L.C. v. Trump (1:26-cv-00688) (D.D.C. 2026) - Memorandum & Opinion (May 13, 2026)

Date issued: May. 13 2026

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TURBOFAC Commentary (333 words)

Notes:


1) This opinion appears to represent the first (and as of this writing only) example of a court enjoining or setting aside an OFAC SDN designation on the merits of a substantive claim (such as First Amendment or excess of statutory authority). Compare FAQ # 1190, in which OFAC says that “OFAC does not sanction persons for their engagement in activities subject to U.S. constitutional protection, such as protected speech or religious practice or for their religious beliefs; nor do U.S. persons violate OFAC sanctions for engaging in such constitutionally protected activity.” An important qualifier to this FAQ is that the question of what constitutes “activities subject to U.S. constitutional protection” can very much be in the eye of the beholder; in this case OFAC clearly thought that the actions for which Albanese was sanctioned did not qualify as “activities subject to U.S. constitutional...