Docket 24A884
Trump v. Casa Inc.
DecidedJun 27, 2025
6-3decision
Source: CourtListener.
Supreme Court limits federal judges' power to issue nationwide injunctions against the Executive
What it does
The ruling holds that federal courts generally may only grant injunctive relief that protects the actual plaintiffs in a lawsuit, not the general public or nonparties. It partially stays three nationwide injunctions blocking President Trump's executive order on birthright citizenship, limiting them to apply only to the specific plaintiffs (individuals, organizations, and possibly states) rather than to everyone in the country, and sends the question of what relief the state plaintiffs need back to the lower courts.
Who benefits
The Executive Branch benefits by gaining the ability to enforce contested policies against people who have not personally sued, even while litigation continues in other courts.
Who is affected
People who are not named plaintiffs or members of a certified class action—including children potentially affected by the birthright citizenship order whose parents haven't sued—may see the executive order enforced against them despite multiple courts finding it likely unconstitutional.
Practical impact
Lower federal courts must now generally limit injunctions against executive action to the named plaintiffs, requiring parties to pursue class certification under Rule 23 to get broader relief. In the short term, the birthright citizenship executive order can take effect against children whose parents are not plaintiffs in these lawsuits or covered by the states' relief, unless further class actions or lower-court rulings on "complete relief" for the states extend broader protection.
Majority — Barrett
Joined by: Roberts, Thomas, Alito, Gorsuch, Kavanaugh
Justice Barrett, writing for the majority, reasoned that the Judiciary Act of 1789 only grants federal courts the equitable remedies that were traditionally available in English courts of equity at the time of the founding, and that nationwide injunctions have no such historical pedigree. Suits in equity were historically brought by and against individual parties, with remedies limited to those parties, and universal injunctions did not appear in American courts until the 20th century and remained rare until recently. The majority rejected the argument that "bills of peace" (a historical group litigation device) or the "complete relief" principle justify universal injunctions, explaining that complete relief means only relief necessary for the actual plaintiffs, not relief benefiting the whole public. The majority found the government likely to suffer irreparable harm from injunctions exceeding this authority, since such injunctions improperly intrude on a coexisting branch of government by blocking enforcement against nonparties. The majority left open whether narrower relief could still give the state plaintiffs "complete relief" given their claimed administrative and financial burdens, sending that question back to the lower courts, and explicitly did not address whether the birthright citizenship order itself is constitutional.
Dissent reasoning
Justice Sotomayor, joined by Justices Kagan and Jackson, argued that the executive order is patently unconstitutional under the Fourteenth Amendment's text, history, and precedent including United States v. Wong Kim Ark, and that the government could show no irreparable harm from being blocked from enforcing a plainly illegal policy. She argued equity has always been flexible and historically included remedies like bills of peace and taxpayer suits that benefited nonparties, so the majority's rigid historical test misreads equity's nature. She contended the lower courts correctly found that only nationwide injunctions could give the individual, organizational, and state plaintiffs complete relief, given cross-state movement of families and administrative burdens, and that the government's proposed narrower alternatives were unworkable and legally incompatible with federal benefits statutes. Justice Jackson, dissenting separately, argued the majority's focus on technical equity doctrine obscures the basic question of whether courts can order the Executive to follow the law at all, and warned that limiting judicial remedies to named plaintiffs creates a "zone of lawlessness" where the government can violate the constitutional rights of anyone who hasn't yet sued, disproportionately harming poor and unrepresented people.
Constitutional question
Whether federal district courts have the equitable authority under the Judiciary Act of 1789 to issue "universal injunctions" that block enforcement of a challenged executive policy against everyone nationwide, not just the parties who sued.
Precedent changed
The ruling does not overrule a specific prior Supreme Court case but relies on and reaffirms Grupo Mexicano de Desarrollo v. Alliance Bond Fund (1999) to foreclose the modern practice of universal injunctions that had developed in lower courts since the mid-20th century.