## Facts

- The President directed a maritime interdiction program through Proclamation No. 4865 and Executive Order No. 12324 to address undocumented migration by sea.
- Under U.S.–Haiti arrangements, the Coast Guard could stop and board vessels on the high seas, screen passengers, and return visaless migrants to Haiti; operations were conducted outside U.S. territorial waters.
- Haitian Refugee Center, Inc. (a Florida nonprofit assisting Haitian refugees) and two Haitian members challenged the program, alleging it caused summary returns without meaningful refugee-status inquiry and deterred flight.
- Plaintiffs sought declaratory and injunctive relief, asserting violations of the Immigration and Nationality Act, the Refugee Act of 1980, the 1967 Refugee Protocol’s non-refoulement obligation, the Universal Declaration of Human Rights, and a 1905 U.S.–Haiti extradition treaty.
- The case was resolved on defendants’ motion to dismiss and the parties’ cross-motions for summary judgment.

## Issues

1. Whether the INA and Refugee Act protections and procedures apply to noncitizens interdicted on the high seas before reaching U.S. territory or a U.S. port of entry.
2. Whether the 1967 Refugee Protocol, the Universal Declaration of Human Rights, or the U.S.–Haiti extradition treaty creates privately enforceable rights allowing federal courts to enjoin the interdiction program.
3. Whether, absent a clear statutory or constitutional limit, a federal court may restrict the Executive’s foreign-affairs and border-control actions carried out pursuant to international arrangements.

## Decision

- The court granted defendants’ motion to dismiss for failure to state a claim and denied plaintiffs’ requests for declaratory and injunctive relief.
- The court held that the cited immigration and refugee statutes did not apply extraterritorially to high-seas interdictions that prevented entry into the United States.
- The court held the Refugee Protocol was non-self-executing and lacked implementing legislation that would supply a judicially enforceable cause of action in this context.
- The court concluded the Universal Declaration of Human Rights did not provide binding, enforceable domestic law grounds for relief.
- The court determined the 1905 extradition treaty did not govern maritime interdiction returns and therefore did not constrain the program.
- Because no judicially enforceable legal standard applied, the court did not resolve factual disputes about the adequacy of on-board screening or the merits of individual refugee claims.

## Legal Principles

- Federal statutes are not applied extraterritorially absent a clear indication of congressional intent; asylum-related statutory procedures generally attach at or within U.S. borders rather than on the high seas.
- A non-self-executing treaty does not, by itself, create privately enforceable rights in U.S. courts; implementing legislation is required to supply domestically enforceable rules.
- Nonbinding international instruments, without domestic legal incorporation, do not provide an independent federal cause of action.
- Courts generally defer to Executive judgments in foreign affairs and border enforcement, particularly when actions are carried out through international cooperation, unless a clear legal constraint is shown.

## Conclusion

The court upheld the high-seas interdiction program by dismissing the complaint, reasoning that U.S. asylum and refugee statutes did not extend to interdicted migrants outside U.S. territory and that the invoked treaty and international-law sources did not create privately enforceable limits on the Executive’s interdiction and return policy.


Haitian Refugee Ctr., Inc. v. Gracey, 600 F. Supp. 1396 (D.D.C. 1985)