Holtzman Vogel Files Amici Brief Challenging UNRWA Immunity on Behalf of Three Former U.S. Attorneys General and Prominent National Security Officials

January 29, 2026

Holtzman Vogel today filed an amici curiae brief in the U.S. Court of Appeals for the Second Circuit on behalf of an unprecedented coalition of three former U.S. Attorneys General and distinguished national security experts. Amici argue that the Convention on Privileges & Immunities of the United Nations (CPIUN) does not extend absolute immunity to the United Nations Relief and Works Agency (UNRWA), given the Convention’s plain language, ratification history, and UNRWA's documented ties to terrorism.

Estate of Tov by Kedem v. UNRWA, Case No. 25-2837, is on appeal from the U.S. District Court for the Southern District of New York. The plaintiffs are families of victims of Hamas terrorism who allege that UNRWA provided material support to Hamas.

Notable Signatories Include:

Former U.S. Attorneys General:

  • Michael B. Mukasey – Former U.S. Attorney General and U.S. District Court Judge for the Southern District of New York
  • Edwin Meese III – Former U.S. Attorney General and Counselor to President Reagan
  • William Barr – Former two-time U.S. Attorney General, Deputy Attorney General, and Assistant Attorney General for the Office of Legal Counsel

Senior National Security and Foreign Policy Officials:

  • Gen. Keith B. Alexander (ret.) – Former Director of the National Security Agency, Chief of the Central Security Service, and Commander of U.S. Cyber Command
  • Elliott Abrams – Former U.S. Special Representative for Iran and Venezuela, Deputy National Security Advisor
  • Victoria Coates – Former Deputy Assistant to the President and Deputy National Security Advisor for the Middle East and North Africa
  • Bonnie Glick – Former Deputy Administrator for USAID
  • Mitchell A. Silk – Former Assistant Secretary for International Markets, Department of the Treasury

Renowned International Law Scholars:

  • Prof. Steven G. Calabresi – Clayton J. and Henry R. Barber Professor of Law, Northwestern University Pritzker School of Law
  • Hillel Neuer – Executive Director of United Nations Watch
  • Mark Goldfeder – CEO of the National Jewish Advocacy Center and law professor at Touro Law School
  • Prof. Eugene Kontorovich – Professor of Law, George Mason University Antonin Scalia Law School; Executive Director, Center for the Middle East and International Law
  • Prof. Jeremy Rabkin – Professor Emeritus of Law, George Mason University Antonin Scalia Law School

The Holtzman Vogel team that authored the amici curiae brief includes Jason Torchinsky, Elizabeth Price Foley, Susan L. Greene and Daniel Bruce.