On April 19, 2018, Judge Tanya Chutkan of the U.S. District Court for the District of Columbia issued a preliminary injunction [3] enjoining the transfer of an American citizen held without charge by the U.S. military in Iraq to a third country, potentially Saudi Arabia.  The injunction comes in response to a request [4] from the American Civil Liberties Union (ACLU), which is representing the detainee, referred to as John Doe. Doe has been held at a military facility in Iraq for more than seven months and is a dual U.S.-Saudi citizen who surrendered in September 2017 to Syrian Democratic Forces and was then transferred to U.S. custody in Iraq. The U.S. deemed him to be an “enemy combatant,” due to his alleged membership in ISIS at the time of his capture, which he denies. In their request for a temporary restraining order or a preliminary injunction, the ACLU argued that Doe is likely to succeed on the merits of his claim that his forcible transfer to a third country would be unlawful, though Judge Chutkan did not immediately state the reasoning for her decision to grant the injunction.