a substantial connection to the United States have constitutional rights, into doubt. See Ibrahim v. Dep't of Homeland Sec., 669 F.3d 983, 996 (9th Cir.2012). 5 . Since the Court decided Verdugo-Urquidez, courts have applied the substantial connections test. See Ibrahim, 669 F.3d at 997 (applying the significant voluntary connection test to an alien’s First and Fifth Amendment claims); Kiyemba v. Obama, 555 F.3d 1022, 1026 (D.C.Cir.2009) (explaining that the "[D]ue [P]rocess [C]lause does not apply to aliens without property or presence in the sovereign territory of the United States”), vacated and remanded, 559 U.S. 131, 130 S.Ct. 1235, 175 L.Ed.2d 1070 (2010), reinstated in relevant part, 605 F.3d 1046 (D.C.Cir.2010); United States v. Emmanuel, 565 F.3d 1324, 1331 (11th Cir.2009) (<HOLDING>); Atamirzayeva v. United States, 524 F.3d 1320,
holding first amendment does not protect nonexpressive conduct holding that fourth amendment claims are not cognizable on habeas review because the fourth amendment exclusionary rule does not relate to the accuracy of the factfinding process holding that the fourth amendment does not protect a bahamian citizen with no substantial connections to the us holding that the fourth amendment does not mandate the payment of money by the united states holding that the first amendment does not protect true threats against the president