Docket 24A884
Trump
DecidedJun 27, 2025
6-3decision
Source: CourtListener.
Supreme Court limits federal courts to plaintiff-only injunctions, blocking universal enforcement bans
Impact9/10
What it does
The Court held that federal courts most likely lack the power to issue "universal injunctions" — orders blocking the government from enforcing a policy against everyone, not just the people who sued. Going forward, injunctions must generally be limited to providing relief only to the specific plaintiffs in each case. The Court partially stayed the three lower-court injunctions against the birthright citizenship Executive Order, but left them in place to the extent needed to protect the named plaintiffs.
Who benefits
The federal executive branch, which can now enforce challenged policies against people who have not personally filed a lawsuit, rather than being blocked nationwide by a single district court ruling.
Who is affected
People whose legal rights may be affected by a challenged federal policy but who are not named plaintiffs in an existing lawsuit — including, in this case, children born in the United States to parents who are not citizens or lawful permanent residents, whose citizenship the Executive Order disputes.
Practical impact
District courts that find a federal policy likely unlawful may no longer simply block its enforcement nationwide; they must tailor injunctions to protect only the specific plaintiffs before them, unless broader relief is the only feasible way to give those plaintiffs complete relief. People affected by a challenged federal policy who are not parties to an existing lawsuit must file their own suits — or seek to join a class action under Rule 23 — to obtain court protection. The birthright citizenship Executive Order remains blocked as to the named plaintiffs in these three cases, while lower courts must reconsider on remand whether any broader relief is justified under the complete-relief standard.
Majority — Barrett
Joined by: Roberts, Thomas, Alito, Gorsuch, Kavanaugh
The majority held that the Judiciary Act of 1789 — the law that gives federal courts their power to issue equitable remedies — only authorizes the kinds of relief that courts of equity in England traditionally provided at the time the Constitution was adopted. The Court reasoned that universal injunctions have no historical equivalent in English equity courts, where remedies were almost always limited to the specific parties in a lawsuit, and that such injunctions were essentially nonexistent in American courts until the mid-20th century. The majority further explained that the historical predecessor most similar to a universal injunction — the "bill of peace," a form of group litigation in English equity courts — actually evolved into the modern class action governed by Rule 23 of the Federal Rules of Civil Procedure, not into the universal injunction, and that allowing universal injunctions lets courts bypass Rule 23's procedural requirements. Because "complete relief" for a plaintiff means relief sufficient to remedy that plaintiff's own injury — not relief extended to everyone similarly situated — the majority concluded that courts exceed their authority when they bar enforcement of a policy against the entire country.
Dissent reasoning
The dissent, written by Justice Sotomayor and joined by Justices Kagan and Jackson, argued that universal injunctions are firmly grounded in centuries of equity practice, pointing to "bills of peace" and taxpayer suits in which English and early American courts routinely awarded relief that benefited entire communities, not just named parties. The dissent contended that equity was always designed to be flexible and adaptive — its "constant aim" being complete justice — and that freezing equitable remedies to only those forms that existed at the founding misunderstands equity's essential nature. The dissent also argued that the Government failed to show the irreparable harm required for a stay, because the Executive Order is plainly unconstitutional under the Fourteenth Amendment's Citizenship Clause and longstanding Supreme Court precedent, meaning the Government has no legal right to enforce it against anyone. Justice Jackson wrote separately to argue that the ruling creates a dangerous "zone of lawlessness" in which the Executive can violate the Constitution with respect to anyone who has not personally filed a lawsuit, fundamentally undermining the rule of law and the Judiciary's duty to ensure the government follows the Constitution.
Constitutional question
Do federal courts have the equitable authority under the Judiciary Act of 1789 to issue "universal injunctions" — court orders that bar the government from enforcing a law or policy against anyone in the country, not just the plaintiffs who filed the lawsuit?