On June 27, 2025, the U.S. Supreme Court significantly limited federal courts' authority to issue nationwide injunctions in Trump v. Casa (No. 24A884). This landmark decision fundamentally reshapes federal litigation practices, particularly in cases challenging federal executive orders and regulations, by restricting injunctions strictly to parties directly involved in specific lawsuits.
A nationwide or universal injunction is a court order prohibiting the federal government from enforcing a law, regulation, or policy broadly—not limited solely to plaintiffs in a specific lawsuit. These injunctions apply across the entire country, exceeding the geographical jurisdiction of the issuing court. Despite being commonly used, the term "nationwide injunction" has been subject to debate and varied interpretations in legal scholarship and practice.
Historically uncommon, nationwide injunctions have seen increasing use over the past decade, particularly in cases involving executive orders and significant federal regulations. Supreme Court Justices including Thomas, Gorsuch, and Alito have raised concerns about their legitimacy and historical grounding.
The rise of nationwide injunctions can be traced to historical changes in judicial procedure. Initially, in 1937, Congress passed legislation requiring three-judge panels for cases challenging federal statutes, with direct appeal to the Supreme Court to limit broad judicial interventions. This system was significantly scaled back in 1976, contributing to more frequent issuance of nationwide injunctions in recent decades. Such injunctions have notably appeared in recent disputes, including those concerning the Corporate Transparency Act’s (CTA) Beneficial Ownership Information (BOI) filing requirements. While the ruling in Trump v. Casa did not specifically address the CTA, it has clear implications for future cases by emphasizing that injunctions must be tailored strictly to the parties directly involved, thereby reshaping broader judicial approaches to federal policies.
Federal courts issue several types of injunctive relief, each suited to different stages and circumstances of litigation:
In addition, courts handling agency-related cases may issue:
Although stays and vacaturs similarly halt policy implementation, they differ from injunctions by not explicitly mandating specific government actions.
The case, officially titled Trump, President of the United States, et al. v. Casa, Inc., et al. (No. 24A884), originated from three separate lawsuits filed in federal district courts by individuals, organizations, and multiple states. These plaintiffs sought to block the implementation of President Trump's Executive Order No. 14160, titled "Protecting the Meaning and Value of American Citizenship," which sought to redefine eligibility criteria for birthright citizenship under certain conditions.
Specifically, the plaintiffs—including individual respondents, advocacy organizations (such as Casa, Inc.), and a coalition of states—argued that the Executive Order violated the Citizenship Clause of the Fourteenth Amendment and certain provisions of federal law (particularly the Nationality Act of 1940). The lawsuits were filed in three federal district courts:
Each district court issued a universal preliminary injunction, preventing executive officials from enforcing the Executive Order against anyone nationwide, not just the parties who brought the suit. These broad injunctions aimed to protect all individuals potentially affected by the order, arguing it was necessary due to the nationwide implications and administrative complexities involved.
The Supreme Court reviewed whether federal courts have the equitable authority under the Judiciary Act of 1789 to issue such universal (nationwide) injunctions. Justice Barrett, writing for a majority comprising Chief Justice Roberts and Justices Thomas, Alito, Gorsuch, and Kavanaugh, emphasized that universal injunctions exceeded traditional equitable remedies historically authorized by Congress.
The Court’s majority concluded that federal courts' equitable powers must be limited strictly to the parties directly involved in litigation. The Court noted that such universal injunctions were not supported by historical equity practice, which traditionally confined relief to the parties before the court. It underscored several concerns, including forum shopping, inconsistent judicial interpretations, and the significant administrative burden that broad injunctions impose on government operations.
Ultimately, the Supreme Court held that federal district courts lack the equitable authority to issue universal injunctions that prohibit the government from enforcing laws, regulations, or executive orders against nonparties. Instead, injunctions must be specifically tailored to address only the concrete harms experienced by the plaintiffs who have demonstrated standing.
This landmark decision substantially narrows the permissible scope of judicial intervention in federal government actions, reshaping federal litigation practice. It requires litigants to carefully define their claims and relief, explicitly targeting only the direct injuries suffered by named plaintiffs.
This ruling will significantly influence future litigation, particularly impacting how challenges to broad governmental policies and executive actions are brought forward. Individual and organizational plaintiffs may be prompted to pursue class-action litigation more actively as an alternative method for obtaining broad judicial relief, given class actions' structured procedural requirements.
The decision represents a fundamental recalibration of federal judicial authority regarding nationwide injunctions, reinforcing narrow judicial remedies and reasserting traditional principles of judicial restraint and equitable relief.
Trump v. Casa significantly clarifies and constrains federal judicial authority concerning nationwide injunctions. By reinforcing equitable limitations and narrowing the scope of permissible injunctions, this ruling profoundly reshapes how federal courts handle litigation involving wide-ranging government policies, emphasizing the necessity of targeted, plaintiff-specific judicial relief.
For further analysis and insights, visit the author’s profile: Anthony O. Maceira Zayas.
For additional context and implications regarding nationwide injunctions, review the Congressional Research Service report: Nationwide Injunctions.
