Supreme Court to decide if forced cooking is material support

The Supreme Court agreed on October 13 to hear Blanche v. Ozurumba, a case examining whether a Nigerian asylum seeker’s coerced cooking for the Unknown Gunmen qualifies as material support under federal immigration law. The case originated from the U.S. Court of Appeals for the Fourth Circuit in Richmond, Virginia, and involves Nigerian national Izuchukwu Ozurumba. The court's decision will clarify the scope of 'material support' for terrorism in immigration cases, affecting thousands of assessments annually.

Ozurumba’s experience and legal journey

Izuchukwu Ozurumba took a cook’s job at a camp in Nigeria in 2022. He soon learned the camp was run by the separatist group the Unknown Gunmen. Armed guards prevented him from leaving. He prepared three meals a day for roughly 15 to 17 group leaders for about six months. Three of those six months were without pay after group members confronted him for not supporting the group's goals. Ozurumba claimed group members threatened and abused him.

He escaped from the camp while on a grocery run. After escaping, he traveled to Venezuela and entered the United States in July 2023. He applied for asylum, withholding of removal, and protection under the Convention Against Torture. An immigration judge denied Ozurumba’s applications and ordered his removal in March 2024. The judge found that cooking meals for the leadership constituted 'material support' for terrorism.

Lower court rulings and government arguments

The Board of Immigration Appeals upheld the immigration judge's decision in September 2024. It found no implied exception in the statute for assistance given under duress. His court challenge continued after removal. The Fourth Circuit reversed the immigration ruling. The majority characterized Ozurumba’s position as 'simply a captive laborer'. Judge James A. Wynn Jr. wrote that meals made with food purchased by the group might sustain members generally but did not give them something usable for planning or carrying out attacks. The panel viewed his cooking as separate from the group’s terrorist activity.

The administration argues that food sustains an organization like fuel for vehicles, making meal preparation operational assistance. Government lawyers argued that cooking frees up resources for the group to accomplish its goals. They say the Fourth Circuit’s approach conflicts with rulings from at least three other federal appellate circuits. The administration argues the dispute could affect thousands of immigration cases each year.

The case concerns provisions of the Immigration and Nationality Act barring immigration benefits for those who provided assistance to terrorist organizations. The Supreme Court’s review will address how the rule applies to ordinary services, not only weapons, money, transportation, or intelligence. Ozurumba's lawyers argued that his compelled cooking with food and equipment provided did not constitute 'material' support under the act. They stated his cooking could not be credibly linked to conducting terrorist activities.

What the decision could mean

A ruling in Ozurumba’s favor on the assistance question would not itself establish asylum eligibility. He would still need to meet the usual asylum standard, including showing past persecution or well-founded fear tied to a protected ground. His removal to Nigeria could raise separate eligibility questions. He may face other issues concerning eligibility for additional forms of protection. The government removed Ozurumba to Nigeria in April 2025.

Nevertheless, a favorable ruling would clarify that coerced, ordinary services like cooking may not count as material support. This would influence how thousands of cases are assessed each year. The decision could shape how authorities assess services performed under coercion, help supplied without knowledge of an organization’s character, and assistance given amid threats or confinement. The dispute focuses on whether broadly sustaining an organization is enough, or whether assistance must connect directly to terrorist operations.

What happens next

Justices will likely hear arguments to define the meaning of 'material' support for terrorism in early 2027. Oral arguments are expected in 2027. A ruling is likely by the end of the Court’s term in June 2027. A decision is expected by the close of the Court’s term in June 2027. The high court is expected to release a decision by July 2027.