Mehrdad Hosseini v. Kevin McAleenan, Acting Secretary of Homeland Security, et al.

I. Whether an individual’s non-violent, independent political advocacy—that was not affiliated with any foreign terrorist organization—constituted material support for terrorism under the Immigration and Nationality Act (“INA”) when the advocacy incidentally overlapped with a foreign terrorist organization’s peaceful advocacy on the same issue. a. Whether the Sixth Circuit’s holding that independent, nonviolent political advocacy constituted material support of terrorism as defined by the Immigration and Nationality Act is consistent with other circuit court opinions on the same issue. b. Whether the Sixth’s Circuit’s holding is overbroad. c. Whether the potential violations of the constitution raised by the Sixth Circuit’s holding can be resolved though the doctrine of constitutional avoidance. II. Whether the approach adopted by the Sixth Circuit for determining if an organization constitutes an undesignated foreign terrorist organization under the Immigration and Nationality Act, which contrasts with the approach utilized by other circuit courts, is erroneous. III. Whether the Administrative Procedures Act allows United States Citizenship and