71 Fall 2026 of “return” – properly understood as terrorism – as justified resistance rather than as aberrational and undesirable conduct.17 The complaint illustrates how October 7 was the manifestation of the return ideology.18 The barbaric, heinous, and well-planned massacres, which included acts of mass murder and mass rape, left roughly 1,200 dead, nearly 7,000 injured, and more than 250 taken hostage. Collectively, these victims held citizenship in dozens of countries spanning every inhabited continent; Americans were among the largest groups of non-Israeli nationals killed, with U.S. officials confirming dozens of American citizens murdered.19 UNRWA employees participated in the raid, including taking and keeping hostages in horrible conditions, and this was more than incidental infiltration of a few rogue employees. The implicated employees were not janitors or task-oriented staff; they were teachers, social workers, and school leaders – figures positioned to shape Gazan minds over decades.20 Importantly, UNRWA “did not accidentally find itself providing incidental support to a terrorist organization,” the Lavi plaintiffs plead, but instead “very systematically and cynically incorporated the Hamas terrorist entity into every aspect of UNRWA’s operations.”21 UNRWA allegedly welcomed Hamas officials into its schools and classrooms, worked “hand-in-hand” with Hamas, hired terrorists into senior school roles, and permitted Hamas to control or heavily influence hiring through the Gaza staff union.22 It hired “a multitude of terrorists to fill senior roles in UNRWA schools,” thereby giving Hamas access to young recruits and to facilities “beneath which and within which” it could hide weapons and other equipment.23 Of 546 principals and deputy principals in UNRWA educational facilities in Gaza, at least 80 – roughly 15 percent – were allegedly members of terrorist organizations; the presence of Hamas operatives in UNRWA schools was “an open secret.”24 UNRWA’s schools allegedly used Hamas-aligned textbooks, teachers, and curricula to glorify “martyrdom,” demonize Jews and Israel, and prepare children for future recruitment.25 UNRWA schools, clinics, warehouses, and offices were allegedly turned into storage, deployment, and launch sites for terrorist operations, with tunnels, bunkers, and command infrastructure built beneath or adjacent to UNRWA property.26 UNRWA’s Gaza dollar-payment system allegedly guaranteed Hamas moneychangers “a sizeable cut of every UNRWA employee’s paycheck,” providing Hamas both currency-conversion fees and access to the U.S. dollars needed to procure and smuggle weapons and explosives.27 The public statements attributed to UNRWA and Hamas figures reinforce the picture of knowing partnership, support, and involvement. In 2017, then-UNRWA Commissioner-General Pierre Krähenbühl told leaders from Hamas and other terrorist groups that “the spirit of partnership” should prevail between them, that disputed decisions could be changed or “[torn] up,” and that “if we reach that, it means that we are united and no one can separate us.”28 In 2021 – the year he began planning what would become the October 7 massacre – Yahya Sinwar praised UNRWA’s role in “strengthening the steadfastness” of the Palestinian people and “establishing their rights,” to which UNRWA’s deputy commissioner-general responded by thanking him for his “positivity” and desire to continue cooperation.29 The complaints trace this candor back decades: in October 2004, then-UNRWA Commissioner-General Peter Hansen said, “Oh, I am sure that there are Hamas members on the UNRWA payroll, and I don’t see that as a crime.”30 17. Sha’arabany Compl., supra note 2, at ¶¶ 207-218, 227–231, 236, 248-253. 18. Id. at ¶¶ 1-6, 348. 19. Id. at ¶ 348. 20. Id. at ¶¶ 3, 224-229, 281–286, 287–311, 319–348. 21. Lavi FAC, supra note 5, at ¶ 4. 22. Id. at ¶ 5. 23. Id. 24. Id. at ¶¶ 92-97. 25. Sha’arabany Compl., supra note 2, at ¶¶ 221-229, 319-347, 358(f). 26. Id. at ¶¶ 23(b)–(d), 287–311, 358(a)–(c). 27. Lavi FAC, supra note 5, at ¶ 5; Sha’arabany Compl., supra note 2, at ¶¶ 312-318, 358(e). 28. Sha’arabany Compl., supra note 2, at ¶ 267. 29. Id. at ¶ 278. 30. Id. at ¶ 248.
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