For much of the last decade, a single federal district judge could block a national immigration policy for everyone in the country. These orders, called nationwide or universal injunctions, were used against policies of several administrations. In June 2025, the Supreme Court sharply limited them. Yet in 2026, courts still blocked some immigration rules nationwide. This guide explains why both things are true.
What a universal injunction was
An injunction is a court order telling someone to do or stop doing something. A universal injunction told the government not to enforce a policy against anyone, not only against the people or groups who sued. A plaintiff in one state could therefore stop a federal rule in all fifty.
Supporters said this avoided a patchwork of rules and protected people who could not sue. Critics said it let a single judge override national policy and encouraged challengers to file in favorable courts.
What the Supreme Court decided in Trump v. CASA
On June 27, 2025, the Supreme Court decided Trump v. CASA, a case about injunctions against the birthright citizenship Executive orderA directive from the President to federal agencies and officials about how to run the executive branch and carry out the law. Executive orders are numbered and published in the Federal Register, and they generally bind the executive branch.See it in the glossary. By a 6 to 3 vote, the Court held that federal courts lack authority under the Judiciary Act of 1789 to issue injunctions that give relief to people who are not parties to the case. Courts may grant only the relief needed to give “complete relief” to the plaintiffs before them.
The Court did not decide whether the birthright citizenship order was lawful. It addressed only the scope of the injunctions. The merits came back to the Court in 2026, when it struck the order down in Trump v. Barbara.
What broad relief is still available
CASA left several routes open, which a Congressional Research Service report described in its July 2026 review of the decision’s first year:
Complete relief that happens to be broad
Sometimes giving plaintiffs complete relief requires an order that reaches beyond them. A state plaintiff, for example, may argue that it cannot be protected without a broader order.
Class actions
A court can certify a class of people in the same situation and grant relief to the whole class. After CASA, a New Hampshire judge certified a class of children affected by the birthright citizenship order and blocked it as to that class. That class case became Trump v. Barbara.
Relief under the Administrative Procedure Act
CASA expressly did not decide whether courts can set aside agency rules for everyone under the Administrative Procedure Act. Under 5 U.S.C. 706, courts can “set aside” unlawful agency action, and under 5 U.S.C. 705 they can postpone a rule’s effective date. Because a rule is either in effect or not, these remedies can operate nationwide in practice.
Why the student rule was blocked nationwide
The September 14, 2026 order on the Duration of status (D/S)The period of stay for F, J and I nonimmigrants, who are admitted for as long as they maintain their program or activity rather than until a fixed date. It appears as D/S on Form I-94.See it in the glossary rule is an example. The court postponed the rule’s effective date under section 705, and applied the order nationwide because it found it unworkable for schools to run under different systems depending on location, according to CUPA-HR. That was not a universal injunction in the CASA sense; it was relief aimed at the rule itself. Our explainer on the student order covers what it means for F-1 and J-1 holders.
What the numbers show
The CRS report tracked Nationwide injunctionA court order that blocks enforcement of a rule or policy for everyone, not only the parties to the case. In Trump v. CASA, decided June 27, 2025, the Supreme Court held that the Judiciary Act of 1789 does not authorize federal courts to issue injunctions broader than needed to give the parties complete relief, while leaving other paths to wider relief open.See it in the glossary issued in the year after CASA. It found that courts continued to issue some, and that appellate courts had stayed a small share of them as of June 27, 2026. The report also noted a shift toward APA VacaturA court order that cancels an agency rule or action and removes its legal effect. Under the Administrative Procedure Act, 5 U.S.C. 706, courts set aside agency action found to be unlawful, which is traditionally treated as vacatur. Whether vacatur can reach beyond the parties to a case is disputed after Trump v. CASA.See it in the glossary and class actions, which can achieve similar results through different legal routes.
What this means for people affected by a policy
- Check who is covered. An order may protect only named plaintiffs, members of an organization, residents of certain states, or a certified class.
- Check the legal basis. An order setting aside a rule under the APA usually protects everyone; an injunction may not.
- Check for appeals. An appeals court can stay an order, letting the policy take effect again while the case continues.
- Follow agency notices. Agencies usually post instructions describing how they will comply and for whom.
An example of narrow relief
In September 2026, a federal judge set aside the DHS rule ending automatic employment authorization extensions only as to seven H-4 spouses who sued, as we reported. Other H-4 spouses in the same situation were not covered by that order. That is what party-specific relief looks like in practice.
The bigger picture
CASA changed the tools, not the fact that courts review immigration policies. A policy can still be blocked broadly, but the path now runs through class actions and challenges to agency rules more often than through a single universal injunction. For the reasons courts rule against agencies, see why federal courts block immigration rules.
Where the debate goes next
Several questions remain open after CASA. Courts and commentators are still debating how far “complete relief” to states can reach, how readily judges should certify nationwide classes in immigration cases, and whether vacatur under the Administrative Procedure Act should apply to everyone. The Supreme Court expressly left the last question for another day. Until it answers, the scope of relief will keep varying by case, and individuals should check each order rather than assume that a blocked policy is blocked for them.
Common questions
Can a state still get a nationwide order after CASA?
Sometimes. The Court allowed relief broad enough to give plaintiffs complete relief, and states have argued that protecting themselves requires broader orders. The scope is decided case by case.
Did CASA end all nationwide immigration rulings?
No. It limited universal injunctions but left open class-wide relief and relief under the Administrative Procedure Act, which is why some rules are still blocked nationwide.
How do I know if I am in a protected class?
The court’s class certification order defines the class. Agencies and plaintiffs’ lawyers often publish plain-language descriptions of who is covered.
Why does the scope of an order matter so much?
Because two people in the same situation can be treated differently depending on whether they are covered. Checking coverage before filing or traveling avoids surprises.