On June 27, 2025, the U.S. Supreme Court held in Trump v. CASA  that nationwide, or “universal,” injunctions “likely exceed the equitable authority that Congress has granted to federal courts.” In this case, several individuals, organizations, and states sued the federal government over a January 2025 Executive Order that purported to end birthright citizenship for certain individuals born in the U.S. with parents with specified immigration statuses. Birthright citizenship is guaranteed by the Fourteenth Amendment.

The Court ruled on procedural grounds with respect to universal injunctions and did not decide the constitutionality of the president’s Executive Order; nor did the decision deny citizenship for any individuals born in the U.S. The Court’s decision partially stayed injunctions that “are broader than necessary to provide complete relief to each plaintiff with standing to sue.”

How might this case affect lawsuits brought by families of students with disabilities brought under the Individuals with Disabilities Education Act (“IDEA”), the Americans with Disabilities Act (“ADA”), or Section 504 of the Rehabilitation Act? 

In the vast majority of cases filed under these statutes, plaintiffs seek relief for specific students alleging specific denials of services and rights guaranteed by the IDEA, or they seek relief for disability discrimination under the ADA or Section 504. These cases do not typically involve universal injunctions. Further, plaintiffs seeking widespread relief for not just one student with a disability, but for all similarly situated students, may still file class action lawsuits and seek class-wide injunctive relief (seeking an order to require an education agency to take certain action or to prohibit an agency from taking certain action).

How might the CASA decision affect the two recent rulings by the U.S. District Court for the District of Massachusetts in New York v. McMahon and Victim Rights Law Center, et al. v. United States Department of Education? In those two cases, the court granted plaintiffs’ motions for preliminary injunctions, prohibiting the U.S. Department of Education from carrying out the reduction-in-force it announced in March of 2025. 

The plaintiffs in these suits may argue that their cases differ from Trump v. CASA, in which the U.S. Supreme Court’s ruling involves injunctions that “are broader than necessary.” Arguably, with the Massachusetts cases that blocked the dismantling of the U.S. Department of Education, the preliminary injunctions are not “broader than necessary,” as the announced reduction-in-force must halt in order for the Department—and specifically OCR—to carry out its statutory duties and provide complete relief to the plaintiffs.