| Trump v. CASA, Inc. | |
|---|---|
 | |
| Argued May 15, 2025 Decided June 27, 2025 | |
| Full case name | Donald J. Trump, President of the United States, et al., Applicants v. CASA, Inc., et al. |
| Docket no. | 24A884 |
| Citations | 606U.S. 831 (more) |
| Argument | Oral argument |
| Decision | Opinion |
| Questions presented | |
| Can a district court issue anationwide (universal) injunction that blocks enforcement of a federal executive order beyond the specific parties involved in the lawsuit? | |
| Holding | |
| Universal injunctions likely exceed the equitable authority that Congress has given to federal courts. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Barrett, joined by Roberts, Thomas, Alito, Gorsuch, Kavanaugh |
| Concurrence | Thomas, joined by Gorsuch |
| Concurrence | Alito, joined by Thomas |
| Concurrence | Kavanaugh |
| Dissent | Sotomayor, joined by Kagan, Jackson |
| Dissent | Jackson |
| Laws applied | |
| Judiciary Act of 1789 | |
| Part ofa series on the |
| Immigration policy of the second Trump administration |
|---|
Targeting of U.S. citizens |
Targeting of immigrants
|
|
Controversies |
Trump v. CASA, Inc.,606 U.S. 831 (2025), is aUnited States Supreme Court case addressing whether lower-court judges have the authority to issue "universal injunctions" to block the enforcement of policies nationwide. On June 27, 2025, the Court ruled in a 6–3 decision that universal injunctions exceed the judiciary power unless necessary to provide the formal plaintiff with "complete relief". Writing for the majority, JusticeAmy Coney Barrett emphasized that "complete relief" for a plaintiff was distinct from "universal relief" impacting all similar situations nationwide.
While the case did not directly addressbirthright citizenship in the United States, it centered on several universal injunctions blockingExecutive Order 14160, an order issued by PresidentDonald Trump to redefine the government's understanding of theCitizenship Clause. Threedistrict court judges issued universal preliminary injunctions to block the order nationwide while cases that they presided over proceeded through the legal system.
The government appealed each case to the Supreme Court, arguing that district judges should only be allowed to prevent a policy from taking effect for the specific challengers filing a given lawsuit. The Supreme Court consolidated the appeals intoTrump v. CASA. In its ruling, the Court issued partial stays on existing injunctions except for those that were parties to the cases.
The opinion did not address the constitutionality of the birthright citizenship executive order and left open the ability for plaintiffs to pursue class-wide relief throughclass action lawsuits.
As a presidential candidate,Donald Trump stated that he would endbirthright citizenship in the United States.[1] After hissecond inauguration, he signedExecutive Order 14160, "Protecting the Meaning and Value of American Citizenship", which ordered alldepartments of the executive branch to refuse to recognize children born to illegal immigrants or visa holders as citizens.[2] An estimated 150,000 such children are born in the United States each year.[3]
The order was quickly blocked by multiple universalpreliminary injunctions issued bydistrict court judges.[4] In addition to the three cases consolidated intoTrump v. CASA, the executive order was also blocked by JudgeJoseph Normand Laplante inNew Hampshire Indonesian Community Support v. Trump.[5] Including these orders, as of May 14, 2025 there had been 39 injunctions issued against the second Trump administration blocking actions such as mass federal employee layoffs, federal funding freezes, and deportations.[6]
The administration viewed each injunction asjudicial overreach and argued lower-court judges should only be allowed to block a contested policy from affecting the actual plaintiffs involved in the case.[3][6] Neither side of the dispute briefed the Supreme Court justices on the constitutionality of Executive Order 14160.[3]
Eighteen states and two cities (San Francisco andWashington, D.C.) filed a lawsuit in theDistrict Court for the District of Massachusetts asNew Jersey v. Trump. Four other states filed a second lawsuit,Washington v. Trump, in theDistrict Court for the Western District of Washington.[7][8] A third lawsuit, by immigrant and asylum-seeker rights groupsCASA de Maryland and the Asylum Seeker Advocacy Project, was filed in theDistrict Court for the District of Maryland on behalf of five pregnant women.[9]
Federal judges in each of the district courts issuedpreliminary injunctions to block the order from taking effect anywhere in the country.[4] JudgeJohn C. Coughenour, presiding overWashington v. Trump, called the order "blatantly unconstitutional".[2] Government appeals challenging the injunctions were rejected by theCourt of Appeals for the Ninth Circuit, theCourt of Appeals for the Fourth Circuit, and theCourt of Appeals for the First Circuit.[4]
On April 17, theSupreme Court agreed to hearTrump v. CASA, consolidating it withTrump v. New Jersey andTrump v. Washington and setting oral arguments for May 15.[10]
Oral arguments were heard on May 15, with the solicitor general of the United States,D. John Sauer, representing the administration; Kelsi B. Corkran, for the immigrant groups, including CASA;[11] andJeremy Feigenbaum, the solicitor general of New Jersey, for the various states.[12]
On June 27, the Supreme Court ruled 6–3 that, “Universal injunctions likely exceed theequitable authority that Congress has given to federal courts."[13]
JusticeAmy Coney Barrett wrote the majority opinion. Barrett’s opinion did not declare universal injunctions unconstitutional, but concluded that they were an overreach based on theJudiciary Act of 1789 and inconsistent with "historical equitable practice".[14] Barrett wrote that "the equitable relief available in the federal courts" should be akin to what was "'traditionally accorded bycourts of equity'" at the time of thefounding of the United States,[14] quoting the Supreme Court's holding inGrupo Mexicano de Desarrollo, S.A. v. Alliance Bond Fund, Inc. (1999).[15]
The Court granted the government a partialstay of the injunctions blocking Executive Order 14160, but "only to the extent that the injunctions are broader than necessary to provide complete relief to each plaintiff with standing to sue."[13] They specified that the executive order could not take effect until 30 days after the ruling.[16]
Barrett acknowledged the importance of providing "complete relief" to plaintiffs seeking an injunction, but said "complete relief" was a narrower concept than "universal relief". Barrett wrote that a pregnant mother would receive complete relief as long as herown child was not denied citizenship. "Extending the injunction to cover all other similarly situated individuals would not renderher relief any more complete," Barrett continued.[17]
However, the Court left it to the "lower courts [to] determine whether a narrower injunction is appropriate" with respect to the states suing the administration.[17] The states had argued that only a universal injunction would provide them with complete relief, because tracking the immigration statuses and residences of parents moving between states before providing a newborn with mandated benefits would be administratively complex.[17]
The Court's ruling left open the ability for plaintiffs to seek widespread relief by filingclass action lawsuits.[18]
JusticesClarence Thomas,Samuel Alito, andBrett Kavanaugh filed concurrences. JusticeNeil Gorsuch joined Thomas's concurrence and Thomas joined Alito's concurrence.[19][20]
Thomas's concurrence explicitly stated that the Court's decision ended the practice of district courts issuing universal injunctions and emphasized the need to create remedies specifically tailored to the parties in a case.[21]
Kavanaugh wrote that plaintiffs may still request the "functional equivalent of a universal injunction" by filing "statewide, regionwide, or even nationwide"class action lawsuits.[20]
Alito opined that the Court's decision may be undermined if states assertthird-party standing to obtain broad injunctions on behalf of their residents, or if district courts award injunctions to loosely defined classes in class action lawsuits. He urged lower courts to be vigilant against potential abuses of these methods.[22][21]
JusticeSonia Sotomayor filed a dissent which was joined by JusticesElena Kagan andKetanji Brown Jackson. Sotomayor argued the government had avoided requesting a complete stay of the injunctions because doing so would require them to prove Executive Order 14160 was likely constitutional. She wrote, "The gamesmanship in this request is apparent, and the Government makes no attempt to hide it."[23]
Jackson also filed a separate dissent, in which she wrote:[24][25]
When the Government says 'do not allow the lower courts to enjoin executive action universally as a remedy for unconstitutional conduct,' what it is actually saying is that the Executive wants to continue doing something that a court has determined violates the Constitution—please allow this. That is some solicitation. With its ruling today, the majority largely grants the government's wish.
Barrett criticized Jackson's dissent, writing that "Justice Jackson decries an imperial Executive while embracing an imperial Judiciary."[25]
Within hours of the Supreme Court ruling, CASA de Maryland filed a motion in their existing district court case in Maryland, asking JudgeDeborah Boardman to certify a class of children born to immigrant parents who would be ineligible for birthright citizenship under Executive Order 14160.[26] TheAmerican Civil Liberties Union filed anotherclass action suit in New Hampshire the same day.[27] In the latter case, JudgeJoseph Laplante granted the class action request on July 10, 2025, and issued an injunction blocking the government from depriving the citizenship of those covered by the class action.[28]
Trump filed a petition to the Supreme Court in September 2025 to specifically review if his EO challenging birthright citizenship violates the Constitution, based on the Washington case and the ACLU case filed in New Hampshire.[29] Twenty-five states, including Florida, Georgia, Texas, Tennessee, and Missouri, wrote an amicus brief urging the Supreme Court to take the case and limit the interpretation of the Fourteenth Amendment from the prior court decision in the 1898 caseUnited States v. Wong Kim Ark. The states argue that the court should use interpretation of the law from theReconstruction era instead.[30] The Supreme Court grantedcertiorari to Trump's petition and will hear that challenge during the 2025 term.[31]
