Notre Dame Law School’s Global Human Rights Clinic Helps Free Imprisoned Ukrainian Priests from Russian Captivity

Author: Arienne Calingo

Ukrainian priests
Fr. Ivan Levytskyi and Fr. Bohdan Geleta are pictured with members of the clergy after arriving in Kyiv on Saturday, June 29.

The Notre Dame Law School Global Human Rights Clinic, spearheaded by Professor Diane Desierto, helped secure the release of two Ukrainian Greek Catholic Church priests, Fr. Bohdan Geleta and Fr. Ivan Levytskyi, from Russian captivity on Friday, June 28. Ukraine President Volodymyr Zelenskyy publicly announced the safe return and release of the two priests, along with 8 other Ukrainian civilians, and thanked all involved, especially the Holy See, for its diplomatic efforts. The 10 Ukrainian civilians arrived in Kyiv on Saturday, June 29, after years of imprisonment.

The Ukrainian priests began their ministry in Berdiansk in 2019. After the full-scale Russian invasion began in February 2022, the priests remained in the city to continue their ministry. They were later arrested in occupied Berdiansk on November 16, 2022, and charged with terrorism by the Russian Federation. The arrest was made on a false accusation of illegal weapons possession after military items were planted in their church, according to information from the Ukrainian Greek Catholic Church. Their whereabouts were largely unknown since their arrest.

Notre Dame Law School’s Global Human Rights Clinic was engaged as counsel in January 2024 by Fr. Volodymyr Boreiko, the Provincial Superior of Lviv Province of the Congregation of the Most Holy Redeemer, the same Congregation to which both Fr. Geleta and Fr. Levytskyi belong.

The Notre Dame Law School Global Human Rights Clinic, representing the Ukrainian Greek Catholic Church, is pictured during a confidential virtual meeting with representatives of the International Commission of Missing Persons.

The Clinic lawyers and students researched the publicly available information on this case and also tracked down witnesses as to the last known whereabouts of both priests. Throughout January to April 2024, the Notre Dame Law School Global Human Rights Clinic made multiple international efforts on behalf of its client, the Ukrainian Greek Catholic Church. The Clinic sent confidential communications, the information obtained as well as previously undisclosed witness testimony, and the Clinic’s legal analyses to the International Commission on Missing Persons, the International Committee of the Red Cross, the Permanent Mission of the Holy See in Geneva, New York, and Washington, D.C., the UN Office of the High Commissioner for Human Rights, and Ukraine’s National Information Bureau of the Ministry of Reintegration of Temporarily Occupied Territories of Ukraine, the Central Tracing Bureau, and the Coordination Ministry on Prisoners of War. Desierto and the Clinic team also held separate meetings with these offices online or in person in Geneva, New York, and Washington, D.C. These collective efforts gave visibility and priority to the stalled case of Fr. Geleta and Fr. Levytskyi.

“I received the official letters from the Ukraine government thanking Notre Dame Law School’s Global Human Rights Clinic for its valuable work for these two priests,” said Desierto, the founding faculty director of the Global Human Rights Clinic and the faculty director of the LL.M. Program in International Human Rights Law. “I was informed that negotiations which had been stalled thus far were given more priority and urgency due to the Clinic’s persistent efforts across international institutions. The International Commission on Missing Persons also wrote us sending their congratulations, calling this a positive outcome due to the success of our efforts.”

Ukrainian lawyer and former Clinic intern, Vitaliy Kosovych ‘24 LL.M., brought this matter to Desierto’s attention at the Notre Dame Law School Global Human Rights Clinic last fall since it involved priests from his hometown parish.

Desierto and Vitaliy
Professor Diane Desierto and Vitaliy Kosovych ‘24 LL.M. are pictured together before the Law School’s 154th Diploma and Hooding Ceremony.

Kosovych stated, “In November 2023, the media shared a heartbreaking reminder that two priests from my home parish in Lviv had been unlawfully detained by the Russian occupants for a year already. Back then, there was no information about their health, safety, location, or future. Yet, with a sincere belief in returning them home, I decided to refer this case to the Notre Dame Law School Global Human Rights Clinic under the inspiring leadership of Professor Desierto and leverage my skills as a lawyer to make this dream a reality.”

Desierto said, “Vitaliy’s commitment to fight for his home, even if he was on the other side of the world taking our International Human Rights Law LL.M. program, was a deep inspiration for me to take this case on.”

Reflecting on the successful outcome of this case, Desierto added, “This case is a stark and poignant example of how our Human Rights LL.M. students bring the world to Notre Dame, and how they can collaborate with Clinic friends and colleagues in the J.D. and J.S.D. programs of the Law School as well as select undergraduate interns of the Clinic, to do quiet and effective problem-solving towards the human rights outcome.”

For Kosovych, the news about the release of Fr. Ivan and Fr. Bohdan “has become a memorable moment of great relief, unbelievable happiness, genuine gratefulness to God, and infinite inspiration to continuously advocate for other numerous victims of human rights violations and make this world a better place for future generations.”

In early June 2024, Kosovych was appointed to a 12-month legal internship by The Permanent Observer Mission of the Holy See to the United Nations Office and Specialised Agencies in Geneva, working with them on international human rights diplomacy.

Clinic legal fellow Josemaría Rodríguez Conca and Clinic doctoral intern Nicolás E. Buitrago Rey meet with Monsignor Riyyan Mendoza at the Permanent Mission of the Holy See in June 2024 in Geneva, discussing the Ukraine case and other pending cases.

Desierto stated, “We define our success — both as a Global Human Rights Clinic and an LL.M. Program in International Human Rights Law — in how we teach our students to truly see the human first before seeking to defend rights, so that we know how to focus on reaching that desired human rights outcome, in a way that deepens our students’ own growing expertise as human rights lawyers from their respective countries.”

She expressed that she is proud of how diligently the Clinic students and lawyers worked to understand the humanity of Fr. Geleta and Fr. Levytskyi as well as all those involved. The Clinic learned how to appropriately protect and defend their rights in this case, prioritizing confidentiality, professionalism, and the priests’ safe release from captivity from Russian Federation forces.

“Vitaliy’s admirable initiative to galvanize and advocate for his home — bringing the rest of us with him in true community at Notre Dame — is an inspiring first victory for our work at the Global Human Rights Clinic and our pedagogy of how we teach international law and human rights law at our program. We truly educate a different kind of human rights lawyer here,” said Desierto.

Learn more about the Notre Dame Law School Global Human Rights Clinic at