Trump v. CASA, Inc. (2025): The Supreme Court Reins in Universal Injunctions
June 27, 2025
Trump v. CASA, Inc., 606 U.S. ___ (2025)
On June 27, 2025, the U.S. Supreme Court issued a landmark decision in Trump v. CASA, Inc., 606 U.S. ___ (2025), placing sharp limits on the authority of federal courts to issue universal injunctions—orders that bar the government from enforcing a law or policy against anyone, not just the plaintiffs in the case. In a 6–3 opinion authored by Justice Amy Coney Barrett, the Court held that such sweeping injunctions “likely exceed the equitable authority that Congress has given to federal courts.”
While the Court did not reach the merits of President Trump’s Executive Order No. 14160, which reinterpreted the Citizenship Clause of the Fourteenth Amendment, the decision has profound implications for federal judicial power, equitable remedies, and the separation of powers doctrine.
Background: Executive Order 14160 and the Challenge from CASA, Inc.
President Trump’s Executive Order No. 14160, titled Protecting the Meaning and Value of American Citizenship, was issued in early 2025 and published at 90 Fed. Reg. 8449. It sought to deny U.S. birthright citizenship in two narrow—but highly controversial—circumstances:
When the child’s mother was unlawfully present in the U.S. at the time of birth and the father was neither a U.S. citizen nor lawful permanent resident; or
When the mother’s presence was lawful but temporary (e.g., on a student visa or tourist visa) and the father also lacked citizenship or lawful permanent residency.
The executive order sparked immediate constitutional challenges. Plaintiffs across three jurisdictions—including individuals, advocacy organizations like CASA, Inc., and the states of Washington, New Jersey, and Massachusetts—filed suit seeking to enjoin enforcement. Federal district courts in Maryland, Washington State, and Massachusetts all granted nationwide or “universal” preliminary injunctions, barring the government from enforcing the Executive Order against anyone in the United States, not just the named plaintiffs.
When the federal government sought to stay the injunctions pending appeal, the U.S. Courts of Appeals in the First, Fourth, and Ninth Circuits denied relief. The government then filed emergency applications for partial stays with the Supreme Court in Trump v. CASA, Inc. (24A884), Trump v. Washington (24A885), and Trump v. New Jersey (24A886), arguing that the lower courts lacked authority to issue such far-reaching relief.
The Question Presented: Can Federal Courts Issue Universal Injunctions?
Notably, the Supreme Court declined to address the underlying constitutionality of Executive Order 14160. Instead, it limited its review to the narrow—yet pivotal—remedial question:
“Whether, under the Judiciary Act of 1789, federal courts have equitable authority to issue universal injunctions.”
In granting the government’s applications for partial stays, the Court held that district courts may only enjoin enforcement of a law or policy to the extent necessary to provide complete relief to the plaintiffs before them. A federal court cannot prohibit the government from enforcing a law against nonparties—no matter how similar their interests or injuries may be.
Justice Barrett’s Majority Opinion: Equity Rooted in History
Justice Barrett’s opinion relies heavily on the Court’s 1999 decision in Grupo Mexicano de Desarrollo, S.A. v. Alliance Bond Fund, Inc., which held that equitable remedies authorized by the Judiciary Act of 1789 are limited to those “traditionally accorded by courts of equity” at the time of the founding.
Key points from the Court’s reasoning:
🔹 1. No Historical Basis for Universal Injunctions
The Court emphasized that English chancery courts at the founding did not issue anything resembling modern universal injunctions. Equitable relief was strictly party-specific, and courts lacked authority to bind nonparties.
“As a general rule, an injunction could not bind one who was not a party to the cause.”
— Trump v. CASA, Inc., Slip op. at 7
The Court found that the “bill of peace”, an early equitable tool cited by the plaintiffs and dissenters, was not analogous to modern universal injunctions. Those bills were limited to small, cohesive groups and evolved into today’s Rule 23 class actions, which contain built-in procedural safeguards. Universal injunctions, by contrast, circumvent Rule 23 and its protections.
🔹 2. Complete Relief ≠ Universal Relief
The Court rejected the argument that universal injunctions are merely a form of “complete relief.” Instead, it drew a bright-line distinction: relief is “complete” when it remedies the injury to the plaintiff, not when it extends to similarly situated nonparties.
“Prohibiting enforcement of the Executive Order against the child of an individual pregnant plaintiff will give that plaintiff complete relief. Extending the injunction to cover everyone similarly situated would not render her relief any more complete.”
— Slip op. at 17
🔹 3. Policy Arguments Are Irrelevant to Judicial Power
While acknowledging competing policy views (e.g., concerns about uniformity or administrative burden), the Court declined to weigh them. Judicial remedies, it held, must derive from legal authority, not policy convenience.
“As with most questions of law, the policy pros and cons are beside the point.”
— Slip op. at 21
Concurring Opinions: Structural Concerns About Judicial Overreach
Three separate concurring opinions—by Justices Thomas, Alito, and Kavanaugh—voiced concern that universal injunctions encroach upon the separation of powers, giving unelected judges the ability to halt federal policy nationwide after a single district court ruling.
Justice Thomas reiterated his long-standing view, first raised in Trump v. Hawaii (2018), that universal injunctions:
Invite forum shopping;
Incentivize judicial grandstanding;
And improperly elevate district courts to de facto national policymakers.
Dissenting Opinions: A Sharp Rebuttal from the Liberal Wing
🔸 Justice Sotomayor (joined by Justices Kagan and Jackson)
Justice Sotomayor’s dissent warned that the majority’s ruling undermines the judiciary’s ability to serve as a check on executive overreach, especially in constitutional cases affecting widespread groups. She criticized the majority for “freezing equity in amber” and ignoring the practical need for universal relief in cases involving immigration, reproductive rights, and civil liberties.
“There may be good reasons not to issue universal injunctions in the typical case. But when the injury at stake is both sweeping and urgent, equity must retain the ability to prevent irreparable harm.”
🔸 Justice Jackson (separately dissenting)
Justice Jackson criticized the entire framing of the issue as an overly technical inquiry into historical analogues. She framed the court’s role more broadly as an institution that “tells the Executive what the law is and requires it to obey.”
Her dissent took aim at what she viewed as the majority’s retreat from meaningful judicial enforcement of constitutional rights.
Practical Impact: A New Era for Equitable Relief
The decision in Trump v. CASA, Inc. is arguably the most consequential case on judicial remedies and equitable power in decades. Key takeaways for practitioners:
✅ Limits on District Court Power
Trial courts can no longer issue injunctions that prevent federal policies from applying to nonparties. This will:
Prevent single-judge forums from controlling national policy;
Require individualized or class-based relief;
Push more plaintiffs toward formal Rule 23 class actions.
✅ Strategic Shifts in Public Interest Litigation
Organizations bringing systemic challenges—e.g., in immigration, environmental, or healthcare cases—will need to tailor their injunctive requests more narrowly or proceed as certified class actions.
✅ Acceleration of Appeals
The ruling encourages the Executive Branch to bypass lower courts when confronted with broad injunctions and seek narrowing stays from appellate courts or the Supreme Court.
Conclusion: A Watershed Moment for Separation of Powers
Trump v. CASA, Inc. reshapes the remedial landscape of constitutional litigation. In anchoring judicial power to historical equitable practices, the Court decisively rolled back the use of universal injunctions that had surged in recent administrations. The decision reasserts the principle that federal courts are not legislatures, and their authority to halt government action must be grounded in the relief necessary to redress the injuries of those actually before the court.
For attorneys, policymakers, and public interest advocates, the message is clear: universal relief is no longer within reach unless procedurally authorized, such as through a properly certified class action. The future of equitable litigation will be more restrained, more party-specific, and—perhaps—more faithful to the constitutional separation of powers.