Description: Washington, DC - Civil rights lawyers represented Plaintiff seeking enjoin President Trump’s Executive Order No. 14160. Protecting the Meaning and Value of American Citizenship, 90 Fed. Reg. 8449.

Universal injunctions likely exceed the equitable authority that
Congress has given to federal courts. The Court grants the Govern-
ment’s applications for a partial stay of the injunctions entered below,
but only to the extent that the injunctions are broader than necessary
to provide complete relief to each plaintiff with standing to sue. Pp. 4–
26.

(a) The issue raised by these applications—whether Congress has
granted federal courts authority to universally enjoin the enforcement
of an executive order—plainly warrants this Court’s review. On mul-
tiple occasions, and across administrations, the Solicitor General has
asked the Court to consider the propriety of this expansive remedy. As
the number of universal injunctions has increased over the years, so
too has the importance of the issue. Pp. 4–5.

(b) The Government is likely to succeed on the merits of its claim
that the District Courts lacked authority to issue universal injunc-
tions. See Nken v. Holder, 556 U. S. 418, 434 (holding that for a stay
application to be granted, the applicant must make a strong showing
of likelihood of success on the merits). The issuance of a universal in-
junction can be justified only as an exercise of equitable authority, yet
Congress has granted federal courts no such power. The Judiciary Act
of 1789 endowed federal courts with jurisdiction over “all suits . . . in
equity,” §11, 1 Stat. 78, and still today, this statute “is what authorizes
the federal courts to issue equitable remedies,” S. Bray & E. Sherwin,
Remedies 442. This Court has held that the statutory grant encom-
passes only those sorts of equitable remedies “traditionally accorded
by courts of equity” at our country’s inception. Grupo Mexicano de De-
sarrollo, S. A. v. Alliance Bond Fund, Inc., 527 U. S. 308, 319.

Universal injunctions are not sufficiently “analogous” to any relief
available in the court of equity in England at the time of the founding.
Grupo Mexicano, 527 U. S., at 318–319. Equity offered a mechanism
for the Crown “to secure justice where it would not be secured by the
ordinary and existing processes of law.” G. Adams, The Origin of Eng-
lish Equity, 16 Colum. L. Rev. 87, 91. This “judicial prerogative of the
King” thus extended to “those causes which the ordinary judges were
incapable of determining.” 1 J. Pomeroy, Equity Jurisprudence §31,
p. 27. Eventually, the Crown instituted the “practice of delegating the
cases” that “came before” the judicial prerogative “to the chancellor for
his sole decision.” Id., §34, at 28. The “general rule in Equity [was]
that all persons materially interested [in the suit] [were] to be made
parties to it.” J. Story, Commentaries on Equity Pleadings §72, p. 74
(Story). Injunctions were no exception; there were “sometimes suits to
restrain the actions of particular officers against particular plaintiffs.”
S. Bray, Multiple Chancellors: Reforming the National Injunction, 131
Harv. L. Rev. 417, 425 (Bray, Multiple Chancellors).3Cite as:

here, suits in equity were brought by and against individual parties,
and the Chancellor’s remedies were generally party specific. See Ive-
son v. Harris, 7 Ves. 251, 257, 32 Eng. Rep. 102, 104 (“[Y]ou cannot
have an injunction except against a party to the suit”). In sum, under
longstanding equity practice in England, there was no remedy “re-
motely like a national injunction.” Bray, Multiple Chancellors 425.
Nor did founding-era courts of equity in the United States chart a
different course. If anything, the approach traditionally taken by fed-
eral courts cuts against the existence of such a sweeping remedy. Con-
sider Scott v. Donald, where the plaintiff successfully challenged the
constitutionality of a law on which state officials had relied to confis-
cate alcohol that the plaintiff kept for personal use. See 165 U. S. 107,
109 (statement of case); id., at 111–112 (opinion of the Court). Alt-
hough the plaintiff sought an injunction barring enforcement of the
law against both himself and anyone “whose rights [were] infringed
and threatened” by it, the Court permitted only relief benefitting the
named plaintiff. Id., at 115–117. In the ensuing decades, the Court
consistently rebuffed requests for relief that extended beyond the par-
ties. See, e.g., Perkins v. Lukens Steel Co., 310 U. S. 113, 123; Froth-
ingham v. Mellon, decided with Massachusetts v. Mellon, 262 U. S.
447, 487–489.

The Court’s early refusals to grant relief to nonparties are consistent
with the party-specific principles that permeate the Court’s under-
standing of equity. “[N]either declaratory nor injunctive relief,” the
Court has said, “can directly interfere with enforcement of contested
statutes or ordinances except with respect to the particular federal
plaintiffs.” Doran v. Salem Inn, Inc., 422 U. S. 922, 931. In fact, uni-
versal injunctions were conspicuously nonexistent for most of the Na-
tion’s history. Their absence from 18th and 19th century equity prac-
tice settles the question of judicial authority.

While “equity is flexible,” Grupo Mexicano, 527 U. S., at 322, the
Court’s precedent emphasizes that its “flexibility is confined within the
broad boundaries of traditional equitable relief.” Ibid. Because the
universal injunction lacks a historical pedigree, it falls outside the
bounds of a federal court’s equitable authority under the Judiciary Act.
Pp. 5–11.

(c) Respondents’ counterarguments are unavailing. Pp. 11–21.

(1) In an effort to satisfy Grupo Mexicano’s historical test, re-
spondents claim that universal injunctions are the modern equivalent
of the decree resulting from a “bill of peace”—a form of group litigation
in the Court of Chancery. Respondents contend that the existence of
this historic equitable device means that federal courts have the equi-
table authority to issue universal injunctions under the Judiciary Act.
The analogy, however, does not work.

[courts of equity] to adjudicate the rights of members of dispersed
groups without formally joining them to a lawsuit through the usual
procedures.” Arizona v. Biden, 40 F. 4th 375, 397 (Sutton, C. J., con-
curring). Unlike universal injunctions, however, which reach anyone
affected by executive or legislative action, bills of peace involved a
“group [that] was small and cohesive.” Bray, Multiple Chancellors
426. And unlike universal injunctions, which bind only the parties to
the suit, decrees resulting from a bill of peace “would bind all members
of the group, whether they were present in the action or not.” 7A C.
Wright, A. Miller, & M. Kane, Federal Practice and Procedure §1751,
at 10.

The bill of peace lives in modern form, but not as the universal in-
junction. It is instead analogous to the modern class action—which, in
federal court, is governed by Rule 23 of the Federal Rules of Civil Pro-
cedure. See ibid. Rule 23 requires numerosity (such that joinder is
impracticable), common questions of law or fact, typicality, and repre-
sentative parties who adequately protect the interests of the class.
Fed. Rule Civ. Proc. 23(a). The requirements for a bill of peace were
virtually identical. See 7A Wright, Federal Practice and Procedure
§1751, at 10 and n. 4. By forging a shortcut to relief that benefits par-
ties and nonparties alike, universal injunctions impermissibly circum-
vent Rule 23’s procedural protections. Pp. 12–15.

(2) Respondents contend that universal injunctions—or at least
these universal injunctions—are simply an application of the principle
that a court of equity may fashion a remedy that awards complete re-
lief. But “complete relief” is not synonymous with “universal relief.”
It is a narrower concept, long embraced in the equitable tradition, that
allows courts to “administer complete relief between the parties.” Kin-
ney-Coastal Oil Co. v. Kieffer, 277 U. S. 488, 507 (emphasis added). To
be sure, party-specific injunctions sometimes “advantag[e] nonpar-
ties,” Trump v. Hawaii, 585 U. S 667, 717 (THOMAS , J., concurring),
but they do so only incidentally.

Here, prohibiting enforcement of the Executive Order against the
child of an individual pregnant plaintiff will give that plaintiff com-
plete relief: Her child will not be denied citizenship. And extending
the injunction to cover everyone similarly situated would not render
her relief any more complete. So the individual and associational re-
spondents are wrong to characterize the universal injunction as simply
an application of the complete-relief principle. The inquiry is more
complicated for the state respondents, because the relevant injunction
does not purport to directly benefit nonparties. Instead, the District
Court for the District of Massachusetts decided that a universal in-
junction was necessary to provide the States5Cite as: 606 U. S. ____ (2025)

lief. As the States see it, their harms—financial injuries and the ad-
ministrative burdens flowing from citizen-dependent benefits pro-
grams—cannot be remedied without a blanket ban on the enforcement
of the Executive Order. Children often move across state lines or are
born outside their parents’ State of residence. Given the cross-border
flow, the States say, a “patchwork injunction” would prove unworkable
for the provision of certain federally funded benefits. The Government
retorts that even if the injunction is designed to benefit only the States,
it is “more burdensome than necessary to redress” their asserted
harms, see Califano v. Yamasaki, 442 U. S. 682, 702, and that nar-
rower relief is appropriate. The Court declines to take up these argu-
ments in the first instance. The lower courts should determine
whether a narrower injunction is appropriate, so we leave it to them
to consider these and any related arguments. Pp. 15–19.
(3) Respondents defend universal injunctions as a matter of pol-
icy; the Government advances policy arguments running the other
way. As with most questions of law, the policy pros and cons are beside
the point. Under the Court’s well-established precedent, see Grupo
Mexicano, 527 U. S., at 319, because universal injunctions lack a
founding-era forebear, federal courts lack authority to issue them. Pp.
19–21.

(d) To obtain interim relief, the Government must show that it is
likely to suffer irreparable harm absent a stay. Nken, 556 U. S., at
434–435. When a federal court enters a universal injunction against
the Government, it “improper[ly] intru[des]” on “a coordinate branch
of the Government” and prevents the Government from enforcing its
policies against nonparties. INS v. Legalization Assistance Project of
Los Angeles County Federation of Labor, 510 U. S. 1301, 1306 (O’Con-
nor, J., in chambers); see also Maryland v. King, 567 U. S. 1301, 1303
(R OBERTS , C. J., in chambers) (“ ‘[A]ny time a State is enjoined by a
court from effectuating statutes enacted by representatives of its peo-
ple, it suffers a form of irreparable injury’ ” (alteration in original)).
The Court’s practice also demonstrates that an applicant need not
show it will prevail on the underlying merits when it seeks a stay on a
threshold issue. See, e.g., Gutierrez v. Saenz, 603 U. S. ___; OPM v.
AFGE, 604 U. S. ___. The Government here is likely to suffer irrepa-
rable harm from the District Courts’ entry of injunctions that likely
exceed the authority conferred by the Judiciary Act. And the balance
of equities does not counsel against awarding the Government interim
relief: A partial stay will cause no harm to respondents because they
will remain protected by the preliminary injunctions to the extent nec-
essary and appropriate to afford them complete relief. Pp. 24–26.
(e) When a court concludes that the Executive Branch has acted un-
lawfully, the answer is not for the court to exceed its power, too.

Government’s applications for partial stays of the preliminary injunc-
tions are granted, but only to the extent that the injunctions are
broader than necessary to provide complete relief to each plaintiff with
standing to sue.

Outcome: Applications for partial stays granted.

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