The Fourth Circuit Court of Appeals has upheld a nationwide injunction that blocks the enforcement of President Donald Trump’s executive order seeking to limit birthright citizenship. The decision, issued by a divided panel, reaffirms a district court’s authority to apply broad injunctions in cases where relief is necessary for both named plaintiffs and similarly situated individuals across the country.
District Courts’ Authority to Issue Broad Injunctions
The ruling emphasized that district courts hold significant discretion in shaping preliminary injunctions, including the ability to extend relief beyond the immediate parties to those who would face identical harm. The panel concluded that the federal government failed to demonstrate that the district court’s approach was an abuse of its discretion. As a result, the broad injunction was upheld, ensuring that similarly situated individuals nationwide would benefit from the order’s protections.
Dissenting View on Limiting the Injunction
One of the three judges on the panel, Circuit Judge Paul V. Niemeyer, dissented from the majority decision. Judge Niemeyer expressed that the injunction’s nationwide scope went beyond what was necessary to protect the identified plaintiffs, including several pregnant women and advocacy organizations. He argued that other district courts could handle similar claims, and a more tailored injunction would have been appropriate.
District Court’s Rationale for the Nationwide Injunction
The nationwide injunction was first issued on February 5, 2025, by U.S. District Judge Deborah L. Boardman. The case was brought by five pregnant women and two advocacy groups — CASA Inc. and the Asylum Seeker Advocacy Project — who argued that the executive order would unlawfully strip their children of birthright citizenship. Judge Boardman found that the plaintiffs had easily demonstrated the need for preliminary relief and that the executive order was likely unconstitutional.
The Trump administration had unsuccessfully attempted to narrow the scope of the injunction at the district court level, a request that Judge Boardman rejected on February 18.
Fourth Circuit Rejects Government’s Emergency Stay Request
Following its defeat at the district court, the Trump administration filed an emergency motion with the Fourth Circuit seeking a stay to limit the injunction while the case was pending. The government argued that the universal relief granted by the district court exceeded the traditional powers of equitable relief.
The Fourth Circuit panel, however, rejected this argument, noting that existing precedent supports nationwide injunctions in cases involving categorical policies like the birthright citizenship executive order. The panel found that narrowing the injunction would create inconsistent outcomes, leaving children’s citizenship status dependent on whether their parents belonged to the specific plaintiff organizations.
Looking Ahead – Nationwide Block on Trump’s Birthright Citizenship Order Holds Firm
The ruling aligns the Fourth Circuit with the Ninth Circuit, which similarly upheld a nationwide injunction against the same executive order. As the legal battle over birthright citizenship continues, the broad injunction preserves the status quo, ensuring that children born to undocumented parents in the U.S. retain their citizenship rights pending further litigation.
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