The US Supreme Court ruled on 27 June 2025 in Trump v. CASA, Inc. (No. 24A884) that universal injunctions, which bar the government from enforcing a policy against anyone rather than only against the parties, likely exceed the equitable authority Congress has given federal courts. By six votes to three, the Court granted the government's applications for partial stays of three such injunctions, but only to the extent they are broader than necessary to give complete relief to each plaintiff with standing, according to the Court's opinion.
The injunctions had blocked Executive Order 14160 on birthright citizenship. The applications did not raise, and the Court did not decide, whether that order is lawful under the Citizenship Clause of the Fourteenth Amendment or the Nationality Act of 1940. The only question was the scope of the remedy.
The Court's reasoning
Writing for the majority, Justice Barrett held that the Judiciary Act of 1789 authorises only the kinds of equitable remedies traditionally available from courts of equity at the founding, and that universal injunctions have no sufficiently analogous historical counterpart. Relief in equity was party-specific, and the Court found that universal injunctions were absent for most of the nation's history. The Court rejected the analogy to the old "bill of peace", holding that its modern successor is the class action under Rule 23 of the Federal Rules of Civil Procedure, whose procedural protections universal injunctions would circumvent. It also distinguished "complete relief" between the parties, which remains available and may incidentally benefit others, from relief that is universal.
For the state plaintiffs, who argued that only nationwide relief could prevent their financial and administrative harms, the Court left it to the lower courts to decide whether narrower injunctions would be appropriate. Consistent with the Solicitor General's representation, the relevant section of the executive order may not take effect until 30 days after the opinion. Justices Sotomayor, Kagan and Jackson dissented.
What it means for businesses challenging regulation
The ruling, listed among the Court's October Term 2024 opinions, reaches well beyond citizenship. Companies and trade associations that sue to block federal rules, tariffs or executive orders can no longer expect a single district court to halt a policy nationwide simply by granting an injunction. Relief will generally protect the plaintiffs themselves, which places more weight on who joins a lawsuit, on associational standing for members, and on Rule 23 class actions. The majority expressly left open whether the Administrative Procedure Act authorises courts to vacate agency action, so challenges seeking to set aside agency rules remain a separate route.
