Which district-court opinions in 2025 were most cited by the Supreme Court in Trump v. CASA, and why?
Executive summary
The Supreme Court’s opinion in Trump v. CASA repeatedly cites three district-court opinions from early 2025 — the District of Maryland’s CASA opinion, the Western District of Washington’s decision, and a Massachusetts district-court preliminary injunction — because those orders exemplified the contemporary surge of “universal” or nationwide preliminary injunctions that the Court treated as the factual hook for reconsidering equitable relief limits [1] [2] [3].
1. Which district-court opinions did the Supreme Court rely on most?
The Court pointed explicitly to three overlapping district-court injunctions: the Maryland district court’s preliminary injunction in CASA, the Western District of Washington’s nationwide injunction, and a Massachusetts district-court nationwide preliminary injunction — characterizing them collectively as the three universal preliminary injunctions at issue in the applications before the Court [1] [2].
2. How the record shows those were the focal district opinions
The Supreme Court’s opinion describes “three overlapping, universal preliminary injunctions entered by three different District Courts” and cites the Maryland and Washington decisions by docket and reporter references while noting appeals and stays in the courts of appeals — language that singles out those district opinions as the concrete instances motivating the Court’s remedial ruling [1] [4].
3. Why the Court emphasized those district rulings — the doctrinal rationale
The majority framed its ruling around whether federal courts may issue injunctions “against anyone” and rooted its limit in the statutory text and structure of the Judiciary Act of 1789, treating the district orders as illustrative of a remedial practice that, the majority held, exceeded the authority Congress authorized for equitable relief [3] [2].
4. Factual and policy context the Court used from the district opinions
The district decisions were presented as part of a broader empirical pattern: the Court and amici pointed to dozens of nationwide injunctions issued in the early months of the administration, and the Maryland/Washington/Massachusetts injunctions were cited as emblematic of that “one-way” effect when a single court bars enforcement nationwide [1] [5] [6].
5. What the majority took from the district opinions — and what it left open
While the Court curtailed universal injunctions generally, it expressly left a “complete relief” exception derived from equitable principles and illustrated by certain district-court remedies, and it cited examples where full relief to a plaintiff inevitably benefits others; thus the Court used the district rulings both to justify a rule and to carve out situations where nationwide relief might still be warranted [3] [2].
6. Counterarguments and the dissent’s reliance on district courts
Dissenting justices, most forcefully Justice Jackson as reported, defended the district courts’ remedial judgments as necessary to vindicate rights and criticized the majority for treating district opinions as mere overreach rather than law-declaring judgments; the dissents leaned on the same factual posture — multiple district courts finding the Executive Order likely unlawful — to argue for preserving broad injunctive relief [2] [7].
7. Strategic agendas visible in the citations
The Government emphasized the nationwide scope of those specific district orders in its emergency applications to the Supreme Court to narrow equitable remedies, while advocates for plaintiffs immediately sought class certification and new nationwide relief after the decision — both tactical moves reflect why the Court foregrounded those district opinions as consequential precedents in practice as well as law [5] [8] [6].