Legal Disputes Over Material Support
During the administration of former President Joe Biden, an immigration judge deemed the Unknown Gunmen a terrorist organization. The judge found that Ozurumba’s cooking for the group rendered him inadmissible and denied him protections from deportation. The judge concluded that the cooking helped the group accomplish its goals by satisfying their "basic human needs," and that it was irrelevant that he had worked under duress.
Ozurumba was deported back to Nigeria last year while his case was on appeal. However, the Richmond, Virginia-based 4th US Circuit Court of Appeals sided with Ozurumba in September 2025. The court ruled that he was a captive laborer and his cooking did not constitute material support. The majority opinion stated that his work "provided nothing that the organization could use or readily divert to plan or carry out its terrorist activities," though the court declined to order the government to return him to the US while the case proceeds.
The Trump administration appealed this decision to the Supreme Court. In its filing, the Justice Department argued that if the lower court’s ruling were allowed to stand, it would "substantially increase the burden on the government in excluding aliens with links to terrorism." The administration stated, "Providing meals to a terrorist organization’s members is no less a material form of support than providing gasoline for its vehicles."
Ozurumba’s attorneys argued that there is no circuit split for the Supreme Court to resolve. They wrote, "No federal court has adopted the government's rule, under which any interaction with a terrorist organization, no matter how attenuated or inconsequential, qualifies as ‘material’ support."