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How did the Supreme Court rule on the constitutionality of Obama's immigration executive actions in 2016?
Executive summary
The Supreme Court in United States v. Texas ended in an equally divided 4–4 tie on June 23, 2016, which left the lower-court injunction blocking President Obama’s DAPA program and the planned DACA expansion in place and thus prevented those programs from taking effect [1] [2]. Because the Court was short one justice, its one-line affirmance “by an equally divided Court” provided no precedent on the constitutional merits of the executive actions [1] [3].
1. A rare tie decided the fate of Obama’s executive actions
The Court’s decision was not a majority opinion but a nine‑word judgment that “The judgment is affirmed by an equally divided court,” meaning there was a 4–4 split after Justice Antonin Scalia’s death left the Court with eight justices—so the injunction from the Fifth Circuit remained in force and the programs stayed blocked [1] [2].
2. What exactly was blocked — DAPA and DACA expansion
The litigation—brought by Texas and 25 other states—challenged the Deferred Action for Parents of Americans and Lawful Permanent Residents (DAPA) program and an expansion of the Deferred Action for Childhood Arrivals (DACA) program; those programs together were estimated to affect up to about 4 million people and to provide protection from deportation and eligibility for work authorization [4] [5] [3].
3. Why the tie matters — no Supreme Court precedent
Because the Court issued an affirmance by an equally divided court without a majority opinion, the decision did not resolve the constitutional or statutory questions about whether the president could adopt these deferred‑action programs; it simply left the Fifth Circuit’s ruling and its nationwide injunction intact. That means the high court’s tie provided no binding guidance for future cases on the limits of executive power in immigration [1] [2].
4. How the short-handed Court and politics intersected
The split reflected the practical reality that the Court had eight justices at the time after Scalia’s death and Senate Republicans delayed a nomination, a political dynamic explicitly linked in reporting and commentary to the outcome: with no ninth justice, a tie was a real possibility and, in this case, effectively decided the fate of the programs for the remainder of Obama’s term [1] [6].
5. Competing legal narratives — executive discretion vs. unlawful lawmaking
The Obama administration framed the deferred‑action initiatives as lawful exercises of long‑standing prosecutorial discretion by immigration officials and “guidance” on enforcement priorities [4]. By contrast, the states and some conservative commentators argued the programs were an unconstitutional unilateral change to immigration law and an overreach of executive authority [7] [8]. The Court’s tie left these competing claims unresolved [4] [8].
6. Immediate practical consequences of the tie
Practically, because the injunction remained in place, the DAPA program and the DACA expansion could not be implemented during the remainder of the Obama administration; the case returned to lower courts and could potentially return to the Supreme Court in a future term if reinstated or if a full Court heard it [2] [9].
7. How stakeholders reacted — predictable partisan responses
Reactions split along predictable lines: the Obama White House called the result a setback and urged continued efforts for legislative reform [9], while state attorneys general and Republican officials hailed the outcome as a defense of separation of powers [10]. Immigrant‑advocacy voices described the decision as heartbreaking for families who would have benefited [6] [11].
8. The longer view — legacy and subsequent developments
Analysts noted the tie as a significant blow to Obama’s immigration legacy and observed that the issue would return to the political arena — notably Congress and future administrations — because the Court’s tie did not settle the legal questions and left implementation dependent on lower courts or later presidential action [3] [12].
Limitations: Available sources in this set report the procedural outcome (a 4–4 tie leaving the injunction in place) and summarize competing arguments, but they do not include the full briefs, internal deliberations of the Justices, or any later litigation developments beyond commentary; those items are not found in the current reporting provided here [1] [2].