## Facts

- On January 20, 2025, President Trump issued Executive Order No. 14160, “Protecting the Meaning and Value of American Citizenship,” directing executive officials not to recognize U.S. citizenship for certain children born in the United States whom the Order deemed not “subject to the jurisdiction” of the United States.
- The Order directed agencies to deny or withhold citizenship documentation for children born after February 19, 2025 to specified categories of noncitizen parents and to adjust agency policies accordingly.
- Individuals, organizations (including CASA, Inc.), and several States filed suits in federal district courts (including in Maryland, Massachusetts, and Washington), alleging the Order conflicted with the Fourteenth Amendment’s Citizenship Clause and federal nationality statutes, including 8 U.S.C. § 1401.
- Each district court entered a preliminary injunction barring the federal government from enforcing the Executive Order against anyone nationwide, not only against the plaintiffs.
- The federal government sought relief in the courts of appeals, requesting stays or narrowing of the injunctions to the plaintiffs; the courts of appeals declined to stay or limit the injunctions.
- The government then filed emergency applications in the Supreme Court seeking partial stays, arguing that federal courts lack equitable authority to issue “universal” injunctions that protect nonparties.
- The Supreme Court consolidated the applications (including matters styled Trump v. Washington and Trump v. New Jersey) and set argument focused on the remedial question of injunction scope, not the Executive Order’s validity.

## Issues

1. Whether, under the Judiciary Act of 1789 and traditional equity practice, federal courts have authority to issue preliminary injunctions that bar enforcement of federal policies against nonparties nationwide.
2. Whether preliminary injunctive relief must be limited to what is necessary to provide complete relief to each plaintiff with standing, rather than extending to all similarly situated nonparties.
3. Whether concerns about the proper judicial role and conflicting nationwide decrees support limiting injunctions to party-based relief absent a recognized basis for broader coverage (such as class actions).

## Decision

- The Court (6–3) granted the government’s applications for partial stays of the preliminary injunctions, to the extent the injunctions were broader than necessary to provide complete relief to each plaintiff with standing to sue.
- The Court held that universal injunctions likely exceed the equitable authority Congress has given federal courts.
- The Court directed that, on remand, the lower courts must tailor any preliminary injunctions so that they extend no further than required to fully remedy the injuries of the plaintiffs before the court.
- The Court did not decide whether Executive Order No. 14160 is lawful or constitutional under the Citizenship Clause or federal nationality statutes; those merits questions remained for further proceedings in the lower courts.
- Justice Barrett wrote the Court’s opinion, joined by Chief Justice Roberts and Justices Thomas, Alito, Gorsuch, Kavanaugh, and (as to the judgment) Kavanaugh; Justices Sotomayor, Kagan, and Jackson dissented, with Justice Jackson also writing separately.

## Legal Principles

- Federal courts’ equitable remedies are tied to the forms of relief traditionally available in equity at the time of the Judiciary Act of 1789, unless Congress clearly authorizes broader remedial tools.
- Injunctive relief should be no more burdensome to the defendant than necessary to provide complete relief to the plaintiffs who have established standing.
- “Complete relief” means relief that fully redresses the plaintiffs’ injuries; it does not automatically justify relief that protects all nonparties who may be affected in similar ways.
- Universal injunctions raise separation-of-powers concerns by allowing a single district court to halt enforcement of federal policy nationwide and increase the risk of conflicting orders from different courts.
- Broader protection can be pursued through established procedures, such as class actions, or may be warranted when broader restraints are truly necessary to fully remedy a plaintiff’s injury, but nationwide coverage is not presumed as the default remedy in non-class cases.

## Conclusion

In Trump v. CASA, Inc., the Supreme Court held that district courts likely exceed their equitable authority when they issue universal preliminary injunctions barring enforcement of a federal policy against nonparties, and it granted partial stays requiring that injunctive relief be narrowed to what is necessary to provide complete relief to each plaintiff with standing, leaving the legality of Executive Order No. 14160 to be decided on the merits in the lower courts.


Trump v. CASA, Inc., 606 U.S. 831 (2025)