Trump v. CASA, Inc.

In this case, the court considered this issue: Can a district court issue a nationwide (universal) injunction that blocks enforcement of a federal executive order beyond the specific parties involved in the lawsuit?The case was decided on June 27, 2025.The Supreme Court held that Federal courts likely lack equitable authority under the Judiciary Act of 1789 to issue universal injunctions that prohibit enforcement of executive actions beyond the parties before the court. Justice Amy Coney Barrett authored the 6-3 majority opinion of the Court.Under the Judiciary Act of 1789, federal courts possess only those equitable remedies “traditionally accorded by courts of equity” at the time of the founding. The Court finds no historical precedent for universal injunctions in English equity courts or early American practice. English equity courts operated through party-specific proceedings, where relief was limited to those actually before the court. While bills of peace allowed courts to adjudicate rights of dispersed groups, these involved small, cohesive groups and bound all members—unlike universal injunctions that protect non-parties without binding them. The historical absence of universal injunctions until the mid-20th century confirms they fall outside traditional equitable authority.The complete relief principle permits courts to fashion remedies that fully redress plaintiffs’ injuries, but complete relief does not equal universal relief. Courts may award relief that incidentally benefits non-parties when necessary to provide complete relief to plaintiffs, such as in nuisance cases where divisible relief is impossible. However, prohibiting enforcement of the Executive Order against individual plaintiffs’ children provides them complete relief without requiring nationwide application. For state plaintiffs claiming administrative and financial harms, the Court remands for lower courts to determine whether narrower injunctions could provide complete relief, such as prohibiting enforcement within plaintiff states or treating affected children as eligible for federally funded benefits.Justice Clarence Thomas authored a concurring opinion, joined by Justice Neil Gorsuch, emphasizing that courts must not expand the complete relief principle to recreate universal injunctions under a different name and that relief should be tailored to redress only plaintiffs’ particular injuries.Justice Samuel Alito authored a concurring opinion, joined by Justice Thomas, warning that lax enforcement of third-party standing requirements and class certification procedures could create loopholes that undermine the Court’s holding against universal injunctions.Justice Brett Kavanaugh authored a concurring opinion explaining that while universal injunctions are improper, plaintiffs may still seek classwide preliminary relief under Rule 23(b)(2) or ask courts to set aside agency rules under the Administrative Procedure Act, and emphasizing that the Court will continue to serve as the ultimate arbiter of the interim legal status of major federal actions.Justice Sonia Sotomayor authored a dissenting opinion, joined by Justices Elena Kagan Ketanji Brown Jackson, arguing that universal injunctions have deep roots in equity’s history through bills of peace and taxpayer suits, that the Executive Order is patently unconstitutional under the Citizenship Clause, and that limiting injunctive relief will leave constitutional rights meaningful in name only for those unable to sue.Justice Jackson authored a separate dissenting opinion arguing that the majority’s decision creates an existential threat to the rule of law by allowing the Executive to violate the Constitution with respect to anyone who has not sued, effectively creating zones where executive compliance with law becomes optional rather than mandatory.The opinion is presented here in its entirety, but with citations omitted. If you appreciate this episode, please subscribe. Thank you.