In a landmark decision, the U.S. Supreme Court ruled on June 27, 2025, that federal courts generally lack the authority to block government policies from being enforced against nonparties, not just the plaintiffs in a case.
The Case and the Court’s Holding
The case, Trump v. CASA, Inc., dealt with Executive Order No. 14160, which declared that children born in the United States to mothers who were either unlawfully present or temporarily in the country, and whose fathers were not U.S. citizens or lawful permanent residents, would not be granted citizenship. Three district courts issued preliminary injunctions blocking the Order’s enforcement nationwide. The government appealed, arguing that such sweeping relief exceeded judicial authority.
Writing for the majority, Justice Barrett wrote that universal injunctions “likely exceed the equitable authority that Congress has given to federal courts” under the Judiciary Act of 1789. The Court emphasized that equitable remedies must be rooted in traditional practices of English courts at the time of the founding, and that universal injunctions have no such historical pedigree. The Court granted the government’s request to partially stay the injunctions, limiting them to only those plaintiffs with standing.
The Court rejected the argument that universal injunctions are justified as a means of affording plaintiffs “complete relief.” The Court clarified that “complete relief” refers to redressing the injuries of the plaintiffs before the court—not to remedying the alleged illegality for everyone affected. For example, enjoining enforcement of Executive Order No. 14160 against a pregnant plaintiff’s child would provide her complete relief; extending that injunction to all similarly situated individuals would not make her relief any more complete. The Court acknowledged that some injunctions may incidentally benefit nonparties, but such benefits do not transform the injunction into a universal one.
But all is not lost for those seeking to challenge government policy on a nationwide basis. Among other things, the majority explained that plaintiffs seeking broad injunctive relief can do so in a class action. Such actions impose certain procedural requirements on the representative plaintiff.
The Court did not address the legality of Executive Order No. 14160 itself. The issue will be left for the District Courts in the first instance.
Concurring Opinions
Justice Thomas, joined by Justice Gorsuch, concurred fully and emphasized that universal injunctions raise serious constitutional concerns by turning courts into de facto policymakers.
Justice Alito, joined by Justice Thomas, expressed concern that the decision could be undermined if courts allow states to assert third-party standing or use class actions to achieve similar nationwide effects. He called for stricter scrutiny of class certification and third-party standing doctrines.
Justice Kavanaugh concurred to underscore that, while district courts are now limited in issuing universal injunctions, the Supreme Court retains the power to determine the interim legal status of major federal policies through emergency applications. He emphasized the Court’s role in ensuring national uniformity during ongoing litigation.
Dissenting Opinions
Justice Sotomayor, joined by Justices Kagan and Jackson, dissented and argued that Executive Order No. 14160 was “patently unconstitutional” under the Fourteenth Amendment’s Citizenship Clause and that universal injunctions were necessary to prevent irreparable harm to newborns at risk of being denied citizenship. She criticized the majority for ignoring the historical use of broad equitable remedies and for weakening the judiciary’s ability to check executive overreach.
Justice Jackson wrote separately to warn that the majority’s decision undermined the rule of law by allowing the Executive to continue enforcing unconstitutional policies against nonparties. She described the ruling as creating a “zone of lawlessness” and a dangerous precedent that could erode constitutional protections for the most vulnerable. Perhaps the sharpest language in the entire decision was the majority’s response to Justice Jackson’s dissent. They wrote, “We will not dwell on Justice Jackson’s argument, which is at odds with more than two centuries’ worth of precedent, not to mention the Constitution itself. We observe only this: Justice Jackson decries an imperial Executive while embracing an imperial Judiciary.”
Implications
The decision in Trump v. CASA, Inc. marks a significant shift in the balance of power between the Judiciary and the Executive. By limiting the scope of injunctive relief, the Court has curtailed the ability of lower courts to halt federal policies on a nationwide basis. While the ruling did not address the constitutionality of Executive Order No. 14160 itself, it sets a precedent that will reshape how constitutional challenges to federal actions are litigated in the future.
