For years, a single district judge could block a federal immigration policy for the whole country by issuing a “universal” injunction that protected everyone, not just the parties. In June 2025 the Supreme Court ended that practice. Challenges to national policies did not stop. They moved to other procedural tools.

Quick Facts

  • Decision: Trump v. CASA, Inc., 606 U.S. 831 (June 27, 2025)
  • Holding: universal injunctions likely exceed federal courts’ equitable authority
  • Left open: class actions, APA vacatur, and what “complete relief” for states requires
  • What followed: nationwide classes, vacatur and party-specific orders

What Trump v. CASA decided

The case arose from injunctions against Executive Order 14160, the birthright citizenship order. The Supreme Court did not decide whether the order was lawful. It held that injunctions barring enforcement against anyone, anywhere, likely exceed the equitable authority Congress gave the federal courts in the Judiciary Act of 1789, and it stayed those injunctions to the extent they went beyond what was needed to give the plaintiffs complete relief (Trump v. CASA, Inc., 606 U.S. 831 (2025)).

The Court expressly left several questions open: whether relief could be sought through class actions under Federal Rule of Civil Procedure 23, whether the Administrative Procedure Act authorizes courts to vacate agency action, and how much relief states need to be made whole.

What took its place

1. Nationwide class actions

Within weeks, a district court in New Hampshire provisionally certified a nationwide class of children who would be denied citizenship under the order and preliminarily enjoined its enforcement as to the class. The Supreme Court reviewed that case on certiorari before judgment and affirmed, holding the order unconstitutional (Trump v. Barbara, 609 U.S. ___ (June 30, 2026)). A class judgment binds the whole class, so class relief can reach far beyond the named plaintiffs without being “universal.” For some immigration provisions, classwide injunctions remain barred by 8 U.S.C. § 1252(f)(1).

2. Vacatur under the Administrative Procedure Act

When the challenged policy is an agency action, a court can “hold unlawful and set aside” it under 5 U.S.C. § 706(2). Setting a policy aside removes it for everyone. In August 2026 a federal court in New York vacated the State Department’s pause on immigrant visas for nationals of 75 countries (CLINIC v. Rubio (S.D.N.Y. Aug. 21, 2026)). See Vacatur: the Order That Sets a Rule Aside.

3. Party-specific relief

Some courts, finding a policy unlawful, now limit relief to the parties. In Ivanov v. Trump, No. 26-cv-915 (D.D.C. Aug. 25, 2026), the court held the diversity-visa pauses unlawful under the APA but enjoined them only as to the named plaintiffs and their derivative beneficiaries.

4. Suits by states

States that sue argue that complete relief for them requires broader orders, a question CASA left for the lower courts.

Why it matters to an individual

Before CASA, a person affected by a national policy could often rely on someone else’s universal injunction. Now protection depends on the vehicle: being a member of a certified class, being covered by a vacatur of the policy, or being a party. Whether a particular order reaches a particular person has to be read from the order itself.

Sources

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