Background: What Happened in Trump v. CASA, Inc.
The U.S. Supreme Court issued a major ruling in Trump v. CASA, Inc. that reshapes how federal courts handle injunctions. The Court ruled 6-3 that federal district courts generally cannot issue universal injunctions under the Judiciary Act of 1789.
The case arose from challenges to President Trump’s Executive Order No. 14160, which aimed to restrict birthright citizenship for children born in the U.S. to non-citizen parents. Several district courts had blocked enforcement of this order, issuing preliminary injunctions that applied not only to the plaintiffs but also to others outside the lawsuit, essentially universal injunctions. The government sought to stay these injunctions during appeals.
The Supreme Court focused solely on whether district courts have the authority to issue such sweeping, universal injunctions. It did not decide on the legality of the executive order itself, which remains under litigation.
The Court’s Reasoning: Limiting District Courts’ Power
Justice Barrett wrote the majority opinion, joined by Chief Justice Roberts and Justices Thomas, Alito, Gorsuch, and Kavanaugh. The Court examined the Judiciary Act of 1789, which gives federal courts jurisdiction over suits in equity and the power to grant equitable remedies known at the nation’s founding.
Here’s the thing: the Court found that universal injunctions have no historical equivalent in early American or English equity practice. Instead, such injunctions emerged only in the 20th century, well after the Judiciary Act was passed. Therefore, federal district courts lack authority under that Act to issue universal injunctions.
The majority also dismissed dissenting views that historical “bills of peace” justified universal injunctions. It held that those were more like modern class actions, which focus on parties within the lawsuit—not on third parties. The Court emphasized that equitable relief is meant to fully address the claims of the parties involved, but not to bind nonparties.
Additionally, the Court flagged practical downsides to universal injunctions, such as encouraging forum shopping and rushing courts to decide complex issues under pressure.
What This Means: Narrower Injunctions and Ongoing Litigation
The Court partially stayed the district courts’ universal injunctions, meaning injunctions can still protect the individual plaintiffs but cannot automatically extend to everyone affected by the order. It also allowed executive agencies to proceed with public guidance related to the order.
Lower courts must now carefully tailor injunctions to the parties before them, offering “complete relief” only to those with standing.
Broader Impact and Alternative Paths to Relief
What this really means is that universal injunctions are off the table as a general remedy, but other legal tools remain.
- Class Actions: Plaintiffs can still seek broad relief through class action lawsuits under Federal Rule 23. This requires meeting specific criteria like commonality and adequacy of representation, which can be a high bar.
- Administrative Procedure Act (APA): The Court did not rule on whether courts can vacate unlawful federal agency actions under the APA. Vacatur effectively nullifies a regulation for everyone, not just the parties, offering a kind of universal remedy without relying on injunctions.
- State Plaintiffs: States suing for their own injuries may still obtain relief that benefits their residents, including nonparties.
The ruling limits the use of universal injunctions but leaves intact other mechanisms that can produce broad legal effects.
Final Takeaway
This decision shifts how courts handle nationwide relief, especially in challenges to federal statutes or executive orders. It signals more focused, case-specific injunctions rather than sweeping bans. Businesses and individuals affected by federal actions should pay close attention to evolving litigation strategies and alternative avenues for broad relief.
