SCOTUS: Universal Injunctions Are Done; Here’s Why That Matters to You

The Supreme Court (SCOTUS) agreed to hear a case regarding the authority of federal courts to issue universal injunctions against an executive order by President Trump related to American citizenship. In a 6–3 decision on June 27, 2025, the Supreme Court ruled on Trump v. CASA that lower courts cannot issue universal injunctions unless tailored to plaintiffs, narrowing legal relief and reshaping the birthright citizenship dispute, among other issues.

What We Know:

• On June 27, 2025, SCOTUS ruled that universal (nationwide) injunctions exceed the equitable authority granted to federal courts under the Judiciary Act of 1789. This means that courts can now only issue relief that directly applies to the plaintiffs in a case.
• The case centers on Trump’s Executive Order 14160, which sought to strip birthright citizenship from children born in the U.S. to non‑citizen parents. The Court specifically avoided addressing its (birthright citizenship’s) constitutionality and focused solely on the remedy for the case in question.
• Justice Amy Coney Barrett authored the majority opinion, emphasizing that lower courts must provide only “complete relief” to named plaintiffs, not broad, nationwide relief.
• Lower courts must now reassess their injunctions and determine whether plaintiffs require broader — but still case‑specific — remedies to ensure protection.
• The ruling furthers a trend in limiting nationwide injunctions, affecting not only immigration but also environmental, labor, and civil rights policies.
• Justice Sotomayor (joined by Kagan and Jackson) called the decision a “dangerous blow to constitutional rights.”

Deeper Dive:

President Trump issued Executive Order No. 14160, which reinterprets the 14th Amendment’s Citizenship Clause to deny birthright citizenship to certain children born in the U.S. based on their parents’ immigration status. Plaintiffs (individuals, organizations, and states) sued, arguing the order violates the 14th Amendment and the Nationality Act of 1940. Three federal district courts issued universal injunctions blocking the order nationwide. The government appealed, not challenging the constitutionality of the order, but arguing that the courts lacked authority to issue universal injunctions. Although the ruling is procedural, its implications are broad.

In a 6-3 decision, SCOTUS granted partial stays of the injunctions, limiting them to only protect the plaintiffs in each case. Justice Amy Coney Barrett wrote the majority opinion, joined by Justices Roberts, Thomas, Alito, Gorsuch, and Kavanaugh, with the dissenting opinion written by Justice Sonia Sotomayor, joined by Kagan and Jackson, with Justice Jackson writing a separate opinion. The Court declined to rule on whether Trump’s executive order violates the 14th Amendment’s Citizenship Clause, leaving that battle for future litigation.

What it did decide reshapes how that battle will be fought. Lower courts can no longer use universal injunctions to halt government action nationwide. Instead, they must determine if narrower injunctions — such as state-specific bans or class-wide protections — are sufficient to provide “complete relief.”

This decision weakens a crucial tool used by civil rights organizations, advocacy groups, and state governments to protect vulnerable populations from sweeping federal policies. The ruling ripples across many areas, limiting sweeping nationwide remedies in immigration, labor, environmental regulations, LGBTQ+ rights, and more, placing emphasis on localized, party-specific relief. The decision in Trump v. CASA may make it more difficult to challenge these policies in court. With lower courts losing leverage to halt federal policies via nationwide injunctions, the burden shifts to plaintiffs to pursue complex class litigation or appeal directly to the Supreme Court.

The majority relied heavily on historical precedent, citing 18^th– and 19^th-century practices and rejecting the idea that equity ever allowed remedies for non-parties. Referencing decisions such as Scott v. Donald and Grupo Mexicano, the Court found no tradition supporting injunctions beyond the plaintiffs themselves. Meanwhile, critics of the ruling argue that the realities of modern federal governance require broader judicial tools to ensure justice for all.

In her concurring opinion, Justice Amy Coney Barrett stated, “The universal injunction was conspicuously nonexistent for most of our Nation’s history. Its absence from 18th- and 19th-century equity practice settles the question of judicial authority.”

Reminder: The United States became an independent nation in 1776… in the 18^th century.

In her dissenting opinion, Justice Sonia Sotomayor argued, “Historical analogues are no doubt instructive and provide important guidance, but requiring an exact historical match for every equitable remedy defies equity’s purpose. Equity courts understood the ‘wisdom’ in keeping injunctive relief flexible, for it was ‘impossible to foresee all the exigencies of society which may require their aid and assistance to protect rights or redress wrongs.’”

More Quotes from the Opinion:

Concurring Opinions

• Justice Thomas: For good reason, the Court today puts an end to the “increasingly common” practice of federal courts issuing universal injunctions…Lower courts should carefully heed this Court’s guidance and cabin their grants of injunctive relief in light of historical equitable limits. If they cannot do so, this Court will continue to be “dutybound” to intervene.

• Justice Alito: Of course, Rule 23 (of the Federal Rules of Civil Procedure) may permit the certification of nationwide classes in some discrete scenarios. But district courts should not view today’s decision as an invitation to certify nationwide classes without scrupulous adherence to the rigors of Rule 23. Otherwise, the universal injunction will return from the grave under the guise of “nationwide class relief,” and today’s decision will be of little more than minor academic interest.

Dissenting Opinions

• Justice Sotomayor: No right is safe in the new legal regime the Court creates. Today, the threat is to birthright citizenship. Tomorrow, a different administration may try to seize firearms from law-abiding citizens or prevent people of certain faiths from gathering to worship. The majority holds that, absent cumbersome class-action litigation, courts cannot completely enjoin even such plainly unlawful policies unless doing so is necessary to afford the formal parties complete relief…Because I will not be complicit in so grave an at­tack on our system of law, I dissent.

• Justice Jackson: I agree with every word of Justice Sotomayor’s dissent. I write separately to emphasize a key conceptual point: The Court’s decision to permit the Executive to violate the Constitution with respect to anyone who has not yet sued is an existential threat to the rule of law…The very institution our founding charter charges with the duty to ensure universal adherence to the law now requires judges to shrug and turn their backs to intermittent lawlessness. With deep disillusionment, I dissent.

With Trump v. CASA, the Supreme Court redraws the boundaries of judicial power, raising the stakes for how and where civil rights cases — especially those involving Black, brown, and immigrant communities — can be fought.

See More: BLK ALERTS – SCOTUS Drops Five Major Rulings in a Day — Immigration, Education, Health Care, and Internet Access in the Balance