What Employers Need to Know About the Fate of Wider Relief After Trump v. CASA, Inc.

On June 27, 2025, in Trump v. CASA, Inc., the U.S. Supreme Court held that universal injunctions—injunctions that prohibit the federal government from enforcing a law, regulation, order, or policy to any person, not just the plaintiffs—likely exceeded the equitable authority that Congress gave to federal courts in the Judiciary Act of 1789. In doing so, the Court partially stayed the district court’s universal injunction of Executive Order No. 14160, which redefined eligibility for birthright citizenship, allowing the injunction to proceed only as to the plaintiffs in the case. 

Because plaintiffs use requests for wider relief like universal injunctions to challenge labor-and employment-related regulations and executive orders, employers are frequently left with this choice: prepare to comply with a new executive order or regulation or wait for a court to intervene. CASA’s holding significantly limits a district court’s ability to intervene to disrupt the implementation of executive orders. But even after CASA, courts maintain the authority to set aside federal agencies’ actions under the Administrative Procedure Act (APA). This allows plaintiffs to achieve similar results to a universal injunction because the relief can halt the agency’s action for all impacted by it. Plaintiffs may also seek wider relief by filing class actions or relying on “associational” standing.

Factual Backdrop and the Court’s Reasoning 

Following Executive Order No. 14160, which identifies circumstances in which a person born in the United States is not an American citizen, advocacy organizations and states sued the federal government to prevent it from enforcing the executive order. Three district courts granted preliminary injunctions, preventing the government from enforcing the executive order.  

The federal government sought emergency relief from the Supreme Court, seeking to limit the injunctions to the plaintiffs only. The government argued the injunctions’ application to non-parties exceeded the authority Congress gave to federal courts through the Judiciary Act of 1789.  The Court agreed, concluding that the federal government was likely to succeed on the merits of its argument that the scope of relief was too broad. 

Writing for the majority, Justice Amy Coney Barrett began with statute, explaining the Judiciary Act grants federal courts jurisdiction over “all suits . . . in equity.”  This power to order equitable remedies, according to Supreme Court precedent, encompasses only those types of equitable remedies “traditionally accorded by courts of equity” at the country’s founding. The Court reasoned that universal injunctions were not analogous to the relief equity courts issued at the time of the enactment of the Judiciary Act. Federal courts, therefore, exceeded their authority by granting these remedies. 

CASA’s Impact on Agency Regulations 

Although the Court framed the question as whether federal courts may “universally enjoin the enforcement of an executive or legislative policy,” the holding barring universal injunctions does not apply to many actions by federal agencies.

The APA, which governs how federal agencies create and enforce regulations, gives courts authority to “set aside agency action” under specified circumstances. Many plaintiffs who seek wider relief move to do so under this provision. For example, the plaintiffs in Ryan LLC v. FTC, who successfully moved a federal district court in Texas for a nation-wide injunction to stop the Federal Trade Commission’s (FTC) ban on non-compete agreement in 2024, successfully sought relief under this provision. CASA does not preclude parties from seeking wider relief under the APA. Footnote 10 in the opinion states, “[n]othing we say today resolves the distinct question whether the Administrative Procedure Act authorizes federal courts to vacate federal agency action,” citing to the APA’s provision that permits courts to set aside “agency action.” 

CASA also left open other common methods for getting wider relief. For example, it left untouched a plaintiff’s ability to file a class-action lawsuit. Class actions allow a single plaintiff or small group of plaintiffs to represent a wider, similarly situated group. Class actions can often achieve much the same results as universal injunctions (though they must comply with procedural limitations set out in the Federal Rules of Civil Procedure). Likewise, CASA did nothing to change so-called associational standing, which allows an association or industry group to sue on behalf of its members. Like a class action, an associational suit can achieve wider relief for a group without joining each member of the group as a plaintiff. 

What Does CASA Mean for Employers?

Courts have halted many labor- and employment-related regulations and executive orders over the last decade. These are just a few of them:

• Coalition of Federal Unions v. Trump (2025): Federal district court enjoined an executive order revoking collective bargaining rights for many federal workers.
• Ryan LLC v. FTC (2024): Federal district court enjoined the FTC’s ban on non-compete agreements.
• Flint Avenue v. U.S. Department of Labor (2024): Federal district court enjoined the Department of Labor (DOL) from raising the salary threshold for nonexempt status under the Fair Labor Standards Act.
• AFL-CIO v. Trump (2020): Federal district court enjoined executive order restricting diversity training by federal contractors and agencies.
• Texas v. EEOC (2018): Federal court issued injunction limiting the Equal Employment Opportunity Commission’s enforcement of guidance on criminal background checks.
• Nevada v. Department of Labor (2016): Federal district court enjoined DOL rule raising the salary threshold for nonexempt status under the FLSA. 

The clearest implication of CASA is the limiting impact on challenges to executive orders. Plaintiffs will now seek relief for the plaintiffs only, rather than any person subject to the executive order. This means that the current injunctions to President Trump’s executive orders will be limited to the parties in those cases only; the executive orders will remain in place for all others.  This will provide a bit more certainty for employers. Previously, employers were left guessing whether an executive order would go into effect or whether a court would halt it before it ever reached the employer. CASA significantly restrains a court’s ability to stop an executive order from going into effect. 

Limiting plaintiffs’ ability to seek universal injunctions will likely cause an increase in plaintiffs’ seeking injunctive relief on behalf of putative class—a class not yet certified—under Federal Rule of Civil Procedure 23. While the government argued courts may not grant injunctive relief to a class not yet certified—under the premise that only a certified class can result in judgments that bind the whole class—the Court did not address this issue, leaving this form of relief undisturbed.  

The less-certain implication from CASA is its impact on agencies. In the short term, plaintiffs may still ask courts to set aside agencies’ actions under the APA. This means that challenges to agency rules and regulations—like the challenges to the FTC’s ban on non-competes in Ryan LLC v. FTC or the DOL’s attempt to raise the salary threshold—will be unscathed; wider relief is still an available remedy for challenges to those rules and regulations. The type of uncertainty employers faced last year—when deciding whether to change their practices with restrictive covenants or employees’ classification for nonexempt status or wait to see if courts intervene—is not going anywhere. 

In the long term, however, a court’s power to set aside agencies’ actions under the APA is less certain. The Supreme Court did not address specific arguments, like whether Article III permits universal relief, that could impact universal remedies under the APA. The government may challenge universal remedies under the APA in the future, but, for now, these remedies remain viable.  

Whenever employers face a new agency regulation or executive order that could impact their business, the recommended course is to consult with an attorney to determine how they can best achieve their business objectives while meeting their obligations under the law.