Complete Relief and Indivisible Injuries After Trump v. CASA
The Supreme Court's decision in Trump v. CASA, Inc. (2025) unequivocally ended the era of the universal injunction issued by federal district courts. The Court held that equitable remedies must be tied to the parties before the court, rejecting the practice of a single plaintiff obtaining an injunction that dictates nationwide policy for non-parties. However, CASA did not eliminate all forms of broad or even nationwide relief. It preserved the traditional equitable principle that a court must be able to afford "complete relief" to the specific plaintiff before it.
This distinction is critical. When a plaintiff's injury is truly indivisible—meaning that geographically limited or partial relief would provide no meaningful remedy—courts retain the authority to issue broad injunctions. This doctrine represents a significant remaining pathway for expansive relief outside the class action context, but the bar for demonstrating indivisibility is exceptionally high.
The Theory and Limits of Complete Relief
The complete relief doctrine survived CASA because it is fundamentally plaintiff-centric, whereas the universal injunction was policy-centric. Universal injunctions were often sought by plaintiffs aiming to halt a government policy generally. Complete relief, conversely, is anchored in the necessity of redressing a specific plaintiff's concrete injury.
The legal theory rests on the premise that equity requires remedies tailored to the actual harm. If a plaintiff demonstrates that their injury spans multiple jurisdictions and that a narrower injunction would be futile, the court may craft a broader remedy. However, many courts may heed Justice Alito's concerns and apply intense scrutiny to ensure this doctrine does not become a loophole to circumvent CASA. The key is demonstrating that broad relief is a necessity for the plaintiff, not merely a convenience or a preference.
Defining and Proving Indivisible Injury
The central challenge is establishing what constitutes an "indivisible injury." Mere administrative inconvenience or a desire for uniformity is insufficient. Indivisibility typically arises in specific contexts:
Integrated National Operations: Plaintiffs, such as large corporations or organizations with centralized operations, may argue that a patchwork of regulations creates operational paralysis. For example, a national logistics company might argue that inconsistent rules regarding transportation standards make compliance impossible.
State Sovereignty and Administration: State governments often present the strongest claims. A state may argue that its regulatory schemes or administrative systems (e.g., healthcare exchanges, environmental compacts) are inherently integrated and cannot function if a federal policy is enjoined only partially. The argument is that cross-border flows of people, commerce, or pollution make localized relief ineffective.
Financial Indivisibility: This occurs when the cost of implementing dual systems to comply with partial relief is so prohibitive that it constitutes an ongoing injury in itself.
The evidentiary burden is substantial. Plaintiffs cannot rely on conclusory allegations. They must provide detailed factual records, often including expert testimony, demonstrating exactly why partial relief fails to redress their injury.
Strategic Considerations for Practitioners
The complete relief pathway requires a highly tactical approach focused on developing a robust factual record.
For Plaintiffs Seeking Broad Relief:
Factual Specificity is Paramount: Do not rely on abstract arguments. Use declarations, internal documents, and expert analysis to illustrate the concrete operational impossibility of partial relief. Show, don't just tell, how systems would break down.
Distinguish from Policy Arguments: Frame the argument entirely around the plaintiff's specific injury and operational needs. Any argument that sounds like a generalized objection to the legality of the policy risks being characterized as an attempted end-run around CASA.
Preempt Narrower Alternatives: Plaintiffs should proactively demonstrate why narrower injunctions proposed by the defense (or the court) would be inadequate.
For Defense Counsel (Government and Private):
Attack the Necessity: The defense strategy centers on demonstrating that broad relief is not strictly necessary. Argue that the plaintiff is exaggerating the burden of partial compliance and that administrative inconvenience does not equate to an indivisible injury.
Propose Divisible Remedies: Offer the court alternative, narrower forms of relief that address the plaintiff's most concrete harms without halting the policy nationwide. This forces the court to engage in narrow tailoring.
Highlight the Impact on Non-Parties: Emphasize the core holding of CASA: remedies should not bind non-parties. Argue that the plaintiff's requested "complete relief" improperly dictates outcomes for others not before the court, intruding on the political branches' authority to set national policy.
The complete relief doctrine remains a viable but narrow path. Success requires moving beyond generalized claims of harm and providing clear, convincing evidence that the plaintiff's injury cannot be redressed by anything less than broad injunctive relief.