Nationwide injunctions are federal court orders that block the government from enforcing a law or policy against everyone in the country, not just the people who filed the lawsuit. In June 2025, the Supreme Court ruled 6–3 in Trump v. Casa, Inc. that federal courts lack the authority to issue them, holding that nothing resembling a universal injunction existed when the nation’s courts were first established.1Supreme Court of the United States. Trump v. CASA, Inc. The era of a single district judge freezing a federal policy for every person in the country has effectively ended, though other tools that can produce similar results, such as vacatur of agency rules and class actions, remain available.
What a Nationwide Injunction Was
A nationwide injunction, sometimes called a universal injunction, worked by targeting the federal defendant rather than drawing a geographic line. Because a court had power over the government official or agency named in the lawsuit, it could order that official to stop enforcing a rule everywhere the official operated. A single judge sitting in one city could freeze a federal policy across all fifty states and territories at once. The order followed the defendant, so the government could not enforce the blocked rule against anyone, whether or not that person was part of the case.
The practical appeal was obvious. A party-specific injunction protects only the people who actually sued. A universal injunction shielded the entire population from a contested regulation, and anyone who violated it faced potential contempt proceedings, including fines or sanctions.2Constitution Annotated. ArtIII.S1.4.3 Inherent Powers Over Contempt and Sanctions Rather than requiring dozens of separate lawsuits, one challenge could stop a policy in its tracks.
Courts that issued these orders relied on two justifications. They pointed to Article III of the Constitution, which grants federal courts authority over cases “in law and equity” arising under federal law.3Congress.gov. U.S. Constitution – Article III They also argued that providing complete relief to the plaintiffs required halting the policy everywhere, because leaving it in effect in some regions would create an unworkable patchwork. Federal Rule of Civil Procedure 65, which governs how injunctions are issued, requires courts to state their reasons and describe what conduct is being restrained, but says nothing explicit about whether an injunction can reach beyond the parties to the lawsuit.4Legal Information Institute. Federal Rules of Civil Procedure Rule 65 – Injunctions and Restraining Orders
How the Supreme Court Ended Them
Trump v. Casa, Inc. arose from challenges to an executive order on birthright citizenship. Multiple district courts had entered universal injunctions blocking enforcement of the order against anyone in the country. The Supreme Court, in a 6–3 opinion by Justice Barrett, held that federal courts simply do not have the power to issue universal injunctions.1Supreme Court of the United States. Trump v. CASA, Inc.
The Court’s reasoning was historical. The Judiciary Act of 1789, which still authorizes federal courts to grant equitable remedies, covers only the kinds of relief that were available in English courts of equity at the founding. In those courts, injunctions could only bind parties to the lawsuit. The opinion cited the longstanding principle that “you cannot have an injunction except against a party to the suit” and noted that universal injunctions were “conspicuously nonexistent for most of the Nation’s history.”1Supreme Court of the United States. Trump v. CASA, Inc.
The Court granted the government’s request to stay the lower court injunctions, but only to the extent those injunctions went beyond what was necessary to protect the specific plaintiffs with standing to sue. The portions that directly protected the named plaintiffs remained in effect.
The Line Around “Complete Relief”
The ruling did not forbid every injunction that happens to benefit people who did not sue. A court can still issue an injunction that incidentally protects nonparties, so long as the order is necessary to fully protect the plaintiffs themselves. The opinion used the example of a noise nuisance: a court can order a factory to stop polluting, and the neighbors benefit, but only the plaintiff who sued can enforce the order through contempt.
What a court cannot do is issue an injunction specifically designed to protect nonparties. Complete relief, the Court said, “is not a guarantee — it is the maximum a court can provide.”1Supreme Court of the United States. Trump v. CASA, Inc. The distinction matters because it preserves some room for broad practical effects while shutting the door on relief consciously extended to everyone in the country.
What Can Still Block a Federal Policy Nationwide
The Casa ruling eliminated universal injunctions but left two significant alternatives intact: vacatur of agency rules under the Administrative Procedure Act and class-action lawsuits. Both can achieve results that look very similar to a nationwide injunction, though each carries its own procedural requirements.
Vacatur of Agency Rules
When a federal agency issues a rule that a court finds unlawful, the Administrative Procedure Act authorizes the court to “hold unlawful and set aside” that agency action.5Office of the Law Revision Counsel. 5 USC 706 – Scope of Review A vacatur does not order the government to stop doing something. It declares that the rule itself no longer has legal effect. The practical result can be identical to a nationwide injunction: if the rule is vacated, it cannot be enforced against anyone. But the legal mechanism is different. An injunction binds a defendant and is enforceable through contempt. A vacatur removes the rule from the books.
The Supreme Court explicitly noted in Casa that the decision does “not resolve the distinct question whether the Administrative Procedure Act authorizes federal courts to vacate federal agency action.”1Supreme Court of the United States. Trump v. CASA, Inc. That question remains open, and lower courts will likely continue using vacatur in challenges to agency rulemaking. For plaintiffs challenging executive orders or presidential actions that are not technically “agency rules,” vacatur is less clearly available, which narrows its usefulness.
Class Actions
The other surviving pathway is a class-action lawsuit. If a court certifies a nationwide class of everyone affected by a challenged policy, an injunction protecting that class covers all of its members, which can functionally mirror a nationwide injunction. The Casa opinion acknowledged this route and traced its lineage to the historical “bill of peace,” where courts consolidated too many individual claims into a single proceeding.1Supreme Court of the United States. Trump v. CASA, Inc.
The tradeoff is time and procedural complexity. Class certification requires showing that the group is too large for individual lawsuits, that common legal questions exist, that the named plaintiffs’ claims are typical of the class, and that the representatives will adequately protect everyone’s interests. Meeting those requirements takes months. Justice Kavanaugh’s concurrence acknowledged that lower courts can sometimes “award preliminary classwide relief” even before the class is formally certified, which could speed things up in urgent cases.1Supreme Court of the United States. Trump v. CASA, Inc. The procedural overhead is still far heavier than what a universal injunction required, where a single plaintiff could block a policy for the entire country overnight.
What Congress May Change
Even before the Casa ruling, Congress had been considering legislation on nationwide injunctions, and several bills were introduced in 2025. The No Rogue Rulings Act passed the House and would limit district courts to injunctive relief protecting only the parties to the case, with an exception allowing broader relief when two or more states from different circuits join in the challenge and the case is heard by a three-judge panel. The Judicial Relief Clarification Act in the Senate took a more sweeping approach, proposing not only to limit injunctive relief to named parties but also to strip courts of the power to “set aside” agency action under the Administrative Procedure Act. That change would close the vacatur workaround.
Other proposals target the appellate process. One bill would send any appeal from a nationwide injunction directly to the Supreme Court, bypassing the circuit courts. Another would mandate three-judge district courts for any case seeking to block executive branch action. Whether any of these bills becomes law is uncertain, but together they show that the pressure on the pre-Casa system did not end when the Supreme Court did.