Supreme Court's Landmark Decision: Limiting Universal Injunctions and Its Impact on Birthright Citizenship

This CLE course examines the consequences of the Supreme Court's landmark 6-3 decision in Trump, President of the United States, et al. v. CASA, Inc., et al. on June 27, 2025. The Court, in an opinion authored by Justice Amy Coney Barrett, significantly limited the equitable authority of federal courts to issue "universal injunctions". The majority concluded that such sweeping remedies, which prohibit the Government from enforcing a law or policy against anyone, anywhere, likely exceed the power granted by the Judiciary Act of 1789 because they lack a historical basis in traditional English Chancery and founding-era U.S. equity practice.

This pivotal ruling stemmed from legal challenges to President Trump's Executive Order No. 14160, which sought to redefine birthright citizenship. However, the Supreme Court explicitly did not rule on the constitutionality of the Executive Order itself, focusing instead solely on the question of judicial remedies. As a result, the injunctions against the Executive Order are now limited to the specific plaintiffs (individuals, organizations, and States) who brought the lawsuits, rather than applying nationwide. This outcome is anticipated to create a "dangerous patchwork of rights" across the nation, and is expected to profoundly reshape litigation strategy against federal policies, encouraging plaintiffs to pursue alternative avenues for broad relief such as Rule 23 class actions or parallel challenges in multiple federal districts. The Executive Order is scheduled to take effect 30 days after the opinion date, although its constitutionality remains subject to future legal review.

Learning Objectives:

1. Analyze the Supreme Court's rationale for limiting universal injunctions. This includes understanding the Court's strict interpretation of the Judiciary Act of 1789 and its reliance on the historical Grupo Mexicano test, which requires a founding-era antecedent for equitable remedies
2. Evaluate the immediate and future implications of Trump v. CASA, Inc. on federal litigation against executive actions. This involves recognizing the shift from universal to party-specific relief and the potential for a "patchwork of rights" regarding federal policies due to varied enforcement across states
3. Identify and assess alternative legal strategies for seeking broad relief against federal policies following this decision. This encompasses understanding the role and stringent requirements of Federal Rule of Civil Procedure 23 class actions and the potential for courts to "set aside" agency rules under the Administrative Procedure Act (§706(2))
4. Understand that the constitutionality of President Trump's Executive Order No. 14160 on birthright citizenship remains an open legal question. This objective highlights that the Supreme Court's ruling focused solely on the scope of judicial remedies, leaving the fundamental constitutional question of birthright citizenship for future merits review