Summary
This Supreme Court opinion determines whether federal district courts possess the equitable authority to issue universal injunctions that bar the enforcement of an executive order nationwide. Relying on historical equity practices and the Judiciary Act of 1789, the Court concludes that such sweeping relief lacks a founding-era analogue and likely exceeds statutory authority. Accordingly, the Court grants the Government's emergency applications for partial stays, restricting the preliminary injunctions to provide complete relief only to the named plaintiffs with standing. The decision expressly avoids ruling on whether the executive order itself violates the Fourteenth Amendment's Citizenship Clause or the Nationality Act.
Topics
Practice areas
Questions Presented
- Whether federal courts possess equitable authority under the Judiciary Act of 1789 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 courts' equitable authority and caused irreparable harm.
- What limits the complete-relief principle places on the scope of party-specific injunctive relief.
Holdings
- Universal injunctions likely exceed the equitable authority Congress has granted to federal courts. The Judiciary Act authorizes only equitable remedies traditionally available in courts of equity at the time of the founding, and universal injunctions lack a sufficient founding-era analogue.
- A bill of peace is not an adequate historical analogue for a universal injunction. Bills of peace involved small, cohesive groups and resulted in decrees binding the represented group, whereas universal injunctions reach anyone affected by governmental action without the procedural protections of a class action.
- The complete-relief principle does not authorize universal relief to nonparties. Courts may provide relief necessary to afford complete relief to the plaintiffs before them, but the remedy may not be broader than necessary to redress those plaintiffs' injuries.
- The Government was entitled to partial stays because it showed a likelihood of success on the question whether the injunctions exceeded statutory equitable authority, likely irreparable harm from being prevented from enforcing the Executive Order against nonparties, and no countervailing equitable basis for maintaining the overbroad relief.
Key quotations
“Universal injunctions likely exceed the equitable authority that Congress has given to federal courts.” (606 U.S. at 2)
““Complete relief” is not synonymous with “universal relief.”” (606 U.S. at 16)
“When a court concludes that the Executive Branch has acted unlawfully, the answer is not for the court to exceed its power, too.” (606 U.S. at 26)
Factual background
President Trump issued Executive Order No. 14160, which directed federal agencies not to recognize or document citizenship for certain persons born in the United States based on their parents' immigration status and citizenship. 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 universal preliminary injunctions barring enforcement of the Order against anyone, and the Government sought partial stays limiting relief to plaintiffs with standing.
Procedural history
Individuals, organizations, and States filed three suits challenging Executive Order No. 14160, which concerns recognition of citizenship for certain persons born in the United States. The district courts found the Order likely unlawful and entered universal preliminary injunctions. The Courts of Appeals denied the Government's requests to stay the relief. The Government then filed three emergency applications for partial stays in the Supreme Court.
Remand instructions
The lower courts must move expeditiously to revise the injunctions so that, for each plaintiff with standing, the relief is no broader than necessary to provide complete relief and otherwise complies with principles of equity. The injunctions are also 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 June 27, 2025.