Trump v. CASA, Inc.
606 U. S. ____ (2025)
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Rule of Law:
Federal courts' equitable authority under the Judiciary Act of 1789 does not include the power to issue 'universal injunctions' that grant relief to nonparties, because such remedies lack a sufficient analogue in the traditional equitable powers exercised by courts at the nation's founding.
Facts:
- President Donald Trump issued Executive Order No. 14160, titled 'Protecting the Meaning and Value of American Citizenship'.
- The Executive Order established a policy to no longer recognize a person born in the United States as a citizen if their mother was unlawfully present or present on a temporary basis, and their father was not a U.S. citizen or lawful permanent resident at the time of birth.
- The policy was set to take effect 30 days after the order's issuance.
- Various individuals, organizations such as CASA, Inc., and states including Washington and New Jersey, anticipated harm from this new policy.
- The plaintiffs included pregnant women whose children would be denied citizenship under the order, organizations whose members would be affected, and states that would face increased financial and administrative burdens for social programs.
Procedural Posture:
- Individuals, organizations (including CASA, Inc.), and States (including Washington and New Jersey) filed three separate lawsuits against President Trump and other executive officials in different federal district courts.
- The plaintiffs in each case sought preliminary injunctions to block the implementation and enforcement of Executive Order No. 14160.
- Each of the three U.S. District Courts (for Maryland, Washington, and Massachusetts) entered a 'universal preliminary injunction,' barring the government from applying the Executive Order to anyone in the country.
- The Government, as appellant, appealed and requested a stay of the injunctions from the respective U.S. Courts of Appeals (for the First, Fourth, and Ninth Circuits).
- Each Court of Appeals denied the Government's request to stay the sweeping relief.
- The Government then filed three nearly identical emergency applications with the U.S. Supreme Court, seeking a partial stay to limit the injunctions' scope to only the named plaintiffs in each case.
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Issue:
Do federal courts have equitable authority under the Judiciary Act of 1789 to issue universal injunctions that prohibit the government from enforcing a law or policy against anyone, not just the parties to the case?
Opinions:
Majority - Justice Barrett
No, federal courts likely lack the equitable authority under the Judiciary Act of 1789 to issue universal injunctions. The Judiciary Act grants federal courts only those equitable powers 'traditionally accorded by courts of equity' at the nation's founding, as established in Grupo Mexicano de Desarrollo, S. A. v. Alliance Bond Fund, Inc. Universal injunctions have no historical analogue in English or early American equity practice, where remedies were generally party-specific. The respondents' proposed historical analogue, the 'bill of peace,' is unpersuasive; it was a device for small, cohesive groups and is the precursor to the modern class action (governed by Federal Rule of Civil Procedure 23), not the universal injunction. Furthermore, the principle of 'complete relief' allows courts to fashion remedies that are complete for the parties before it, not to grant relief to nonparties, even if they are incidentally benefitted.
Concurring - Justice Thomas
Yes, I agree with the majority that federal courts lack the authority to issue universal injunctions. I write separately to emphasize that the 'complete relief' principle operates as a ceiling on a court's authority, not a mandate. Courts must not distort this principle to replicate the effects of a universal injunction under the guise of providing complete relief to the plaintiffs before them. Any relief must still fall within the traditional limits of a court's equitable powers.
Concurring - Justice Alito
Yes, I join the Court's opinion but write to highlight two unresolved issues that could undermine its practical significance. First, the issue of third-party standing, particularly for states suing on behalf of their residents, could be used to obtain broader relief than an individual could. Second, district courts must not hastily certify nationwide classes under Rule 23 without rigorous analysis, as this could become a substitute for the now-prohibited universal injunction.
Concurring - Justice Kavanaugh
Yes, I join the Court's opinion, which brings needed clarity. This decision will require district courts to follow proper legal procedures, such as Rule 23 for class actions or the APA for setting aside agency rules, when awarding broad preliminary relief. I write to underscore that this case affects the 'interim before the interim,' and this Court will often remain the ultimate decisionmaker on the interim legal status of major new federal actions pending a final decision on the merits.
Dissenting - Justice Sotomayor
Yes, federal courts have the authority to issue universal injunctions, a power grounded in centuries of equitable principles. The majority ignores the patent unconstitutionality of the underlying Executive Order, which defies the Fourteenth Amendment's Citizenship Clause. The Court misreads history; equity has always been flexible, and historical remedies like the 'bill of peace' and taxpayer suits regularly provided relief to nonparties. By stripping courts of this power, the majority kneecaps the Judiciary's ability to check even the most flagrantly illegal executive actions, rendering constitutional guarantees meaningful only for those who can afford to sue.
Dissenting - Justice Jackson
Yes, federal courts must have this authority to maintain the rule of law. The majority's decision is an existential threat to this principle because it grants the Executive permission to engage in unlawful behavior toward anyone who has not yet sued. This creates a 'zone of lawlessness' where the Executive has the prerogative to disregard the law, which is antithetical to our constitutional system. The Judiciary's role is to ensure fidelity to the law for everyone, not just to dole out relief to private parties who manage to get to court.
Analysis:
This decision significantly curtails the power of a single federal district judge to halt a federal policy nationwide, a practice that had become a prominent feature of litigation against recent presidential administrations. The ruling effectively forces plaintiffs seeking broad, non-party relief to utilize more structured and demanding procedural vehicles, such as class actions under Federal Rule of Civil Procedure 23. This change will likely decrease the frequency of sudden, nationwide halts to executive policies and encourage more legal issues to 'percolate' through different appellate circuits, but it may also limit the judiciary's ability to provide a swift and complete check on executive actions deemed unlawful.
