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Nationwide injunction

In United States law, a nationwide injunction is injunctive relief in which a court binds the federal government even in its relations with nonparties. In their prototypical form, nationwide injunctions are used to restrict the federal government from enforcing a statute or regulation.

History before the American founding
Professor Samuel Bray has said early equity practice included "nothing remotely like a national injunction", Courts did have the equitable power to enjoin defendants with regard to the plaintiff, but typically not the world at large. In cases where multiple parties had a common claim against the same defendant, the British chancellor sometimes offered a remedy known as a "bill of peace." The bill of peace bound the defendant against that group of parties with a common claim, regardless of whether they were all parties in the case. For example, if several tenants brought a claim against a landlord that they shared in common with all tenants, then the court of equity might issue a remedy that applied to the landlord's relations with those tenants not before the court. This order only applied to the defendant's interactions with an identified group of similarly situated nonparties, rather than the entire world, and it depended on the group being small enough and enough actual claims being brought by members of the group. == History in the United States federal courts ==
History in the United States federal courts
First 175 years For the first 175 years of the republic, courts typically did not enjoin defendants with respect to nonparties, especially if that defendant was the federal government. Some scholars have estimated that American federal courts issued a dozen nationwide injunctions during this time, while others have estimated that American federal courts issued zero nationwide injunctions during this time. In the nineteenth century, courts occasionally enjoined a municipality or county from enforcing a challenged tax or ordinance against nonparties. This was considered an extension of the "bill of peace" because it resolved a common claim by a small and cohesive group. One explanation for the lack of nationwide injunctions is that the federal government itself waived its sovereign immunity from suit in 1976, while another is that venue and personal jurisdiction rules for a long time restricted litigants from suing cabinet officers outside of Washington, D.C., when seeking injunctions. Some cases from this period raised questions about the lawfulness of nationwide injunctions or closely related remedies. • Scott v. Donald (1897) — James Donald sued the state of South Carolina for confiscating his alcohol under a statute he argued violated the federal Constitution. In addition to damages, Donald asked the court to enjoin the state from enforcing the statute against anyone. Despite agreeing that the statute was unconstitutional, Professor Mila Sohoni interpreted the Lewis Publishing order as an "injunction barring the enforcement of the new federal law against anyone until the merits had been decided." • Frothingham v. Mellon (1923) — Harriet Frothingham sued the federal government for spending money under the Maternity Act, which she argued exceeded the powers of the federal government. She asked the Supreme Court to enjoin the government from carrying out the provisions of this act with regard to her and nonparties alike. New Deal challenges After the federal courts held numerous acts of New Deal legislation unconstitutional, they did not issue nationwide injunctions. Sometimes over a thousand individual injunctions were granted with regard to a single provision, as each plaintiff brought suit to ensure that the statute could not apply to them. According to the Department of Justice, nationwide injunctions remained "exceedingly rare" for a few decades after 1963. However, in 1968, the Supreme Court in Flast v. Cohen noted in dicta and without condemnation that "injunctive relief sought by appellants . . . extends to any program that would have the unconstitutional features alleged in the complaint," rather than merely to those programs injuring the plaintiff. And in 1973, a district judge in New York granted a preliminary injunction against the Interstate Commerce Commission that would "affect the agency in the entire scope of its authority and jurisdiction." Courts issued an average of 1.5 nationwide injunctions per year against the Reagan, Clinton, and George W. Bush administrations. In 1998, the District of Columbia Circuit upheld a nationwide injunction against the Army Corps of Engineers, preventing it from enforcing against anyone a rule it had promulgated under the Clean Water Act. It held that after finding an agency rule or regulation unconstitutional under the Administrative Procedure Act, a federal court should ordinarily "vacate" the rule or regulation rather than merely hold it unlawful with respect to the plaintiffs. and a 2004 holding of Judge Reggie Walton enjoining the federal government from enforcing a policy it established under the Endangered Species Act. Judge Walton reasoned that a nationwide injunction was appropriate "because the declaratory judgment alone is inadequate when a policy is found to be facially invalid." Obama administration According to the Department of Justice, federal courts issued 19 or 20 nationwide injunctions against the Obama administration, including many on high-profile legal and political issues. Judge Reed O'Connor of the Northern District of Texas issued a nationwide injunction to prevent the Obama administration from issuing its guidance that Title IX required institutions to allocate bathroom accessibility based on gender identity rather than biological sex. When the Department of Justice requested that Judge O'Connor narrow relief to the plaintiff states, he declined to do so. Judge Sam R. Cummings of the Northern District of Texas issued a nationwide injunction to prevent the Obama Administration from issuing a rule that would require employers to disclose certain activities with third parties related to dissuading labor unions. And Judge Virginia A. Phillips of the Central District of California held in 2010 that the federal government's "Don't Ask, Don't Tell" policy was unconstitutional and permanently enjoined the Secretary of Defense from enforcing it. First Trump administration According to the Department of Justice, federal courts issued 20 nationwide injunctions against the first Trump Administration in its first year alone, The following month, Judge Derrick K. Watson of the District of Hawaii issued a nationwide injunction to prevent the administration from implementing an executive order amending its entry restrictions. In April 2017, Judge William Orrick of the Northern District of California issued a nationwide injunction to prevent the administration from restricting funding to "sanctuary cities." Judge Orrick reasoned that "where a law is unconstitutional on its face, and not simply in its application to certain plaintiffs, a nationwide injunction is appropriate." In December 2017, Judge Marsha J. Pechman issued a nationwide injunction to prevent the administration from enforcing its transgender military ban. In early 2019, Judge Richard Seeborg of the Northern District of California issued a nationwide injunction preventing the Department of Commerce from asking census takers if they are United States citizens. In December 2019, Judge David Briones of the Western District of Texas issued a nationwide injunction to prevent the administration from using certain funds to erect a border wall. Also in 2019, Judge Jon S. Tigar of the Northern District of California issued a nationwide injunction to prevent the Department of Justice and Department of Homeland Security from implementing a rule regulating asylum eligibility. And multiple judges issued nationwide injunctions to prevent the Department of Homeland Security from rescinding the Deferred Action for Childhood Arrivals program, and the Ninth Circuit affirmed one such injunction. Biden administration Fourteen national injunctions occurred in the first three years of Biden's term. Second Trump administration As of April 2025, federal judges have issued three federal injunctions against the Trump administration's efforts to rollback protections of the 14th amendment to the United States constitution. Courts have issued at least 14 other nationwide injunctions against the second Trump administration. On June 27, 2025, the United States Supreme Court ruled in Trump v. CASA, Inc. that federal courts do not have the authority to issue universal injunctions, on the basis that "Congress has granted federal courts no such power" and that nationwide injunctions were not practiced when the Judiciary Act of 1789 created federal courts' jurisdiction over suits in equity. == Controversy surrounding lawfulness ==
Controversy surrounding lawfulness
Justices and judges The Supreme Court has not decided whether nationwide injunctions are lawful, but some justices have criticized the practice. Another Ninth Circuit panel has said that the Administrative Procedure Act mandates nationwide injunctions. A Fifth Circuit panel has held that nationwide injunctions are appropriate because district courts exercise "the judicial power" of the entire United States, not just a smaller territory, and because in certain contexts—like immigration—uniformity is required. On the other hand, Judge Nicholas Garaufis of the Eastern District of New York has expressed concerns about the constraining effect of nationwide injunctions on future litigation, where another court might be inclined to rule the other way on the merits but cannot do so because that would conflict with the injunction issued by a sister court. He has argued that nationwide injunctions through a national "class action" are "presumptively inappropriate," but may be lawful when the plaintiffs are asserting clearly established rights, the plaintiffs' rights are indivisible, the plaintiffs' claims are based on the burdens of the unconstitutionality of the challenged provisions, and it would be inappropriate to issue a narrower injunction. Professor Mila Sohoni has argued that nationwide injunctions are both constitutional and good. Hausman and Amdur advocate such injunctions "when necessary to prevent real-world injuries," under a framework that "would otherwise preserve opportunities for percolation across multiple chancellors." Executive branch The executive branch has often criticized the practice of nationwide injunctions. On March 10, 2018, Attorney General Jeff Sessions authored an op-ed in National Review calling nationwide injunctions "a threat to our constitutional order." "Nationwide injunctions," Sessions wrote, "mean that each of the more than 600 federal district judges in the United States can freeze a law or regulation throughout the country—regardless of whether the other 599 disagree." Consistent with "the Department's considered and longstanding" opposition to nationwide injunctions, Attorney General Sessions instructed litigators to argue before courts that nationwide injunctions(1) exceed the constitutional limitations on judicial power; (2) deviate from longstanding historical exercise of equitable power; (3) impede reasoned discussion of legal issues among the lower courts; (4) undermine legal rules meant to ensure orderly resolution of disputed issues; (5) interfere with judgments proper to the other branches of government; and (6) undermine public confidence in the judiciary. He criticized the effect of nationwide injunctions on legislative and judicial deliberations, and on the limited power Article III grants to judges—especially the solo district court judges who typically issue these injunctions. At the hearing, Samuel Bray, Hans von Spakovsky, Amanda Frost and Michael Morley discussed the legal issues surrounding the practice. On September 7, 2018, Representative Bob Goodlatte introduced the "Injunctive Authority Clarification Act of 2018." The Act did not make it to a vote, but it would have amended the United States Code to provide that:No court of the United States (and no district court of the Virgin Islands, Guam, or the Northern Mariana Islands) shall issue an order that purports to restrain the enforcement against a non-party of any statute, regulation, order, or similar authority, unless the non-party is represented by a party acting in a representative capacity pursuant to the Federal Rules of Civil Procedure. The Act would amend the United States Code to provide that "no district court may issue any order providing injunctive relief unless the order is applicable only to (1) the parties to the case before the district court; or (2) the judicial district in which the order is issued." On February 25, 2020, the Senate Committee on the Judiciary held a hearing on "Rule By District Judge: The Challenges of Universal Injunctions," considering an array of perspectives on the rise of the nationwide injunctions and the possible policy solutions. Committee Chairman Senator Lindsey Graham noted his concern that "I don't think you can run a country this way" and Senator Dianne Feinstein expressed her interest in learning more about the practice, as she "was not really familiar with what a nationwide injunction is," but noted that nationwide injunctions helped protect hundreds of thousands of DACA recipients from deportation. "[I]in light of the complete absence of even a claim of harm in the nonplaintiff States," they wrote, "there is no basis for forcing the injunction on us." and at the 2019 Federalist Society Western Chapters Conference, as well as in the National Constitution Center's "We The People" podcast. Various media outlets have criticized the practice. In 2015, the Daily Kos published an article on "How conservative federal judges in Texas are putting a stranglehold on President Obama's policies." The article explained:An unsettling pattern has emerged in Texas of federal district judges issuing nationwide injunctions on policies put forward by the Obama administration. In other words, judges from the most conservative circuit in the nation are overriding the federal government and dictating policy nationwide from their benches in Texas. It argued that the nationwide injunction has "become increasingly common over the past few decades as political activists try to enlist judges to make the kind of widespread policy changes that the legislative or executive branches are designed to handle." == Terminology ==
Terminology
The legal world has yet to come to a consensus about what to call these injunctions. Jesse Panuccio has argued these injunctions should be called "non-party injunctions." == References ==
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