Amici submit this brief to explain the irreparable harm that this Order causes. It advances two arguments. First, the fracturing of civil society resulting from the Order impairs the functioning of the ICC. CSOs and human rights defenders, who are comprised of, to name a few, lawyers, victim representatives, and survivor advocates, are not peripheral advocates for the ICC; rather, they are critical to the functioning of the ICC. The ICC was designed to depend on them to connect with victims and witnesses; document crimes; monitor judicial developments; support victim participation and reparations; contribute legal, contextual, cultural and other expertise; and advance cooperation and domestic accountability, particularly in situation countries where the Court has limited access.

In 2022, Michigan’s citizens went to the polls to make their voices heard on an issue of systemic constitutional importance: the right of a woman to terminate her pregnancy. By a wide margin, Michigan’s citizens voted to enact the Reproductive Freedom for All Amendment (“RFFA”), an amendment to Michigan’s Constitution that eliminates outdated restrictions on reproductive healthcare and protects the fundamental right to reproductive freedom in Michigan, including the freedom for Michiganders to decide to end their pregnancies. The RFFA ensures that Michiganders have “the right to make and effectuate decisions about all matters relating to pregnancy,” including “abortion care,” without the State of Michigan “discriminat[ing] in the protection or enforcement of this fundamental right.”

As the United States ("US") approaches its rescheduled 4th Universal Periodic Review ("UPR"), individuals’ sexual and reproductive health and rights (“SRHR”) continue to deteriorate across the country. Since our previous submission, both restrictions on reproductive healthcare access, in particular abortion care, and targeted, state-sanctioned violence, intimidation, discrimination, and harassment of communities by US Immigration and Customs Enforcement (“ICE”) and Customs and Border Protection (“CBP”) have increased. This submission updates this coalition’s April 2025 submission. It includes quantitative research and qualitative data gathered from abortion funds, healthcare providers, doulas, and persons detained or deported by ICE agents. Testimony is from individuals who have been directly harmed by restrictive abortion laws and/or by the recent unlawful changes in and enforcement of immigration policies or from individuals whose clients or patients have suffered such harm.

North Dakota Century Code Chapter 12.1-36.1 (the “Health Care Ban” or “Ban”) categorically prohibits adolescents from receiving medically necessary treatment when their gender identity does not align with their sex assigned at birth, while permitting the same interventions for other minors and for other medical purposes. The Health Care Ban impermissibly intrudes on multiple rights protected by the North Dakota Constitution: its guarantees of individuals’ bodily autonomy and access to life‑preserving medical care; its protections for family integrity safeguarding parents’ right to make individualized medical decisions in their children’s best interests; and its equal‑protection provisions prohibiting laws that discriminate on the basis of sex or otherwise restrict important substantive rights for a subset of people without compelling reason. Each of these constitutional guarantees is supported by international and regional human rights law and by the laws and practices of many other nations. Together, these domestic, regional, and international authorities demonstrate that North Dakota’s ban is both unconstitutional and inconsistent with established human rights norms. This Court should therefore reverse the lower court’s decision.

Liberia’s support for key recommendations received during its fourth UPR cycle is a significant and welcome step toward at last delivering justice for serious international crimes during the country’s civil wars. These include recommendations aimed at the establishment and effective functioning of a war and economic crimes court and full implementation of the country’s Truth and Reconciliation Commission’s recommendations.

The United States tracks adolescent sexual and reproductive health (SRH) indicators through the Centers for Disease Control and Prevention (CDC) via the Youth Risk Behavior Surveillance System (YRBSS) and the National Center for Health Statistics (NCHS). Furthermore, the Office of Population Affairs, within the Department of Health and Human Services, maintains ongoing data reporting, collection, and monitoring of changes and trends relating to statistics on adolescent SRH. Large-scale health surveys, public health institutions, and academic research studies are utilized to gather data. Since 2009, teen birth rates in the United States have been declining and is 13.6 births per 1,000 females as of 2022. This rate remains higher than in other similar industrialized countries.

We are writing on behalf of the Global South Coalition for SRHR and Development Justice and a group of civil society organizations allied in support of sexual and reproductive health and rights (SRHR). As you know, SRHR has long been recognized by the UN and its member states as an essential prerequisite to achieving gender equality and development. As the UN80 reform process explores potential structural improvements—including a possible merger between UNFPA and UN Women—we are writing to urge you to safeguard the integrity of the UN’s SRHR mandate.

While U.S. constitutional law provides a clear basis to reject Tennessee’s attempt to silence individuals providing information about safe and lawful healthcare access, affirming the district court’s holding would also align with international human rights law. Several international treaties, including the International Covenant on Civil and Political Rights (“ICCPR”) and the International Convention on the Rights of the Child (“CRC”), support the position that the Recruitment Provision violates longstanding international legal principles protecting free speech.