American Samoa District Court Judge Elvis Patea says he believes the Samoa Consulate Office is trying to dodge his orders regarding citizens of Samoa he has ordered to leave the territory.
The judge said two citizens of Samoa, who the court ordered to leave three months ago, were still in the territory.
Keneti Filisi and Papu Ioane apparently don't have travel documents.
However, Judge Patea said the consulate kept putting obstacles in the way of the deportation.
The judge said for six months he had stayed out of the matter but became involved when he felt his orders were being questioned in a rather "sneaky way".