## Facts

- Federal immigration law renders inadmissible a noncitizen deemed “likely at any time to become a public charge,” listing factors to consider but not defining “public charge.”
- The Department of Homeland Security issued a 2019 rule interpreting “public charge” to include noncitizens likely to receive specified public benefits (including Medicaid, housing, and food assistance) above a threshold: more than 12 months in the aggregate within any 36-month period, counting each benefit separately.
- A nonprofit organization providing immigrant services and two noncitizen members sued, alleging the rule would deter benefit use, force the organization to divert resources to counseling/assistance, and harm the individuals’ ability to adjust status and remain in the United States.
- A federal district court entered a nationwide preliminary injunction barring enforcement of the rule.
- The government appealed, challenging standing, likelihood of success under the Administrative Procedure Act, and the nationwide scope of relief.

## Issues

1. Whether the nonprofit organization had Article III organizational standing based on alleged diversion of resources and programmatic changes triggered by the rule.
2. Whether the individual noncitizen plaintiffs had standing based on alleged effects on admissibility and adjustment of status.
3. Whether plaintiffs were likely to succeed on the merits of an APA challenge to the rule, including whether the rule was a permissible interpretation of an ambiguous statutory term under Chevron.
4. Whether plaintiffs satisfied the requirements for preliminary injunctive relief, including irreparable harm and the balance of equities/public interest.
5. Whether a nationwide preliminary injunction was permissible and appropriately tailored.

## Decision

- The Fourth Circuit panel reversed the nationwide preliminary injunction and remanded.
- The panel held the organization lacked organizational standing because its claimed injuries were self-inflicted programmatic and budgetary choices rather than legally cognizable injuries traceable to the rule.
- The panel held the individual plaintiffs had standing because the rule directly affected the legal standards governing their ability to remain in the United States.
- On the merits, the panel concluded plaintiffs were unlikely to succeed because the statute’s use of “public charge” was ambiguous and DHS’s interpretation fell within a reasonable range.
- The panel held plaintiffs failed to justify preliminary relief, including for lack of sufficient irreparable harm and because equities and the public interest favored allowing the Executive Branch to implement immigration policy.
- The panel held a nationwide injunction was improper at the preliminary stage and overbroad relative to providing complete relief to the plaintiffs.
- A dissent would have found organizational standing, a likelihood of success on the merits, and justification for broad relief.

## Legal Principles

- An organization lacks standing where the asserted “diversion of resources” reflects voluntary budgetary or programmatic choices rather than a compelled injury fairly traceable to government action.
- Individuals have standing when government action concretely alters the legal framework governing their immigration status and the resulting harms are traceable and redressable.
- When Congress leaves a statutory term undefined and its meaning is ambiguous, a reviewing court may uphold an agency rule if the agency’s interpretation is permissible and reasonable under Chevron.
- Preliminary injunctive relief requires a clear showing of likelihood of success and irreparable harm, and courts must also weigh equities and the public interest, giving substantial weight to the government’s interests in administering immigration laws.
- Equitable relief should be no more burdensome than necessary to provide complete relief to the plaintiffs; nationwide injunctions raise concerns about overbreadth and inter-court conflict, especially at the preliminary stage.

## Conclusion

The Fourth Circuit panel reversed a nationwide preliminary injunction against the public-charge rule, dismissing the organizational plaintiff for lack of standing, recognizing standing for individual plaintiffs, concluding the rule likely survived APA review under Chevron, and holding that preliminary and nationwide relief were unwarranted.


CASA de Maryland, Inc. v. Trump, 971 F.3d 220 (4th Cir. 2020)