Nationwide and universal injunctions are court orders that block a federal policy beyond the people who actually sued, and after the Supreme Court’s June 2025 decision in Trump v. CASA, Inc., federal district judges can no longer issue the broadest version of them. The Court held that universal injunctions “likely exceed the equitable authority that Congress has given to federal courts” and limited injunctive relief to what is necessary to make the actual plaintiffs whole.1Justia. Trump v. CASA, Inc., 606 US (2025) That ruling reshapes how any challenge to a federal policy now plays out.
What the Terms Actually Mean
The labels get used loosely, but they describe three different things, and the difference controls who benefits from a win in court.
A traditional injunction protects only the named plaintiffs. If you sued a federal agency over a regulation and won, the order would shield you. The agency could keep enforcing the same regulation against everyone else.
A nationwide injunction orders the government not to enforce a challenged policy anywhere in the country. The focus is the defendant’s conduct rather than the plaintiff’s protection, so people in distant states who never filed suit benefit because the government has been told to stop enforcing the policy everywhere.
A universal injunction goes one step further and affirmatively grants relief to non-parties, declaring that every person in the country is protected from the challenged action. Before CASA, a single district judge could effectively set policy for the entire country through one of these orders. That power is what drove the controversy and what the Supreme Court moved to curtail.
Trump v. CASA and the New Limit
On June 27, 2025, the Supreme Court partially stayed several lower-court orders that had blocked an executive order nationwide and used the occasion to settle the underlying question. The majority grounded its reasoning in history. Applying the framework from Grupo Mexicano de Desarrollo v. Alliance Bond Fund, the Court held that federal courts possess only those equitable remedies “traditionally accorded by courts of equity” at the country’s founding. A modern remedy does not need an exact historical twin, but it has to have a founding-era antecedent. Universal injunctions have none. The Court wrote that “under longstanding equity practice in England, there was no remedy remotely like a national injunction.”1Justia. Trump v. CASA, Inc., 606 US (2025)
The core of the holding is a distinction between “complete relief” and “universal relief.” Complete relief is the maximum a court can give the plaintiffs who actually sued. An injunction can sometimes benefit non-parties incidentally, but it cannot be designed to protect everyone in the country. The Court allowed the challenged injunctions to stand only “to the extent that the injunctions are broader than necessary to provide complete relief to each plaintiff with standing to sue.”1Justia. Trump v. CASA, Inc., 606 US (2025)
Justice Thomas, joined by Justice Gorsuch, concurred to emphasize that complete relief “is not a guarantee — it is the maximum a court can provide.” In Thomas’s framing, the complete-relief principle is a ceiling, not a floor, and courts should not stretch injunctions to burden the government more than necessary to fix the plaintiffs’ specific injuries.
Justice Kavanaugh concurred separately to flag that plaintiffs still have procedural options. They can pursue class certification under Federal Rule of Civil Procedure 23(b)(2) and potentially obtain classwide relief that is “statewide, regionwide, or even nationwide.”1Justia. Trump v. CASA, Inc., 606 US (2025)
Justice Sotomayor dissented. She argued that universal injunctions are consistent with centuries of equitable practice, pointing to English “bills of peace,” which allowed courts to settle disputes affecting whole communities in a single case to prevent a multiplicity of lawsuits. In her view, blocking a “flagrantly illegal policy” for everyone is sometimes the only way to deliver complete justice. Justice Jackson filed a separate dissent.1Justia. Trump v. CASA, Inc., 606 US (2025)
The Constitutional and Statutory Backdrop
The reasoning in CASA sits on top of a longer argument about what federal courts are for. Article III of the Constitution limits federal courts to resolving actual “cases” and “controversies,” which the Supreme Court has interpreted to mean that judicial power is the power to decide disputes between the specific parties who bring a case.2Legal Information Institute. Overview of Cases and Controversies That built-in constraint is meant to keep judges from acting as policy-makers at large.
Supporters of broader relief have pointed to Section 706 of the Administrative Procedure Act, which tells courts to “hold unlawful and set aside” agency actions that are arbitrary or contrary to law.3Office of the Law Revision Counsel. 5 USC 706 – Scope of Review The phrase “set aside” has become a battleground. One reading treats it as a command to wipe out the rule entirely, for everyone, once a court finds it unlawful. The other limits it to the parties in the case, treating the phrase as a direction to disregard the rule only as applied to the people who challenged it.
What Courts Can Still Do
Complete Relief to the Named Plaintiffs
A court can still order the government to stop enforcing the challenged policy against the plaintiffs standing before it, and the relief can be as thorough as those plaintiffs need. If an injunction happens to benefit non-parties as a practical side effect, that is permitted. What CASA prohibits is designing the order to shield everyone in the country.
Class Actions Under Rule 23(b)(2)
The procedural mechanism Kavanaugh pointed to allows a court to certify a class when the opposing party has acted on grounds that “apply generally to the class, so that final injunctive relief or corresponding declaratory relief is appropriate respecting the class as a whole.” The resulting order can look a lot like a universal injunction in practice, but class certification comes with guardrails that a standalone injunction never required. Plaintiffs must show that the class is too large for everyone to join individually, that common questions of law or fact exist, that the named plaintiffs’ claims are typical of the class, and that the representatives will adequately protect the class’s interests.4Legal Information Institute. Rule 23 – Class Actions
These requirements force a slower, more rigorous process than what used to be needed. A single plaintiff can no longer secure protection for the whole country without any class certification at all. The tradeoff is speed: class certification takes time, involves heightened evidentiary standards, and is subject to interlocutory appeal. For plaintiffs trying to block a government policy urgently, the class action path is less certain.
APA Vacatur, With a Question Mark
The CASA ruling addressed injunctions, not the separate question of whether a court can vacate an agency rule under APA Section 706. Vacatur and injunctions are different remedies. An injunction orders a party to do or stop doing something; vacatur declares the rule itself void. In practice, vacating a rule has the same universal effect as a universal injunction because the rule no longer exists for anyone. A Congressional Research Service analysis noted that CASA “cast doubt” on whether universal vacatur under the APA remains available but did not directly address it, and observed that litigants seeking broad relief may now shift toward vacatur even as the legal status of that remedy “may become more precarious.”5Congress.gov. Set Aside and Vacatur Under the Administrative Procedure Act The Supreme Court has never squarely decided whether “set aside” authorizes universal vacatur.
Who an Injunction Binds
Even a party-specific injunction reaches further than just the named plaintiffs and defendants. Federal Rule of Civil Procedure 65(d)(2) specifies that an injunction binds the parties themselves, their officers, agents, employees, and attorneys, and any “other persons who are in active concert or participation” with those individuals, provided they have actual notice of the order.6Legal Information Institute. Rule 65 – Injunctions and Restraining Orders
The “active concert” provision is what gives a party-specific injunction practical reach beyond the courtroom. A federal agency enjoined from enforcing a regulation cannot simply delegate enforcement to a contractor or state partner to work around the order. Anyone who knowingly helps the enjoined party violate the injunction can face contempt, even if they were never named in the lawsuit.
The flip side matters too. Before a non-party can be held in contempt, the court must establish that the person had actual notice of the order and acted in concert with the enjoined party. Formal service is not required, but the non-party must have genuinely known about the injunction. This protects people who independently engage in conduct that happens to overlap with what the injunction prohibits. Rule 65(d)(2) becomes more important after CASA because courts can no longer extend protection to everyone through a universal order.
Other Checks on Broad Injunctions
Random Case Assignment
Forum shopping was one of the practical problems that built pressure against universal injunctions in the first place. Plaintiffs would file in a specific judicial division, sometimes one with a single sitting judge, knowing exactly who would hear the case. In March 2024, the Judicial Conference of the United States strengthened its policy on random case assignment to address this. Under the new policy, any civil case seeking to block or mandate state or federal action through injunctive or declaratory relief must be assigned through a district-wide random process rather than being routed to the division where it was filed. If a division has only one judge, filing there no longer guarantees that judge will hear the case. Routine cases that do not seek to block government action are unaffected.7United States Courts. Conference Acts to Promote Random Case Assignment
Bills in Congress
Congress has not stopped working on the question. At least two bills introduced in 2025 would restrict broad injunctive relief by statute. Senator Josh Hawley’s Nationwide Injunction Abuse Prevention Act would limit the scope of relief available in district courts.8Congress.gov. S 1099 – Nationwide Injunction Abuse Prevention Act of 2025 Senator Chuck Grassley’s Judicial Relief Clarification Act takes a similar approach, prohibiting lower courts from issuing orders that apply to non-parties and making temporary restraining orders against the government immediately appealable.9Congress.gov. S 1206 – Judicial Relief Clarification Act of 2025 Both bills were referred to the Senate Judiciary Committee. Whether either advances may depend on whether CASA is seen as having already handled the problem through the courts.