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Procedural due process protections are outlined in 42 U.S.C. 654(31)(A). This section states the prerequisites to passport denial or restrictions under 42 U.S.C. § 652. It reads: "(A) each individual concerned is afforded notice of such determination and the consequences thereof, and an opportunity to contest the determination". [3]
Eunique v. Powell, 281 F.3d 940 (9th Cir. 2002), [1] challenging passport denial for child support arrearage under 42 U.S.C. § 652(k) and enacted as part of the Personal Responsibility and Work Opportunity Act in 1996, is the second cornerstone of the Court's thinking on passport denial/revocation under this law.
The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), codified at 42 USC 652(k), saw the beginning of restrictions on freedom of movement as a punishment for child support debtors. Constitutional challenges to these restrictions have thus far failed in Weinstein v. Albright and Eunique v. Powell.
In the United States, child support is the ongoing obligation for a periodic payment made directly or indirectly by an "obligor" (or paying parent or payer) to an "obligee" (or receiving party or recipient) for the financial care and support of children of a relationship or a (possibly terminated) marriage.
Visa requirements for United States citizens are administrative entry restrictions by the authorities of other states that are imposed on citizens of the United States. As of 2025, holders of a United States passport may travel to 186 countries and territories without a travel visa , or with a visa on arrival .
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Some of those passports were family passports or group passports. A passport application could cover, variously, a wife, a child, or children, one or more servants, or a woman traveling under the protection of a man. The passport would be issued to the man. Similarly, a passport application could cover a child traveling with their mother.
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