In June, I reported on Trump v. CASA, Inc., et al which was argued before the U.S. Supreme Court in May. The issue pertains to birthright citizenship, but shines a spotlight on a federal district court's authority to issue nationwide injunctions, thereby thwarting the policy decisions of a sitting president. There is no explicit statutory or constitutional legal authority for nationwide injunctions, and courts utilizing them have derived the authority from a myriad of jurisdictional statutes and rules. On June 27, 2025, the Court, not surprisingly, ruled in favor of the President in a 6-3 decision strictly down ideological lines.
Writing for the majority, Justice Amy Coney Barrett deftly concludes her opinion by succinctly addressing the judiciary's authority, stating "[some say that universal injunctions give[s) the judiciary a powerful tool to check the Executive Branch. But federal courts do not exercise general oversight of the Executive Branch; they resolve cases and controversies consistent with the authority Congress has given them. When a court concludes that the Executive Branch has acted unlawfully, the answer is not for the court to exceed its power, too." In keeping with this summation of judicial restraint, the Court concluded that where the lower court has the authority to grant equitable relief, that relief is limited to the parties.
In dissent, Justice Sonia Sotomayor suggests that the court's holding "runs directly counter to the point of equity: empowering courts to do complete justice, including through flexible remedies that have historically benefited parties and non-parties alike." The dissent further opines that limiting injunctive relief to the parties, or a specific jurisdiction(s) will result in an inconsistent application of rights across jurisdictions.
While the dissent's position on inconsistent application may be true in the short term, it is not in the long term. Like many issues subject to legal scrutiny, the law may remain uncertain and inconsistent until a final determination is made. In matters of constitutional significance, rarely is the final arbiter a federal district court. Further, non-parties who may suffer irreparable harm in the interim are free t o bring their own action-seeking individualized injunctive relief.
It is important to note that while this case may be a win for President Trump as to birthright citizenship, other issues will emerge where he, or any future president, may prefer that a nationwide injunction be issued. So, while the case was decided on ideological lines, its legacy will not favor any one party.
Trump v. CASA perfectly illustrates that the law can be messy and uncertain, often for long periods of time, but that the legal finality, which ultimately emerges, is critical to preserving the Republic.