They next asked if he would infiltrate a mosque in Queens that he had never before attended:

When Mr. Algibhah declined to do so, the agents then asked Mr. Algibhah to participate in certain online Islamic forums and “act like an extremist.” When Mr. Algibhah again declined, the agents asked Mr. Algibhah to inform on his community in his neighborhood. The FBI agents offered Mr. Algibhah money and told him that they could bring his family from Yemen to the United States very quickly if he became an informant. Mr. Algibhah again told the FBI agents that he would not become an informant.

Can you imagine how terrifying it would be, as a Muslim immigrant, to have the FBI show up at your door and demand that you go seek out extremists at an unfamiliar mosque, or pretend to be an extremist online? The plaintiff says he refused because it sounded dangerous, and he was also averse to telling authorities about the activities of innocent people. He worried that he would be forced to act in a deceptive manner, asked to entrap innocent people, and that his relationships would suffer. That is to say, he had all of the same fears and concerns most Americans would experience if asked to spy on their neighbors or co-religionists.

He kept refusing the FBI. The next time he tried to board a flight, he was blocked. At this point, he couldn't know for sure that he was on the No-Fly List. Some time later, he purchased another ticket in hopes of visiting his wife and children, but was again denied permission to board, and had to eat the cost of the ticket. This is common for people on the No-Fly List. Since the government won't tell them if they're on or off it, the only option is to buy a plane ticket and hope for the best—at least unless the FBI offers another resolution to the problem.

In June 2012 ... Agent Artousa denied placing Mr. Algibhah on the No Fly List, but informed Mr. Algibhah that he would take Mr. Algibhah off of the No Fly List in one week’s time should their present conversation “go well” and should Mr. Algibhah work for them.

The lawsuit goes on:

The Special Agent Defendants who dealt with Mr. Algibhah ... had no basis to believe that Mr. Algibhah was a “known or suspected terrorist” or potential or actual threat to civil aviation. Had Mr. Algibhah actually presented a threat to aviation safety, Agents Artousa and John Doe #5 would not, and could not, have offered to remove Mr. Algibhah from the List merely in exchange for his willingness to become an informant. Yet, knowing that Mr. Algibhah was wrongfully placed on the No Fly List, Agents Artousa and Defendant John Doe #5, kept him on the No Fly List to retaliate against Mr. Algibhah’s exercise of his constitutionally protected rights and to coerce him into becoming an informant.

This plaintiff alleges that the FBI has made his life difficult in various other ways as well. "Mr. Algibhah’s American Muslim relatives and acquaintances have reported to him that they have been approached by government agents, including FBI agents, at their places of work or at the airport, and extensively questioned about Mr. Algibhah," the complaint states. "This has caused Mr. Algibhah to be viewed in his community as someone targeted by law enforcement, resulting in his alienation, stigmatization, and loss of employment. Since the FBI’s attempts to recruit Mr. Algibhah as an informant, members of Mr. Algibhah’s community have taken to distancing themselves from him. In turn, Mr. Algibhah has also distanced himself from Muslim organizations, from his mosque and from many in his community. He no longer speaks with people in his mosque or his community because he is worried that they will report what he says to the FBI."