The U.S. Supreme Court’s landmark June 2025 decision in Trump v. CASA stripped federal district judges of their power to issue nationwide injunctions that halt presidential policies—a victory celebrated at the White House as a blow to efforts that had hindered President Donald Trump’s agenda. Yet just weeks later, judges around the country have found new legal avenues to restrict, block, or delay Trump administration actions by using alternate strategies suggested by the high court itself.

Shifting Grounds: From Injunctions to Class Actions and APA Challenges

For years, nationwide injunctions were a favored tool for quickly freezing new government policies while litigation played out. This practice exploded during Trump’s first term, when courts blocked executive orders on immigration, healthcare, and more: the Trump administration faced 64 such injunctions from 2017-2021, compared to just a handful under previous presidents. Joe Biden’s administration was also impeded by dozens of nationwide injunctions, leading to bipartisan concerns about judicial overreach.

The Supreme Court’s 6-3 decision authored by Justice Amy Coney Barrett in Trump v. CASA argued that regional federal judges could no longer halt policy for the entire nation unless absolutely necessary to provide complete relief to plaintiffs in the case. The conservative majority held that such far-reaching injunctions were not expressly permitted under the Judiciary Act of 1789 and emphasized that lower courts should limit remedies to the individuals before them.

Class Actions: A Widespread Replacement

Though it ruled against universal injunctions, the Supreme Court alluded to other mechanisms for national legal relief, including class action lawsuits. Legal experts say these “bedrock” strategies are quickly filling the gap left by the restricted injunctions.

“There’s lots of other ways to get widespread relief,” says Nicholas Bagley, law professor at the University of Michigan. “The fact is they are available now.” Through class certification, a single judge can rule on behalf of thousands or millions of similarly situated individuals—frequently leading to a sweeping, near-nationwide impact.

Recent cases bear this out. On the same day as the CASA decision, the ACLU filed a class action suit in New Hampshire to challenge Trump’s executive order limiting birthright citizenship. U.S. District Judge Joseph Laplante granted class status, covering all children born after Feb. 20, 2025, to parents who are not citizens or legal permanent residents. Laplante ruled the plaintiffs are likely to succeed on the merits and face irreparable harm if the policy remained in effect during litigation.

In Washington, D.C., U.S. District Judge Randolph Moss certified a class in a case challenging Trump-era asylum rules, overturning Proclamation 10888 and finding it exceeded presidential authority under the Immigration and Nationality Act.

Administrative Procedure Act: An Ongoing Avenue

Another critical tool is the Administrative Procedure Act (APA), which since 1946 has let courts review and invalidate federal regulations deemed “arbitrary, capricious, or contrary to law.” Justice Brett Kavanaugh, concurring in the Supreme Court’s order, highlighted the mechanism for “setting aside” agency rules while lawsuits proceed—a subtle but powerful means of halting policy nationwide, at least temporarily.

Federal judges have acted quickly: in July 2025, a coalition of 19 states sued to block mass layoffs at the Department of Health and Human Services (HHS). U.S. District Judge Melissa DuBose ruled that HHS “acted arbitrarily and capriciously,” pausing the layoffs while the court considers whether the changes unlawfully undermine services mandated by Congress.

Similarly, in New York, U.S. District Judge Brian Cogan used the APA to temporarily “set aside” a Department of Homeland Security directive ending protection for Haitian nationals. While distinct from an injunction, the effect is a nationwide suspension of the policy unless and until proper procedures are followed.

Implications for the Future of Presidential Policy Making

The intended effect of limiting nationwide injunctions—narrowing judicial power over presidential actions—has been blunted by the agile shift to class actions and APA-based litigation. This evolution means that even as one pathway closes, others remain open to challenge sweeping executive actions.

The pace of judicial certification of class actions has accelerated since the Supreme Court’s decision. According to UCLA law professor David Marcus, courts remain receptive: more than 75% of class action requests regarding government policies were granted by district courts in the last decade. Legal scholars note that while the procedural rigor for class certification can be substantial, in practice, many government-targeted class actions present “clear-cut” facts justifying such relief.

At the appellate level, the U.S. Department of Justice has begun appealing many of these decisions, seeking reversals or narrower relief—especially after judges appointed by Republican presidents, including Trump himself, have certified broad plaintiff classes or invoked the APA to suspend enforcement.

Policy Impacts in Immigration, Federal Workforce, and Civil Rights

Trump’s renewed push on immigration—tougher enforcement, ending certain protections for undocumented migrants, and rolling back birthright citizenship—continues to draw legal headwinds. State governments, advocacy groups, and affected individuals are leveraging both class actions and APA challenges to forestall or invalidate enforcement moves.

For example, the July 2025 class certification ruling in Texas prevented the deportation of Venezuelan nationals under a rarely used Alien Enemies Act based on class status, and in Rhode Island, a judge invoked the APA to block layoffs that could threaten services to millions of Americans.

Even executive actions targeting government transparency and access to healthcare information have met judicial scrutiny. In July, the HHS faced a temporary order requiring the restoration of over 60 web pages with critical public health content, after Doctors for America successfully challenged the pages’ abrupt removal as unlawful under the APA. The department is now reviewing the policy for compliance and potential revision.

Looking Ahead: Ongoing Uncertainty as Legal Doctrines Evolve

While the Supreme Court erased the automatic power of distant judges to freeze federal law on a nationwide basis, the underlying tug-of-war over presidential authority persists. Some legal experts fear that the Court may again revisit the standards for these alternative remedies, especially given their vast impact on high-profile policies.

“Hard cases make bad law,” warns Adam Zimmerman, professor at the University of Southern California, noting that rushed decisions with profound political stakes could have unforeseen consequences for other types of beneficial class actions. Meanwhile, the Court is also being urged to clarify whether “setting aside” regulations under the APA truly amounts to a nationwide block or should be restricted to the parties before the court—the very question just addressed in the context of injunctions.

With civil liberties, immigration enforcement, and government operations at stake, the path forward will remain contested. For the Trump administration and its legal opponents, the game has changed—but neither side is conceding.