So-called “universal” injunctions—court orders that bar the government from enforcing a challenged policy against anyone, not just the plaintiffs in a case—have been a feature of litigation against the Trump administration. Or at least they were. In last Friday’s decision in Trump v. CASA, the Supreme Court limited the availability of such injunctions, paring back the universal relief that had been provided by three district courts in challenges to President Donald Trump’s executive order on birthright citizenship. Still, CASA leaves plaintiffs with several avenues to obtain relief that approximates the scope of the erstwhile universal injunction.
