Case Overview
Main Holding
6-3 decision ending universal injunctions. Federal courts must tailor relief to specific plaintiff injuries.
Key Impact
Creates "remedial gap" for non-litigants. Shifts strategy to class actions and APA vacatur.
What's Left Open
Merits of birthright citizenship EO, APA vacatur authority, Article III constitutional limits.
Supreme Court Opinions
Majority Opinion
Applies strict historical test based on 1789 English equity practice. No founding-era analogue found for universal injunctions.
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Concurrence
Emphasizes SCOTUS as "ultimate decider" via emergency docket. Endorses class actions and APA alternatives.
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Concurrence
Warns against "complete relief" trap. Insists relief is discretionary ceiling, not mandatory floor, to prevent substantive evasion.
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Concurrence
Warns against loopholes: state third-party standing and lax class certification standards.
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Dissent
Argues for flexible equity. Cites Pierce and Barnette as granting universal relief in effect.
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Dissent
Creates "zone of lawlessness." Law only binds government as to those who sue.
Read Analysis → Deep Dive →Case Timeline
Executive Order 14160
Trump issues birthright citizenship executive order
District Court Injunctions
Multiple federal courts issue universal injunctions
Supreme Court Decision
6-3 ruling ends universal injunctions
USCIS Implementation
Agency issues implementation guidance for Executive Order
Post-CASA Lower Court Responses
Federal courts find workarounds: Ninth Circuit affirms universal injunction for states (July 23), D. Mass. upholds universal relief citing cross-border harm (July 25), D.N.H. certifies nationwide class (July 10), D. Md. adopts SCOTUS class action path (July 16)
Case Materials
Lower Court Opinions
- Washington v. Trump (9th Cir.) - July 23, 2025
Ninth Circuit affirms universal injunction for state plaintiffs
- New Jersey v. Trump (D. Mass.) - July 25, 2025
Massachusetts District upholds universal injunction citing cross-border harm
- CASA v. Trump (D. Md.) - July 16, 2025
Maryland District adopts SCOTUS procedural path for class certification
- Barbara v. Trump (D.N.H.) - July 10, 2025
New Hampshire certifies nationwide class following "SCOTUS blueprint"
Executive Materials
Precedent Cases
Scholarship
Practice Pointers
Class Actions
The Supreme Court's CASA decision eliminated universal injunctions, channeling systemic litigation into the rigorous framework of FRCP 23(b)(2) class actions. This new landscape places a premium on mastering certification, requiring precise strategies to overcome heightened scrutiny of standing, commonality, and overall class cohesion.
Read Full Analysis →Complete Relief
While Trump v. CASA ended universal injunctions, it preserved a narrow path for broad relief: the "complete relief" doctrine. This strategy hinges on proving a plaintiff's injury is truly indivisible, where partial remedies are futile. Learn the high evidentiary bar required to invoke this exception.
Read Full Analysis →APA Vacatur
In the wake of Trump v. CASA, the Administrative Procedure Act's vacatur remedy may become the most potent tool for nationwide relief against unlawful final agency action. This statutory power to "set aside" a rule sidesteps the equitable limits on injunctions, potentially making it a critical post-CASA strategy.
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