Supreme Court Decides Trump v. CASA, Inc.

On June 27, 2025, the Supreme Court of the United States decided Trump v. CASA, Inc., No. 24A884, and the cases consolidated with it, holding that nationwide, universal injunctions likely exceed the equitable authority Congress has granted to federal courts; so federal district courts lack authority to issue those injunctions to the extent the injunctions purport to accord relief to persons not party to the proceedings before them.

In January 2025, the President of the United States issued Executive Order No. 14160, which expresses and directs enforcement of a federal policy deeming certain individuals born in the United States of America not to be American citizens. 

Various individuals, organizations, and States challenged the legality of that Order in at least three federal district courts ― the District of Maryland, the Western District of Washington, and the District of Massachusetts. Each of those district courts issued an order preliminarily enjoining the federal government from enforcing the Executive Order nationwide. And none of the federal Courts of Appeals granted the Government’s request to stay those preliminary injunctions. The Government then sought emergency relief from the Supreme Court via its “emergency docket,” asking that it partially stay each of the injunctions to limit application of the injunctions to the parties to the proceedings (i.e., to prevent them from applying nationwide). 

On June 27, 2025, the Court granted the Government’s request, finding the Government was likely both to succeed on its argument that federal district courts lack statutory authority to issue nationwide injunctions, and to suffer irreparable harm absent a stay of the lower courts’ orders. The Court explained that while Congress has authorized federal courts to issue equitable remedies, universal injunctions — which purport to apply to persons not party to the proceeding in which they are issued — are not the sort of equitable remedy that historically was traditionally available, and thus are not relief Congress has empowered federal district courts to issue. The Court rejected attempts to analogize universal injunctions to historical bills of peace, which it observed have instead evolved into the modern-day class action. It also disagreed that the universal injunctions the three district courts issued were necessary to accord the parties to the proceedings complete relief, though it left to the district courts the question of the scope of injunctive relief necessary to accord complete relief in each suit. And it held that policy arguments that might support the arguable necessity of universal injunctions in certain circumstances do not overcome courts’ lack of statutory authority to issue them. Because the nationwide injunctions intruded on the Executive Branch’s authority to enforce its policies against non-parties to the suits, the Court agreed that they irreparably harmed the Government. And because the requested stay would not affect application of the preliminary injunctions to the parties to the proceedings, the Court agreed the balance of the equities favored the Government.

Justice Barrett delivered the Court’s opinion. Justice Thomas filed a concurring opinion, in which Justice Gorsuch joined. Justice Alito filed a concurring opinion, in which Justice Thomas joined. Justice Kavanaugh filed a concurring opinion. Justice Sotomayor filed a dissenting opinion, in which Justices Kagan and Jackson joined. Justice Jackson also filed a dissenting opinion.