TRUMP, PRESIDENT OF THE UNITED STATES, ET AL. v. CASA, INC., ET AL. (2025)

Case Title & Citation

• TRUMP, PRESIDENT OF THE UNITED STATES, ET AL. v. CASA, INC., ET AL. (2025)
• Official citation: Trump v. CASA, Inc., 606 U.S. ___ (2025)

Court Name & Bench

Name of the court: Supreme Court of the United States (SCOTUS or SC)

Judges:

• Majority: Justice Barrett, joined by Chief Justice Roberts, Justices Thomas, Alito, Gorsuch, and Kavanaugh
• Concurring Opinions: Justices Thomas (joined by Gorsuch), Alito (joined by Thomas), Kavanaugh
• Dissenting: Justice Sotomayor (joined by Kagan and Jackson), Justice Jackson (separate dissent)

Bench type: Full Bench (9 Justices)

Date of Judgment

Date Delivered: 27^th of June 2025

Parties Involved

Petitioners: POTUS, Donald J. Trump, and federal executive officials.

Respondents: CASA Inc. (immigrants’ rights organization), as well as individual plaintiffs affected by the Executive order, and several States represented by the Solicitor General of New Jersey.

Facts of the Case

The President’s executive order No.14160 (20^th Jan 2025), sought to redefine the meaning of the US Constitution, providing that a person born is the United States would not be conferred citizenship if (1) the child’s mother was unlawfully present, the father was not a citizen or a lawful permanent resident at the time of birth, or (2) where the mother was not a permanent resident and the father was not a citizen or permanent resident. This executive order aimed to accelerate implementation by 30 days. This resulted in multiple lawsuits being filed, challenging the constitutionality of the executive order, as it is a violation of the Fourteenth Amendment’s Citizenship Clause. Three lawsuits were filed across several US District Courts by States, immigrant rights organisations, and individuals, with all federal judges holding that nationwide preliminary injunctions should be placed on the defendants to restrict the implementation of the orders.

The Executive branch sought partial stays from the SC, challenging the scope of the injunctive orders and the application to parties not part of the lawsuits. The SC consolidated the three relevant cases where Trump et al. sought emergency relief.

Issues Raised

The issue addressed by the courts is: Do federal courts have the equitable authority to issue universal nationwide injunctions that prevent the enforcement of executive orders against anyone (under the Judiciary Act 1789, codifying rights afforded to the judicial branch by Congress), and should relief be limited to parties before the court?

It is important to note that the SC judgement does not address the constitutionality of the executive order in question here, only a federal court’s ability to issue a universal (or nationwide) injunction.

Arguments of the Parties

Key contentions by the Petitioner/Appellant: The Judiciary Act of 1789 does not extend equitable relief to those not party to the decision, therefore the ability of a court to issue such an order is inconsistent with remedies “traditionally accorded by courts of equity” (Grupo Mexicano de Desarrollo, S. A. v. Alliance Bond Fund, Inc, 1999). Also, this ability of federal courts has hindered the government’s ability to implement its policies, slowing processes. They argue that for such relief to be properly sought, parties should bring class action lawsuits (through the class action rule 23), not through judicial order that extends to those outside of the lawsuit. (Federal Rules of Civil Procedure, Rule 23)

Key contentions by the Respondent/Defendant: Argue that the universal injunction is a proportionate equitable power of the courts when necessary for complete relief. They argue that long-standing “bill of peace,” a form of group litigation in the court of Chancery, could be the basis of allowing for this modern equivalent to permit group and community-wide remedies. The injunction is necessitated by the nationwide negative effect it will have on millions of people, and not allowing for this will allow the order deemed unconstitutional by multiple federal courts to impact people not covered by the injunction. The cross-state-border impact must be considered, and the court of equity is empowered to take progressive decisions that align with modern circumstances, which necessitate a change in approach.

Judgment 

The SC granted the Trump administration’s application for partial stays of the preliminary injunctions, to the extent that the orders were broader than necessary to provide complete relief, a narrow scope than universal relief, covering only the parties to the lawsuit. The court held that the Judiciary Act 1789 did not support the propriety of universal injunctions and that federal courts only have the power to issue injunctive orders as to the parties in a given case, to completely remedy their injury and no one else. The court held that implementation of section 2 of the executive order would remain stayed for 30 days after the date of the opinion. The court did not resolve the underlying question of the executive orders’ constitutionality in their decision.

Dissenting judges argued fervently against the decisions of their fellow Justices; both Justice Sotomayor and Justice Jackson gave separate dissents against the ruling.

Legal Reasoning / Ratio Decidendi

The court came to its decision based on the logic that nationwide injunctions exceed courts’ equitable authority granted by the Judiciary Act 1789. This is because courts should issue relief only for the parties before the court. No interpretation of the rule could be found to support universal injunctions, as well as any interpretation that complete relief could extend to those outside of the parties. Other avenues, such as Bills of Peace, are not extendable in scope as to authorise the use of universal injunctions. The court also cited policy concerns such as forum shopping, where cases are held in strategic jurisdictions to allow courts in one federal jurisdiction to dictate what happens in another. The courts pointed towards the class action rule 23 in their decision as the proper vehicle for this kind of relief.

Significant precedents cited:

• Grupo Mexicano de Desarrollo v. Alliance Bond Fund, (1999): Limits equitable remedies to traditional application practices.
• Scott v. Donald, (1897): Relief limited to named plaintiffs, cannot extend even to a defined outside group.
• INS v. Legalization Assistance Project, (1993): Universal injunctions burden executive authority, Government likely to suffer irreparable harm.

Conclusion

The universal injunction has long been an area of scepticism for SC Justices, as their nature has often been seen as an overreach, such as in Food and Drug Administration v. Alliance for Hippocratic Medicine, 602 U.S. 367 (2024), where the court unanimously found that the plaintiffs did not have grounds to do so under Article III, as no legal injury could be found. In that case, the courts similarly reversed the lower court’s ruling to block FDA-approved abortion medication, but the SC did not go as far as to address the ability of courts to issue universal injunctive orders in any capacity. The court’s choice to address this issue in this case, which is underpinned by the apparent need for relief against an unconstitutional executive order (SC did not address this finding of the lower courts), was seen by dissenting judges as pure “gamesmanship”-J. Sotomayor. The plaintiffs, who knew they could not defend the orders’ constitutionality, sought to abolish the federal branch’s best route to preventing harm through the universal injunction. The SC has ignored this question of constitutionality and prevented itself from protecting its citizens from harm by no longer allowing federal courts to take emergency action through these equitable measures. Justice Sotomayor states that “(the executive) asks this court to hold that no matter how illegal a law or policy, courts can never simply tell the executive to stop enforcing it against anyone”, which Justice Jackson follows with “the majority ignores the judiciary’s foundational duty to uphold the constitution and laws of the US, the ruling thus diverges from first principles. It is also profoundly dangerous as it gives the executive the go-ahead to sometimes wield the kind of unchecked, arbitrary power the founders crafted our constitution to eradicate. With deep disillusionment, I dissent.” Coming to such an absolute conclusion to completely prevent the use of nationwide injunction in one of the most obvious cases of their necessity, the court has crippled its own ability to control the executive.

Reference(S):

Cases

• Trump v CASA, Inc. 606 US ___ (2025)
• Grupo Mexicano de Desarrollo, S. A. v. Alliance Bond Fund, Inc. 527 US 308 (1999)
• Scott v. Donald 165 US 107 (1897)
• INS v. Legalization Assistance Project 510 US 1301 (1993)
• Food and Drug Administration v. Alliance for Hippocratic Medicine 602 US 367 (2024)

Constitution

• US Const art III

SCOTUS Opinion

• Syllabus, Opinion, Concurrences and Dissents, Trump v CASA, Inc., 606 US ___ (2025), Supreme Court of the United States (June 27, 2025)

Statutes and Rules

• Judiciary Act 1789 (Act of 1 September 1789, ch 20, 1 Stat 73)
• Federal Rules of Civil Procedure, Rule 23 (Class Actions)
• US Constitution art III
• United States, Executive Order No 14160, 90 Fed Reg 3250 (20 January 2025)