On June 27, 2025, the U.S. Supreme Court held, in a 6-3 decision in Trump v. Casa, that federal courts lack the authority to issue nationwide injunctions under the Judiciary Act of 1789 (Judiciary Act). In doing so, the Court partially stayed the nationwide injunctions issued by three district courts against the enforcement of President Donald Trump’s Executive Order (EO) targeting birthright citizenship guaranteed by the 14th Amendment of the U.S. Constitution.

By eliminating the availability of nationwide injunctions, Casa introduces uncertainty to individuals and organizations subject to a growing number of Executive Orders that have been halted by nationwide injunctions. The fate of the underlying cases remains uncertain, as district courts must grapple with the Supreme Court ruling and examine whether each injunction is broader than necessary to provide relief to each named plaintiff with standing to sue.

Background

The Casa litigation arose from EO 14160, which sought to redefine the scope of birthright citizenship by declaring that individuals born in the U.S. to mothers who were either unlawfully or only temporarily present in the country, and whose fathers were neither citizens nor lawful permanent residents, were not entitled to citizenship. Individuals, organizations and states filed three separate suits to enjoin the enforcement of the EO. District courts in Maryland, Washington and Massachusetts granted the requested relief on a nationwide basis.¹ The government appealed. On appeal the Government took the unexpected position of not appealing regarding the merits of the underlying EO, but rather only to seek partial stays of the district courts’ nationwide injunctions, arguing that such injunctions exceeded their authority under the Judiciary Act.

Writing for the majority, Justice Barrett sided with the government, holding that nationwide injunctions likely exceed the authority that Congress has given to federal courts. The Judiciary Act provides that federal courts have jurisdiction over “all suits … in equity.” As previously held by the Court, this encompasses only the sorts of equitable remedies “traditionally accorded by courts of equity” at the country’s inception.² Nationwide injunctions, the court held, are not “sufficiently analogous” to any relief available in the High Court of Chancery in England or founding-era courts of equity in the United States.

Instead, the Court held that Article III of the U.S. Constitution limits courts to resolving specific cases and controversies and that any remedy must be no broader than required to provide the plaintiffs with “complete relief.” The Court distinguished that the principle of “complete relief” is not synonymous with “universal relief.” Complete relief operates as the ceiling, and under no circumstances can a court award relief beyond what is necessary to redress the specific plaintiffs’ injuries. As the Court explained in this case, prohibiting enforcement of the EO against the child of an individual pregnant plaintiff will give that plaintiff complete relief, as her child will not be denied citizenship. However, extending the injunction to cover everyone similarly situated would not render the plaintiff’s relief any more complete.

The Court granted the Government’s request for a partial stay of the injunctions, but only to the extent that the injunctions are broader than necessary to grant complete relief to each plaintiff who had standing to sue. Therefore, the injunctions remain in effect for the named plaintiffs who filed the lawsuit; however, the lower courts are instructed to expedite their review of how these injunctions may be narrowed to comply with the principles of equity.

What Remedies Are Still Available?

While Casa has created significant limitations for litigation challenging federal statutes and executive actions on a nationwide basis, several avenues remain available:

• Complete Relief on Behalf of States: The Court recognized that the complete relief inquiry is more complicated for state respondents. In Casa, state plaintiffs argued that universal relief is necessary due to the administrative complications of individuals moving in and out of their borders. Siding with the states, the District of Massachusetts issued an injunction that did not purport to directly benefit nonparties. Instead, the lower court held that a nationwide injunction was necessary to provide the states themselves with complete relief. The government argued that there were still ways in which the injunction could have been narrowed, while still providing complete relief to the state respondents. The Court declined to address these arguments, directing the lower courts to determine whether a narrower injunction is warranted. If state respondents can successfully argue that limiting a nationwide injunction would not afford the states complete relief, some of the current nationwide injunctions could remain in place. However, the bar in achieving these injunctions is likely to be higher. Justice Alito also explained in his concurrence that while the courts allow states to assert the rights of a third party, the state itself must show that it would have Article III standing. He further cautioned that if lower courts allow states to assert third-party standing, the limits to injunctive relief could be undermined.
• Rule 23(b)(2) Class Action: All the justices agreed that class actions under the Federal Rule of Civil Procedure may be used to obtain an injunction that protects a class of individuals, and perhaps even a nationwide class, against a particular government action. However, Rule 23(b)(2) class actions are not without their limits. To certify a class, plaintiffs must demonstrate numerosity, commonality, typicality, and adequacy of the named plaintiffs to represent the class, Rule 23(a), and that the party opposing the class has acted on grounds generally applicable to all class members, Rule 23(b)(2). These requirements limit the types of cases in which preliminary injunctive relief is available, as well as the expediency of obtaining injunctive relief, as courts review the evidence to establish a proposed class.
• APA Vacatur: The Court noted that its holding does not resolve “the distinct question whether the Administrative Procedure Act authorizes federal courts to vacate federal agency action.” Section 706 of the APA provides that federal courts shall “set aside” any agency action that violates the provisions of the APA. Historically, plaintiffs have utilized the APA to achieve a “universal vacatur,” staying regulations or other government actions from taking effect pending the outcome of litigation. The Court has recently questioned whether such universal vacatur under the APA is compatible with equitable remedies under Article III. See e.g. Biden v. Texas, 597 U.S. 785 (2022). It remains an open question on how lower courts and the Supreme Court may respond to this method for potentially obtaining nationwide relief in light of Casa.

Implications On Current Litigation

During the first 100 Days of the Trump Administration, district courts issued approximately 25 nationwide injunctions blocking EOs and other government actions related to, among other things, termination of probationary federal employees, federal funding, immigration, and diversity, equity, and inclusion (DEI) programs. The lower courts in each case will now be tasked with determining whether these injunctions can be narrowed to a smaller group or a specific geographic location without compromising the protections afforded to the named plaintiffs. Organizations that have benefited from one or more of the injunctions currently in place can no longer presume that these benefits will continue to be extended to them.

Just hours after the Casa decision was issued, groups challenging the constitutionality of the birthright citizenship EO issued several new lawsuits, switching their legal actions to class action complaints.[3] Organizations should actively monitor the potential class action lawsuits that may be filed and consult with legal counsel to determine the feasibility of joining these lawsuits.

Impact on Healthcare & Life Sciences Organizations

Healthcare & Life Sciences organizations should carefully review injunctions that directly and/or indirectly affect them, including those affecting the disbursement of federal funding, grants for biomedical research, and DEI programs. We expect that several of these injunctions will be amended and may no longer benefit unnamed parties. Organizations with operations across multiple states or jurisdictions in particular will need to evaluate whether injunctive relief is likely to be limited to a particular geographic location and be on the lookout for pending class actions.

Organizations may also benefit from consulting with their State Attorneys General and respective trade associations to assess whether a State or association challenge to an EO could effectively protect their organization’s rights. State governmental bodies and organizations are uniquely positioned to develop coordinated legal strategies in response to challenging Government actions that target a broad group of citizens or organizations. 

Footnotes 

[1] CASA, Inc. v. Trump, 763 F. Supp. 3d 723 (D. Md. 2025); Washington v. Trump, No. C25-0127-JCC, 2025 WL 350361 (W.D. Wash. Jan. 28, 2025); New Jersey v. Trump, No. CV 25-10139-LTS, 2025 WL 617583 (D. Mass. Feb. 26, 2025)

[2] See Casa at 3 (citing Grupo Mexicano de Desarrollo, S.A. v. Alliance Bond Fund, Inc., 527 U.S. 308, 319 (1999)).

[3] On July 2, 2025, Judge Randolph D. Moss of the U.S. District Court for the District of Columbia issued a summary judgment decision blocking President Trump’s “Invasion” Proclamation, which sought to foreclose pathways to legal migration and asylum applications for crossing the southern border. Judge Moss also granted the Plaintiff’s motion to certify the Rule 23(b)(2) class and held that implementing the Proclamation is “not in accordance with law” under Section 706 of the APA and therefore should be vacated. The Court also concluded that this case is one of the “rare cases” where injunctive relief is required and therefore issued a “narrowly tailor[ed]” injunction to prohibit the federal defendants from implementing the Proclamation, which will have the effect of a nationwide injunction. Undoubtedly, this decision will be appealed, but serves as a roadmap for plaintiffs seeking universal relief. See Refugee & Immigrant Ctr. for Educ. & Legal Servs. v. Noem, No. CV 25-306 (RDM), 2025 WL 823987 (D.D.C. Feb. 22, 2025).