Summary
This Supreme Court decision addresses whether federal courts possess the equitable authority under the Judiciary Act of 1789 to issue universal injunctions that bar government officials from enforcing an executive order against anyone nationwide. The Court held that such sweeping relief lacks historical precedent in English and American equity practice and likely exceeds statutory grants of judicial power. Consequently, the Court granted the Government's emergency applications for partial stays, limiting the preliminary injunctions to provide complete relief only to the specific plaintiffs with standing. The underlying merits regarding the executive order's compliance with the Citizenship Clause and Nationality Act were expressly left unaddressed.
Topics
Practice areas
Questions Presented
- Whether the Judiciary Act of 1789 authorizes federal courts to issue universal injunctions barring enforcement of an executive order against nonparties.
- Whether the Government was entitled to partial stays because the injunctions likely exceeded the equitable authority of the issuing courts.
- What limits the complete-relief principle places on the scope of party-specific injunctive relief.
Holdings
- Universal injunctions likely exceed the equitable authority that Congress has granted to federal courts under the Judiciary Act of 1789 because such relief lacks a sufficiently analogous founding-era antecedent in traditional equity practice.
- A bill of peace is not an adequate historical analogue for a universal injunction; its modern descendant is the class action governed by Federal Rule of Civil Procedure 23.
- Complete relief is not synonymous with universal relief; an injunction may extend only as far as necessary to provide complete relief to each plaintiff with standing and may not be broader than necessary to redress the plaintiffs' injuries.
- The Government established a sufficient likelihood of success on the question of the injunctions' scope and irreparable harm from injunctions that likely exceeded statutory authority, warranting partial stays.
Key quotations
“These injunctions—known as “universal injunctions”—likely exceed the equitable authority that Congress has granted to federal courts.” (2)
“Because the universal injunction lacks a historical pedigree, it falls outside the bounds of a federal court’s equitable authority under the Judiciary Act.” (11)
““Complete relief” is not synonymous with “universal relief.”” (16)
“When a court concludes that the Executive Branch has acted unlawfully, the answer is not for the court to exceed its power, too.” (26)
Factual background
President Trump issued Executive Order No. 14160, which directed the United States not to issue or accept documentation of citizenship in specified circumstances involving the immigration status and citizenship of a child's parents. Individuals, organizations, and States challenged the Order under the Fourteenth Amendment's Citizenship Clause and §201 of the Nationality Act of 1940. Three district courts entered preliminary injunctions barring executive officials from enforcing the Order against anyone, not only the named plaintiffs.
Procedural history
Plaintiffs filed three separate actions challenging Executive Order No. 14160, which restricted recognition of citizenship for certain persons born in the United States. The District Courts determined that the Order was likely unlawful and issued universal preliminary injunctions. The Fourth, Ninth, and First Circuits denied the Government's requests to stay the injunctions. The Supreme Court granted the Government's applications for partial stays to the extent the injunctions exceeded the relief necessary for plaintiffs with standing, and also stayed provisions barring agencies from developing and issuing implementation guidance.
Remand instructions
The lower courts shall move expeditiously to revise the injunctions so that, with respect to each plaintiff with standing, they provide no more than complete relief and otherwise comply with principles of equity. The injunctions are stayed insofar as they prohibit executive agencies from developing and issuing public guidance concerning implementation of Executive Order No. 14160. Section 2 of the Executive Order may not take effect until 30 days after the opinion.