This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.
In brief
Overview
The Supreme Court held that universal injunctions exceed Article III judicial power because Congress has not granted federal courts the equitable authority to issue them.
Background and question before the Court
The central legal question is whether a federal court may issue a universal injunction—an injunction that applies to all persons or entities—when Congress has not expressly granted such equitable power.
What each side argues
Applicants (Donald J. Trump and Federal Officials)
Source-limited. The record does not yet support a complete account.
Respondents (CASA, Inc., States, and Others)
Respondents argue that universal injunctions provide complete relief consistent with equity, and that the Judiciary Act authorizes such relief.
What happened at oral argument
JUSTICE THOMAS: General Sauer, the — these universal injunctions, as you say, have proliferated over the last three decades or so. Would you discuss, though, the origins of universal injunctions?
According to Justice Sotomayor, jUSTICE SOTOMAYOR: I'm sorry. ... Does citizenship mean are you born in the territory of the United States, or does it mean are you loyal to someone else ...?
According to Justice GORSUCH, well, what do you say, though, to the suggestion that the patchwork problems for the government and plaintiffs justify broader relief?
According to Justice THOMAS, general, when were the first universal injunctions used?
According to Justice Thomas, you say the government is wrong about the availability of preliminary injunctions. On what do you base that?
According to Justice Kavanaugh, some of your concerns about this Court being involved, I guess I'm not sure I really understand that.
According to Justice Gorsuch, you don't get to squiggle out into the first bucket, okay? We're in the third bucket.
According to States, which is I think it requires having district courts consider the availability of the alternative and explaining why it's not workable in the case.
According to Justice Jackson, may a federal court in the United States of America order the Executive to follow the law?
- [1] cac4be8c76a563bcfab0-r1-f96a441c2d484a57.pdf, p. 7
- [2] cac4be8c76a563bcfab0-r1-f96a441c2d484a57.pdf, p. 8
- [3] cac4be8c76a563bcfab0-r1-f96a441c2d484a57.pdf, p. 25
- [4] cac4be8c76a563bcfab0-r1-f96a441c2d484a57.pdf, p. 38
- [5] cac4be8c76a563bcfab0-r1-f96a441c2d484a57.pdf, p. 128
- [6] cac4be8c76a563bcfab0-r1-f96a441c2d484a57.pdf, p. 151
- [7] cac4be8c76a563bcfab0-r1-f96a441c2d484a57.pdf, p. 88
- [8] cac4be8c76a563bcfab0-r1-f96a441c2d484a57.pdf, p. 88
- [9] a516c52cdcc5dff82dc5-r1-fb37a04b11076b76.pdf, p. 94
What the Court decided
A universal injunction can be justified only as an exercise of equitable authority, yet Congress has granted federal courts no such power.
Neither the universal injunction nor any analogous form of relief was available in the High Court of Chancery in England at the time of the founding.
Why it matters
The zone of lawlessness the majority authorizes will disproportionately impact the poor, the uneducated, and the unpopular, who lack resources to defend themselves.
According to Justice Jackson, courts must have the power to order everyone, including the Executive, to follow the law, especially when constitutional rights are at stake.
Terms to know
No glossary terms are available for this guide.
Primary sources
Read the source materials on the official site or open the immutable repository copy used for this guide.
- a516c52cdcc5dff82dc5-r1-fb37a04b11076b76.pdfopinion
- cac4be8c76a563bcfab0-r1-f96a441c2d484a57.pdforal argument transcript
Guide generated September 18, 2026. Automated validation accepted this version.