Justices rule universal injunctions exceed traditional equitable authority under the Judiciary Act
Supreme Court of the United States
Trump v. CASA, Inc.
606 U.S. 831
In Trump, President of the United States, et al. v. CASA, Inc., et al., No. 24A884 (decided June 27, 2025), the Supreme Court considered whether federal courts have the authority to issue universal injunctions—that is, injunctions that prohibit the government from enforcing a law or policy against anyone, not just the plaintiffs before the court.
The controversy arose after several individuals, organizations, and States filed lawsuits challenging President Trump’s Executive Order No. 14160, titled Protecting the Meaning and Value of American Citizenship, 90 Fed. Reg. 8449. The Executive Order sought to define circumstances in which a person born in the United States would not be considered “subject to the jurisdiction thereof” and therefore not entitled to automatic citizenship. Plaintiffs argued that this order violated both the Fourteenth Amendment’s Citizenship Clause and §201 of the Nationality Act of 1940.
In each case, the District Court agreed with the plaintiffs, finding the Executive Order likely unlawful, and issued a universal preliminary injunction that barred federal officials from enforcing the order against anyone in the country. The Courts of Appeals declined to narrow those injunctions when the Government sought a stay. The Government then filed emergency applications asking the Supreme Court to limit the injunctions to the plaintiffs who actually brought the lawsuits. Importantly, the Government did not ask the Court to decide whether the Executive Order itself was constitutional. The sole question was whether the federal courts possessed equitable authority under the Judiciary Act of 1789 to issue such nationwide or universal injunctions.
The Court held that they likely do not. Writing for the majority, Justice Barrett reasoned that Congress, through the Judiciary Act of 1789, granted federal courts equitable power only to the extent that such power existed in the English Court of Chancery at the time of the founding. Traditional equity, both in England and in early American practice, provided remedies that were party-specific—relief directed at those who were actually before the court. Historical sources and early American precedents showed no example of an injunction that bound the government with respect to persons who were not parties to the litigation.
In the eighteenth and nineteenth centuries, equitable suits were intended to resolve disputes between particular parties, and injunctions were limited to those parties. For example, in Scott v. Donald (1897), where a plaintiff successfully challenged a state law, the Supreme Court allowed relief only for that plaintiff, not for others who might be affected by the same law. Later decisions, such as Frothingham v. Mellon and Doran v. Salem Inn, Inc., reaffirmed that injunctive and declaratory relief generally apply only to the plaintiffs before the court.
Because universal injunctions have no historical analogue in equity, the Court concluded that federal courts lack statutory authority to issue them. Justice Barrett explained that while equity is flexible, that flexibility operates “within the boundaries of traditional equitable relief.” Universal injunctions, which extend relief to nonparties nationwide, exceed those boundaries.
The respondents attempted to justify universal injunctions by analogy to historical “bills of peace,” an equitable device used to resolve disputes involving small, cohesive groups. The Court rejected this argument, noting that a bill of peace bound all members of a defined group and more closely resembled the modern class action under Federal Rule of Civil Procedure 23—a procedure that includes safeguards and requirements absent from universal injunctions. To allow universal injunctions would be to bypass Rule 23’s procedural protections entirely.
Respondents also argued that universal injunctions were necessary to grant “complete relief.” The Court disagreed, clarifying that “complete relief” means full relief for the parties before the court, not relief for all others who might be similarly situated. For example, an individual plaintiff would receive complete relief if the Executive Order could not be applied to her or her child; extending that protection to everyone else in the country would not make her relief any more complete.
The States raised a more complex argument, contending that partial relief would not remedy their administrative and financial injuries because of the interstate movement of citizens and federally funded benefits. The Court left these questions for the lower courts to address, suggesting that narrower injunctions might still adequately protect the States’ interests.
In granting the Government’s request for a partial stay, the Court emphasized that broad injunctions against the federal government cause irreparable harm by intruding on the Executive Branch’s ability to implement its policies nationwide. The balance of equities favored the Government: limiting the injunctions would still protect the plaintiffs while preventing unnecessary restrictions on executive enforcement.
The Court concluded that when the Executive Branch acts unlawfully, the proper remedy is not for the Judiciary to exceed its own authority. Therefore, the Government’s applications for partial stays were granted, narrowing the injunctions to apply only as far as necessary to protect the plaintiffs with standing.
Justice Barrett delivered the opinion of the Court, joined by Chief Justice Roberts and Justices Thomas, Alito, Gorsuch, and Kavanaugh. Justice Thomas filed a concurrence joined by Justice Gorsuch; Justice Alito also concurred, joined by Justice Thomas; and Justice Kavanaugh wrote separately. Justice Sotomayor dissented, joined by Justices Kagan and Jackson, and Justice Jackson filed a separate dissent.
In essence, the Court reaffirmed that federal judicial power extends only as far as historically recognized equitable principles allow. Universal injunctions, lacking historical precedent and structural limits, were found to exceed that power.
TRUMP, PRESIDENT OF THE UNITED STATES,
et al. v. CASA, INC., et al.
on application for partial stay
No. 24A884. Argued May 15, 2025—Decided June 27, 2025
