In a landmark ruling, the Supreme Court has determined that federal district courts likely lack the power to issue universal injunctions that block presidential actions across the nation.
This decision stems from the Court’s interpretation of the Judiciary Act of 1789, which it stated does not permit such sweeping equitable relief.
The ruling is expected to have significant implications for the Trump administration, allowing it to continue enforcing its executive orders in the face of legal challenges.
Despite the ruling, the Court has not made a determination regarding the constitutionality of President Donald Trump’s executive order on birthright citizenship.
In the case of Trump v. CASA, Inc., which was decided with a 6–3 majority, the Supreme Court posited that the administration is likely to prove that Congress did not grant federal district courts the equitable authority to issue universal injunctions when it enacted the Judiciary Act of 1789.
The decision emerged from three cases that were brought against President Trump’s Executive Order 14160.
This executive order stipulates that citizenship can only be conferred on children whose parents are U.S. citizens or lawful permanent residents.
Plaintiffs in these cases argued that the order violates the Citizenship Clause of the Fourteenth Amendment and Section 201 of the Nationality Act of 1940.
In response, federal district courts had issued universal injunctions to prevent the enforcement of the executive order against anyone, not just the specific plaintiffs involved.
The Trump administration sought stays of these universal injunctions but was denied by the First, Fourth, and Ninth Circuit Courts of Appeals.
Subsequently, the administration filed urgent applications with the Supreme Court, requesting that these broad injunctions be limited.
The Supreme Court underscored that the Judiciary Act of 1789 does not authorize universal injunctions, as such remedies were not part of the equity practices in the High Court of Chancery in England during the founding period.
Only relief that provides complete and specific remedies to individual plaintiffs is regarded as acceptable, according to the Court’s ruling.
The Court noted that complete relief does not equate to universal relief, stating that it “is a narrower concept” designed to address relief specifically between litigating parties.
For example, a potential injunction preventing enforcement against the child of one pregnant plaintiff would indeed provide complete relief, yet extending the injunction to cover all other similarly situated individuals would not enhance that relief.
The Court’s majority opinion emphasizes the need for courts to avoid overreaching in their remedial powers, a concern raised by the Trump administration, which argued that sweeping injunctions may compel expedited legal considerations without adequate briefing.
Despite concerns about the implications of limiting judicial authority, the Court held firmly that precedent exists to delineate the extent of equitable relief available to district courts.
Justice Sonia Sotomayor filed a dissent, joined by Justices Elena Kagan and Ketanji Brown Jackson.
She expressed concern that the Court’s ruling permits the government to impose unconstitutional orders on individuals who are not parties to a lawsuit unless they take legal action.
Justice Sotomayor argued that the majority’s conclusion renders constitutional protections nearly meaningless for those outside of formal lawsuits.
Justice Jackson further underscored the potential dangers of the decision, terming it an “existential threat to the rule of law.”
She stated that courts must possess the authority to hold everyone accountable, including the Executive, to ensure adherence to the law in all cases.
The Supreme Court’s decision in Trump v. CASA, Inc. marks a pivotal moment, granting key judicial support to the Trump administration.
This ruling allows the administration to proceed with enforcing the executive order on birthright citizenship against individuals who have not filed suit.
In doing so, it opens the door for the enforcement of other executive orders that may be facing constitutional scrutiny.
Ogletree Deakins has committed to closely monitoring the aftermath of this ruling, providing updates through its Governmental Affairs and Immigration blogs.
For further insights into how the actions of the Trump administration are impacting employers, additional resources are available on Ogletree Deakins’ New Administration Resource Hub.
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