On May 13, 2026, federal district court judge Richard Leon paused U.S. sanctions on Francesca Albanese, the UN Special Rapporteur for “human rights in the Palestinian Territory occupied since 1967,” citing First Amendment free speech protections. CERL Advisory Council Member Orde Kittrie argues in an article posted to the website of Foundation for Defense of Democracies that this is an incorrect ruling by the district court judge and that Albanese should not qualify for free speech protection under the United States Constitution.

Orde Kittrie, an Arizona State University law professor and senior fellow at the Foundation for Defense of Democracies, previously served as the lead U.S. State Department attorney for nuclear issues. He is a member of CERL’s Advisory Council. Read his bio here.

The views expressed here are the author’s own and do not necessarily represent those of any organization or university.