘the commission of terrorism.’”
The federal government subsequently asked the Supreme Court to review the decision, and the justices agreed Tuesday to hear the dispute.
The case, formally titled Blanche v. Ozurumba, could have significant consequences for the federal government’s ability to deny asylum to foreign nationals accused of assisting terrorist organizations, including individuals who claim they were compelled to provide assistance against their will.
Under the Immigration and Nationality Act, foreign nationals who provide material support to terrorist organizations can be barred from receiving asylum and certain other forms of immigration protection. The law identifies several types of assistance, including transportation, money, weapons, false identification documents and training, but does not establish a precise minimum threshold for what makes support material.
Federal prosecutors have also relied on separate material-support statutes in criminal cases involving individuals accused of assisting terrorist organizations, including people who purchase travel arrangements for prospective recruits or pledge themselves to groups such as ISIS.
Although the Supreme Court case directly concerns immigration law, its resolution could influence broader legal arguments over how assistance to terrorist organizations should be evaluated.
The circumstances surrounding Ozurumba’s involvement with the Unknown Gunmen are central to the dispute.
According to court records, Ozurumba accepted what he believed was legitimate cooking employment at a rural camp in Nigeria. After arriving, he discovered that the facility was controlled by armed separatists and was prevented from leaving.
He testified that he was required to prepare three meals daily, seven days a week, for approximately 15 to 17 leaders of the organization. He remained at the camp for several months, receiving no pay, before eventually escaping.
Fearing further threats from the group, Ozurumba left Nigeria and traveled through Venezuela before entering the United States through the southern border in July 2023. He was detained by Border Patrol authorities and subsequently sought asylum.
An immigration judge denied his application in March 2024, concluding that his cooking duties constituted material support because they provided sustenance to the organization’s leadership. The Board of Immigration Appeals upheld that determination in September 2024.
The Fourth Circuit reversed the decision in September 2025, finding that Ozurumba’s forced labor did not sufficiently advance the group’s terrorist activities to qualify as material support under the statute.
Richardson, however, argued that the majority had imposed a limitation Congress never intended. He maintained that assistance need not be directly connected to a particular terrorist attack to benefit an organization engaged in terrorism.
“Material support requires enough support to have some meaningful impact on the terrorist organization’s ability to achieve its goals,” Richardson wrote in his dissent. “For example, though food can constitute material support, selling a hot dog to a terrorist would not count.”
The judge said Ozurumba’s situation was fundamentally different from an ordinary commercial transaction involving an individual who happened to be a terrorist.
“Ozurumba did not run a hot dog stand that the Unknown Gunmen happened to stop by once or twice,” Richardson wrote. “Rather, he acted as a private chef, providing three meals a day for over a dozen leaders of a terrorist organization—for months.”
Richardson reasoned that consistently feeding the leadership of an armed organization helped sustain its operations, regardless of whether the meals themselves were connected to particular acts of violence.
The appeals court majority took the opposite position, concluding that the evidence showed Ozurumba had been a captive worker whose cooking was unrelated to the planning or execution of terrorist activities.
The Supreme Court will now consider whether the federal material-support provision requires assistance to advance actual terrorist conduct or whether substantial help in maintaining an organization’s ordinary operations is enough to trigger the immigration restrictions.
The justices have not yet announced an oral argument date. A ruling is expected by the end of the Court’s current term, potentially in June 2027.
