Judicial Limits Redefined: Trump v. CASA, Inc. and the Future of Nationwide Relief

On Friday, June 27, 2025, the Supreme Court issued a landmark decision in Trump v. CASA, Inc., holding that “universal injunctions likely exceed the equitable authority that Congress has given to federal courts” under the Judiciary Act of 1789.[1] This case arose from President Trump’s Executive Order 14160 (“Executive Order”), which sought to end birthright citizenship for children born to parents with unlawful or temporary immigration status.[2] This prompted lawsuits by individuals, organizations, and several states claiming the order violated the Fourteenth Amendment’s Citizenship Clause.[3] Several district courts issued universal injunctions, enjoining the enforcement of Executive Order 14160.[4]

I. The Court’s Determination on Equitable Relief

The majority opinion discussed the Judiciary Act of 1789, which provides federal courts with jurisdiction over “all suits in equity”.[5] The Court analyzed the precedent surrounding the interpretation of the Judiciary Act of 1789 and determined that the equitable remedies available to federal courts are those “traditionally accorded by courts of equity”.[6] More specifically, the Court analyzed whether or not the universal injunctions are “sufficiently analogous to the relief issues by the High Court of Chancery in England at the time of adoption”.[7] The majority held that there was no analogous form of relief. The majority further held that universal injunctions were nearly nonexistent for most of the Nation’s history, demonstrating the lack of precedent.[8] The Court granted the Trump Administration’s application for a partial stay of the injunctions, limiting the injunctions to those plaintiffs with standing to sue.[9] Therefore, the injunctions only apply to the specific plaintiffs who were directly affected and entitled to sue. However, other parties that were not a part of the lawsuit or lacked standing will no longer be protected by the injunctions.

The Court declined to determine the constitutionality of the Executive Order, but found the universal injunctions were an improper form of relief.[10] The constitutionality of the Executive Order will likely be decided on later as the case develops. The Supreme Court’s decision extends beyond the specific injunctions in this matter and applies to all federal courts.[11] The Court further held that the Executive Order will not go into effect until July 27, 2025, 30 days following the decision.[12]

II. Potential Consequences of the Court’s Holding

This decision still leaves open a range of different possibilities, which will likely develop over time. First, the Court noted that class actions may still obtain injunctive relief that protects all class members.[13] As emphasized by Justice Kavanaugh in his concurrence, it is possible to obtain classwide relief that is statewide or even nationwide, effectively operating as a universal injunction.[14] Nonetheless, class certification is a rigorous process and the class must still meet all components of Rule 23 of the Federal Rules of Civil Procedure (“Rule 23”).[15] The majority opinion did underscore the fact that universal injunctions were inherently workarounds to Rule 23.[16]

Secondly, the Court did not discuss whether State plaintiffs still have third-party standing to bring Citizenship Clause claims on behalf of individual residents.[17] Typically, a litigant may not assert the legal rights of third parties; however, in limited circumstances this may be allowed.[18] Justice Alito, in his concurrence, stated that federal courts would have to conscientiously apply such limitations on third-party standing to preserve the effect of the Court’s decision.[19]

III. Conclusion

The Supreme Court’s decision in Trump v. CASA, Inc. significantly narrowed the forms of relief available for third parties with aligned interests of litigants suing against government policies. While holding that universal injunctions likely exceed the equitable authority granted to federal courts, the Supreme Court left open the possibility to obtain similar relief through class actions or, by the Court’s standard, plaintiffs with standing that can prove that such relief is necessary. However, the Court left unresolved issues surrounding third-party standing. As a result, the way in which challenges to governmental policies are handled will likely change as a result of the Court’s holding, leaving litigants and federal courts to navigate its implications.

If you have any questions, please feel free to contact Ariel Ronneburger (aronneburger@cullenllp.com) at (516) 296-9182, or Joshua Kaye (jkaye@cullenllp.com) at (516) 297-9117. 

This advisory provides a brief overview of the most significant updates in the law and does not constitute legal advice. Nothing herein creates an attorney-client relationship between the sender and recipient.

Footnotes 

[1] 606 U.S. 1, 2 (2025).

[2] Id. at 1.

[3] Id. at 1.

[4] Id. at 2; State of New Jersey v. Trump, No. 25-1170 (1st Cir. 2025); State of Washington et al. v. Trump et al. No. 2:2025cv00244 (W.D. Wash. 2025); Casa Inc. et al. v. Trump et al., No. 8:2025cv00201 (D. Md. 2025).

[5] Id. at 5.

[6] Id. at 5.

[7] Id. at 6.

[8] Id. at 10.

[9] Id. at 26.

[10] Id. at 1.

[11] Id. at 1.

[12] Id. at 26.

[13] Id. at 4.

[14] Id. at 2 (Kavanaugh, J., concurring).

[15] Id. at 3 (Kavanaugh, J., concurring).

[16] Id. at 14.

[17] Id. at 1 (Alito, J., concurring).

[18] Id. at 2 (Alito, J., concurring). The Court noted that “the precise circumstances in which third-party standing is permissible” have yet to be determined. Id. Justice Alito explains that a litigant must both prove ordinary Article III standing and that it has standing to raise the right of others, shown by having a “close relationship”  to the right holder and the right holder is hindered in their ability to protect their own interests. Id.

[19] Id. at 2 (Alito, J., concurring).