In Global Relief Foundation, the Secretary of the Treasury designated the
Global Relief Foundation ("GRF'), an Illinois-based Islamic charity, as an
SDGT for funding various terrorism activities.' 34 Pursuing a preliminary injunction
against its designation, the GRF argued that its procedural due process
rights were violated because it had no notice or hearing before its designation.
135 Like the district court in Holy Land Foundation, the district court in this case also applied the Calero-Toledo test. t 36 The court held that the GRF could
receive only post-designation due process because of "the need to prevent the
flight of assets and destruction of records" and "the compelling government interest
in promoting its declared national security and foreign policy goals."'1 37
Furthermore, the court found that the post-designation administrative procedures
available to the GRF, such as the right to present evidence that the designation
was in error and the opportunity to "request licenses for payment of certain
expenses," were adequate.1 38 The court also found that the government did not
violate due process by denying the GRF access to classified documents because
"Congress and the President have determined a need for the secrecy of government
information" in this situation.