Trump, President of the United States, et al. v. Casa, Inc. et al.
No. 24A884 · Decided June 27, 2025
Whether federal courts possess the equitable authority to issue universal injunctions under the Judiciary Act of 1789. Federal courts lack the equitable authority under the Judiciary Act of 1789 to issue universal injunctions that bar the enforcement of government policy against nonparties, except to the extent necessary to provide complete relief to respondents with standing.
ON APPLICATION FOR PARTIAL STAY · Argued May 15, 2025
Parties — Petitioner: TRUMP, PRESIDENT OF THE UNITED STATES, et al. · Respondent: CASA, INC., et al.
Vote & lineup6–3 on the judgment. Barrett delivered the opinion of the Court, joined by Roberts, Thomas, Alito, Gorsuch, Kavanaugh (6). Dissent(s): Sotomayor (joined by Kagan, Jackson); Jackson. Concurrence(s): Thomas (joined by Gorsuch); Alito (joined by Thomas); Kavanaugh.
Who prevailed — The petitioner prevailed in obtaining partial stays to limit the scope of the preliminary injunctions to only those parties necessary for complete relief.
The question

Whether federal courts possess the equitable authority to issue universal injunctions under the Judiciary Act of 1789. Specifically, the Court addresses whether a district court may bar the enforcement of an executive order against all persons rather than just the named respondents. The decision focuses on the scope of remedial power granted by Congress rather than the underlying legality of Executive Order No. 14160.

Petitioner's argument
  • District courts lack the equitable authority to issue universal injunctions because such remedies are not traditionally rooted in equity practice.
  • Universal injunctions encourage forum shopping and create an asymmetric litigation environment where the petitioner must win every case to avoid a nationwide freeze of policy.
  • These injunctions force "rushed, high-stakes, [and] low-information" decision-making by courts on highly consequential matters.
  • The current universal injunctions are more burdensome than necessary to redress any asserted harms.
Respondent's argument
  • Universal injunctions are the modern equivalent of "bills of peace," a traditional equitable device used for group litigation.
  • Such relief is necessary to provide "complete relief" to the respondents, particularly for States facing administrative burdens and financial injuries from cross-border population flows.
  • Universal injunctions are a practical necessity to quickly protect large groups from unlawful government action without requiring thousands of individual suits.
  • They ensure equal treatment among individuals when the Executive Branch adopts a facially unlawful policy.
The decision
  • The Court held that universal injunctions likely exceed the equitable authority granted to federal courts by Congress.
  • Under the Judiciary Act of 1789, § 11, 1 Stat. 78, federal courts may only issue equitable remedies "traditionally accorded by courts of equity" at the nation's inception, per *Grupo Mexicano de Desarrollo, S. A. v. Alliance Bond Fund, Inc.*
  • Historical analysis of the English High Court of Chancery and early U.S. cases, such as *Scott v. Donald* and *Perkins v. Lukens Steel Co.*, demonstrates that equitable remedies were traditionally party-specific.
  • The Court rejected the "bill of peace" analogy, noting that those devices involved small, cohesive groups and evolved into modern class actions governed by Rule 23 of the Federal Rules of Civil Procedure; universal injunctions impermissibly circumvent these procedural protections (*Smith v. Bayer Corp.*).
  • The Court distinguished "complete relief" from "universal relief," stating that while courts may administer complete relief between parties (*Kinney-Coastal Oil Co. v. Kieffer*), this does not justify extending relief to nonparties.
  • Relief is only permissible if it is no more burdensome to the petitioner than necessary to provide complete relief to the respondents, citing *Califano v. Yamasaki*.
  • The petitioner demonstrated a likelihood of irreparable harm because universal injunctions "improper[ly] intru[de]" on a coordinate branch of government (*INS v. Legalization Assistance Project of Los Angeles County Federation of Labor*).
  • Consequently, the Court granted partial stays to limit the injunctions to the extent they are broader than necessary to provide complete relief to respondents with standing to sue.
Separate opinions
Thomas, concurring (joined by Gorsuch)
  • Argues that "complete relief" is a ceiling rather than a mandate and must be balanced against other principles of equity.
  • Cites *Frothingham v. Mellon* to show that courts may deny complete relief if the respondent's interest is too minute or indirect.
Alito, concurring (joined by Thomas)
  • Warns that the decision could be undermined if courts laxly apply third-party standing (*Powers v. Ohio*, *Kowalski v. Tesmer*) or Rule 23 class certification (*Wal-Mart Stores, Inc. v. Dukes*).
Kavanaugh, concurring
  • Discusses the "interim before the interim" and argues that this Court often serves as the ultimate decider of the national interim legal status of major federal policies to avoid chaotic patchwork enforcement.
Sotomayor, dissenting (joined by Kagan, Jackson)
  • Argues that birthright citizenship is a fundamental right under the Fourteenth Amendment's Citizenship Clause and *United States v. Wong Kim Ark*.
  • Contends that universal injunctions are consistent with equity's goal of "complete justice" and cites historical examples like *Lewis Publishing Co. v. Morgan* and *Pierce v. Society of Sisters*.
Jackson, dissenting
  • Argues that the Judiciary has a foundational duty to compel the petitioner to follow the law universally to prevent "intermittent lawlessness."
  • Claims the majority creates a "dual-track" system where constitutional rights are only protected for those with the resources to sue.
Read the full opinion on supremecourt.gov (PDF) →