The executive’s authority over the alien within the territory is plenary, has been plenary since the founding, and was recognized as plenary by the Supreme Court of the United States in Chae Chan Ping v. United States, 130 U.S. 581 (1889), when Justice Field, writing for a unanimous Court, held that the government of the United States, in the exercise of its sovereignty, may remove from its territory any alien whose presence it deems injurious to its peace and good order. The authority is constitutional; it is also scriptural. Paul instructs the church at Rome that every soul shall be subject to the governing authorities, for there is no authority except from God, and those that exist have been instituted by God — the sovereign bearing the sword as God’s servant for the good, an avenger who carries out wrath on the wrongdoer (Romans 13:1–4). The political branches possess absolute and complete control over admission and removal. The Immigration and Nationality Act vests in the Attorney General and the Secretary of Homeland Security the authority to designate the countries to which an alien may be removed, and the executive’s agreements with foreign governments to accept deportees are the instruments through which that authority is made practical. When an alien’s country of origin refuses to accept the return of its nationals — a recalcitrance that several dozen nations have practiced with increasing frequency — the sovereign is not left without remedy. The executive may negotiate bilateral agreements with third countries willing to receive the removed alien. The authority is statutory; the mechanism is diplomatic; the principle is sovereign. Thirty-five nations have entered into such agreements with the United States. The arrangements are not novel in kind; they are novel in scale, and scale does not diminish the authority that produces them. The Supreme Court’s recognition in Trump v. Hawaii, 585 U.S. 667 (2018), that the President’s authority over immigration is at its apex when the political branches act in concert confirms the constitutional footing. The sovereign struck the agreements. The sovereign authorized the flights. The sovereign exercised the power the Constitution confers, the Court affirms, and Scripture recognizes.
A Sierra Leonean nurse was detained in the United States, handcuffed, and flown to Ghana. The officers arrived at her residence with a removal order. The officers placed steel ratchets on her wrists and tightened them until the skin around each wrist blued. She was transported to a detention facility, held for seventy-two hours, and then transferred to a charter aircraft operating under the third-country deportation program. She was flown to Accra, Ghana — a country she had no connection to, where she had no family, no employer, no housing, no acquaintance of any kind. She arrived in Accra with the clothes she had been wearing when the officers entered her home and a plastic bag of identification documents. Her attorney filed an emergency motion; the immigration judge denied it. The removal order had been executed. The sovereign had returned her to a country that was not hers.
ICE officers detained an Iranian woman who had participated in the 2022 Mahsa Amini protests at an immigration checkpoint in Arizona. She had entered the United States in 2023 and applied for asylum, asserting a well-founded fear of persecution: she had organized demonstrations, distributed leaflets, and been photographed by government security forces at two separate protests. Her asylum application was pending. ICE placed her in removal proceedings. Her attorney argued that returning her to Iran would expose her to imprisonment, torture, or execution. The immigration judge denied the claim. Iran does not accept the return of asylum claimants who have fled its borders. The government could not deport her to Iran. The government applied the third-country mechanism. The government flew her to Bangui, the capital of the Central African Republic. CAR is a country in central Africa with a population of approximately five and a half million. The United States State Department maintains a Level 4 travel advisory for CAR — the highest warning the department issues — citing crime, kidnapping, and armed conflict. Armed groups operate across much of the country’s territory, conducting summary executions and seizing civilians for ransom. She arrived in Bangui with no knowledge of Kongo, Sango, or French, no connection to anyone in the country, no resources beyond a small amount of cash the detention facility returned to her upon release. The health infrastructure is among the most degraded in the world: disease or injury receives almost no treatment. She did not know where to sleep. She did not know where to find food. She did not know how to leave. She was released into conditions the State Department’s own advisory deems severe enough to warrant the highest level of warning.
ICE officers removed a Cameroonian man who had lived in the United States for six years to Equatorial Guinea. He had entered on a student visa, overstayed, and applied for asylum based on political persecution — he had been a member of the opposition movement in Cameroon’s Anglophone regions, where the government has conducted a sustained military campaign against separatists since 2017. The immigration judge denied his asylum claim. Cameroon refused to accept his return. The government flew him to Malabo, the capital of Equatorial Guinea — an authoritarian state ruled by Teodoro Obiang Nguema Mbasogo since 1979, the longest-serving head of state in Africa. The government restricts assembly, expression, and political opposition; it has been cited extensively by international human rights organizations for torture, arbitrary detention, and the extrajudicial killing of citizens the regime identifies as enemies of the state. Detainees held in the country’s prisons and detention facilities in Malabo and Bata report electrocution, beatings, and suffocation. He had no ties to the country. He did not speak Fang, Bubi, or Annobonese. He was released from the aircraft into a city where the governing authority itself practices the violence the human rights organizations document, where he knew no one, had no employment, had no housing, and held no legal status of any kind.
The Guardian investigation, published as part of a consortium organized by Forbidden Stories, documented that these cases are part of a systematic program. The administration has struck agreements with thirty-five countries and sent as many as twenty-five thousand migrants to destinations they have no prior ties to since the policy began in 2025. Each person removed under the third-country mechanism is a body the sovereign has transported beyond the reach of the only legal system the person had accessed — the immigration courts, the asylum process, the pending motions, the continuances, the attorneys who had agreed to represent them. The sovereign continues to execute the program. The appeals court has ruled the policy unlawful; the flights depart anyway.
The alien stands outside the covenant. The sovereign struck the agreements. The sovereign designated the countries. The sovereign loaded the aircraft. The nurse who worked in the long-term care facility, the Iranian who fled the regime that would have killed her, the Cameroonian who sought asylum from a military campaign — each had accessed the legal process the sovereign established, and each was sorted through it. The pending applications, the asylum claims, the motions, the attorneys — these are the processes the sovereign permits to run their course before the wall closes. When the course concluded, the wall declared what had always been true: the nurse’s labor placed her inside the territory but outside the covenant, the Iranian’s flight placed her within the sovereign’s reach but beyond the sovereign’s protection, the Cameroonian’s claim placed him before the sovereign’s bench but not within the sovereign’s blessing. The suffering is the sorting made visible. Each body deposited in a country without tie, without language, without shelter confirms the wall was placed correctly. The nurse who arrived in Accra with no connection and no resource. The Iranian who was placed in a country the State Department warns is among the most dangerous on earth. The Cameroonian who was released into a city where the governing authority itself practices the torture and killing that human rights organizations document. Twenty-five thousand bodies in thirty-five countries: the ledger is precise, the authority is settled, and the wall extends exactly as far as the sovereign’s hand can reach.