In a landmark decision, Trump v. Casa de Maryland, Inc., 598 U.S. ___ (2025), the Supreme Court held that federal courts lack the authority to issue universal injunctions—orders that prohibit the government from enforcing a law or policy against anyone beyond the specific plaintiffs in a case. The decision arose from challenges to Executive Order No. 14160, which addressed birthright citizenship interpretations for certain children born in the United States. Lower courts had issued nationwide injunctions blocking the order, but the Supreme Court held that such broad relief exceeds the equitable authority granted to federal courts under the Judiciary Act of 1789.
The Court, citing Grupo Mexicano de Desarrollo S.A. v. Alliance Bond Fund, Inc., 527 U.S. 308 (1999), emphasized that equitable remedies must align with traditional practices of courts of equity at the time of the founding, which generally limited relief to the parties before the court. Universal injunctions, the Court reasoned, lack historical precedent and are inconsistent with the principles of equity. The ruling allows injunctions only to the extent necessary to provide complete relief to the plaintiffs in a case.
The majority, following principles established in Lewis v. Casey, 518 U.S. 343 (1996), acknowledged that narrower injunctions tailored to the plaintiffs’ specific injuries would provide appropriate relief and directed lower courts to reconsider their orders accordingly. The Court explicitly limited its holding to the procedural question of remedy scope, reserving judgment on the underlying constitutional questions.
The dissenting justices, citing Pennsylvania v. Wheeling & Belmont Bridge Co., 54 U.S. 518 (1852), contended that universal injunctions have historical precedent in equity and serve a crucial function in ensuring uniform application of constitutional protections. They emphasized the practical implications of limiting injunctive relief in cases involving widespread government policies.
In summary, the Court’s 6-3 decision establishes that federal courts must limit injunctive relief to what is necessary to remedy the specific plaintiffs’ injuries, marking a significant shift in the scope of judicial remedies available in challenges to federal government actions.
Justice Amy Coney Barrett, wrote for the majority opinion that,
“Some say that the universal injunction “give[s] the Judiciary a powerful tool to check the Executive Branch.” … But federal courts do not exercise general oversight of the Executive Branch; they resolve cases and controversies consistent with the authority Congress has given them. When a court concludes that the Executive Branch has acted unlawfully, the answer is not for the court to exceed its power, too.”
Justice Samuel Alito wrote in a concurring opinion that,
“Putting the kibosh on universal injunctions does nothing to disrupt Rule 23’s requirements. Of course, Rule 23 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.”
The Supreme Court’s decision in Trump v. Casa de Maryland, Inc. notably refrained from delving into the substantive debate surrounding birthright citizenship under the Fourteenth Amendment. The Court explicitly avoided addressing whether the children of undocumented immigrants are “subject to the jurisdiction thereof,” as posited by the Trump administration. Given the complexity and historical significance of the Fourteenth Amendment, it seems probable that any substantial alteration to the interpretation of birthright citizenship would necessitate a constitutional amendment. Such an amendment would address the contentious issue of citizenship for children born in the United States to undocumented immigrants, thereby providing clarity and resolution to this ongoing legal debate.
In conclusion, the Supreme Court’s decision in Trump v. Casa de Maryland, Inc. underscores a pivotal shift in the interpretation of judicial authority regarding nationwide injunctions. As Justice Amy Coney Barrett articulated in the majority opinion, federal courts are tasked with resolving cases and controversies within the limits of their congressional authority, rather than exercising broad oversight of the Executive Branch. The ruling definitively curtails the ability of district court judges to issue universal injunctions, thereby reinforcing the principle that courts must not exceed their mandate, even when addressing unlawful actions by the Executive. This decision delineates the boundaries of equitable relief, emphasizing that remedies should be strictly confined to addressing the specific injuries of the plaintiffs, thereby preserving the balance of power among the branches of government.