What Supreme Court rulings since 2024 have changed how nationwide injunctions are issued?
Executive summary
The Supreme Court’s most consequential change since 2024 is its June 27, 2025 decision in Trump v. CASA, Inc., which the Court held substantially curtails the ability of lower federal courts to issue “universal” or nationwide injunctions that bind nonparties [1] [2]. That ruling narrows the remedy available in many challenges to presidential and agency actions, while leaving open alternate paths such as class certification and unresolved questions under the Administrative Procedure Act [3] [4].
1. The headline ruling: Trump v. CASA—what changed and why
In a 6–3 decision, the Court concluded that federal courts lack the equitable authority under the Judiciary Act of 1789 to issue nationwide injunctions as a general matter, reasoning that equity remedies historically were party-specific and did not authorize universal relief barring enforcement of executive actions as to nonparties [2] [5]. The majority partially stayed three district-court nationwide injunctions blocking the President’s birthright-citizenship executive order and emphasized that district courts may not provide relief that extends beyond the parties before them unless traditional equitable practice supports it [1] [6].
2. Concurrences and dissents: fissures in reasoning and remaining levers
Justice Alito’s concurrence flagged concerns about third‑party standing and class certification, urging strict enforcement of standing doctrines and “scrupulous adherence” to Federal Rule of Civil Procedure 23—warnings lower courts may use to limit broad relief even when class actions are pursued [3]. Dissenting Justices Ketanji Brown Jackson and Sonia Sotomayor argued the decision guts judicial protection against unconstitutional executive action and urged class remedies as a practical buffer; Jackson warned the ruling allows executive conduct to escape nationwide restraint until many individual suits are litigated [1] [7].
3. What the Court left open: the APA, vacatur, and class litigation
The majority expressly did not resolve whether and how relief under the Administrative Procedure Act—such as vacatur of agency rules—permits nationwide remedies, meaning that remedies functionally similar to universal injunctions might survive in APA suits or via nationwide class certification [4] [3]. Commentators and practitioners immediately noted that plaintiffs are likely to shift strategies toward certified class actions and APA vacatur claims, and that the procedural rigors of Rule 23 now become a gatekeeper to broad relief [2] [5].
4. Practical ripple effects: litigation strategy, forum shopping, and enforcement gaps
Law firms, advocacy groups, and local-government coalitions warned that the CASA ruling forces affected parties to race to certify nationwide classes or litigate multiple suits in different districts, increasing burdens on plaintiffs and producing potential patchwork enforcement of federal policy across states and employers [6] [8]. Critics such as the Campaign Legal Center argued the ruling reduces judicial tools to protect nationwide rights against unconstitutional presidential actions, while the White House framed the decision as restoring separation-of-powers limits on “rogue” district judges [9] [10].
5. Context from 2024 and the Court’s broader trajectory
Before CASA, the Court’s 2024 term included opinions and concurrences that signaled willingness to revisit the scope of nationwide relief—most notably Justice Thomas’s concurrence in FDA v. Alliance for Hippocratic Medicine and broader debate in the Court’s docket about universal injunctions’ history and legitimacy [2] [11]. CASA crystallized those signals into a binding rule that limits universal injunctions, while acknowledging historic equitable practice and leaving procedural and statutory pathways for broad relief to be litigated further [11] [5].
6. Bottom line and open questions for future cases
The clear doctrinal change since 2024 is the Court’s repudiation of unfettered nationwide injunctions in Trump v. CASA, redirecting litigants toward class certification, standing arguments, and APA remedies—but the decision intentionally leaves unresolved whether vacatur or other judicial tools can produce equivalent nationwide effect, and it invites future litigation over both procedural standards and the scope of state standing [4] [3]. Reporting and legal commentary uniformly signal that CASA reshapes remedial strategy without closing all avenues to nationwide relief, creating an unsettled landscape that will be clarified in coming cases [7] [5].