Trump v. CASA, Inc. (606 U.S. 831, 2025)

PRELIMINARY PRINT Volume 606 U. S. Part 2 Pages 831–941 OFFICIAL REPORTS OF THE SUPREME COURT June 27, 2025 Page Proof Pending Publication REBECCA A. WOMELDORF reporter of decisions NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, pio@supremecourt.gov, of any typographical or other formal errors. OCTOBER TERM, 2024 831 Syllabus TRUMP, PRESIDENT OF THE UNITED STATES, et al. v. CASA, INC., et al. on application for partial stay No. 24A884. Argued May 15, 2025—Decided June 27, 2025* Plaintiffs (respondents here)—individuals, organizations, and States—fled three separate suits to enjoin the implementation and enforcement of President Trump's Executive Order No. 14160. See Protecting the Meaning and Value of American Citizenship, 90 Fed. Reg. 8449. The Executive Order identifes circumstances in which a person born in the United States is not “subject to the jurisdiction thereof ” and is thus not recognized as an American citizen. The plaintiffs allege that the Executive Order violates the Fourteenth Amendment's Citizenship Clause, § 1, and § 201 of the Nationality Act of 1940. In each case, the District Court entered a “universal injunction”—an injunction barring executive offcials from applying the Executive Order to anyone, not just the plaintiffs. And in each case, the Court of Appeals denied the Government's request to stay the sweeping relief. The Government Page Proof Pending Publication argues that the District Courts lacked equitable authority to impose universal relief and has fled three nearly identical emergency applica- tions seeking partial stays to limit the preliminary injunctions to the plaintiffs in each case. The applications do not raise—and thus the Court does not address—the question whether the Executive Order vio- lates the Citizenship Clause or Nationality Act. Instead, the issue the Court decides is whether, under the Judiciary Act of 1789, federal courts have equitable authority to issue universal injunctions. Held: Universal injunctions likely exceed the equitable authority that Con- gress has given to federal courts. The Court grants the Government's applications for a partial stay of the injunctions entered below, but only to the extent that the injunctions are broader than necessary to provide complete relief to each plaintiff with standing to sue. Pp. 839–862. (a) The issue raised by these applications—whether Congress has granted federal courts authority to universally enjoin the enforcement of an executive order—plainly warrants this Court's review. On multi- ple occasions, and across administrations, the Solicitor General has *Together with No. 24A885, Trump, President of the United States, et al. v. Washington et al., and No. 24A886, Trump, President of the United States, et al. v. New Jersey et al., also on applications for partial stays. 832 TRUMP v. CASA, INC. Syllabus asked the Court to consider the propriety of this expansive remedy. As the number of universal injunctions has increased over the years, so too has the importance of the issue. Pp. 839–840. (b) The Government is likely to succeed on the merits of its claim that the District Courts lacked authority to issue universal injunctions. See Nken v. Holder, 556 U. S. 418, 434 (holding that for a stay application to be granted, the applicant must make a strong showing of likelihood of success on the merits). The issuance of a universal injunction can be justifed only as an exercise of equitable authority, yet Congress has granted federal courts no such power. The Judiciary Act of 1789 en- dowed federal courts with jurisdiction over “all suits . . . in equity,” § 11, 1 Stat. 78, and still today, this statute “is what authorizes the federal courts to issue equitable remedies,” S. Bray & E. Sherwin, Remedies 442. This Court has held that the statutory grant encompasses only those sorts of equitable remedies “traditionally accorded by courts of equity” at our country's inception. Grupo Mexicano de Desarrollo, S. A. v. Alliance Bond Fund, Inc., 527 U. S. 308, 319. Universal injunctions are not suffciently “analogous” to any relief available in the court of equity in England at the time of the founding. Id., at 318–319. Equity offered a mechanism for the Crown “to secure justice where it would not be secured by the ordinary and existing proc- Page Proof Pending Publication esses of law.” G. Adams, The Origin of English Equity, 16 Colum. L. Rev. 87, 91. This “judicial prerogative of the King” thus extended to “those causes which the ordinary judges were incapable of determin- ing.” 1 J. Pomeroy, Equity Jurisprudence § 31, p. 27. Eventually, the Crown instituted the “practice of delegating the cases” that “came be- fore” the judicial prerogative “to the chancellor for his sole decision.” Id., § 34, at 28. The “general rule in Equity [was] that all persons mate- rially interested [in the suit were] to be made parties to it.” J. Story, Commentaries on Equity Pleadings § 72, p. 74. Injunctions were no exception; there were “sometimes suits to restrain the actions of partic- ular offcers against particular plaintiffs.” S. Bray, Multiple Chancel- lors: Reforming the National Injunction, 131 Harv. L. Rev. 417, 425 (Bray, Multiple Chancellors). Of importance here, suits in equity were brought by and against individual parties, and the Chancellor's remedies were generally party specifc. See Iveson v. Harris, 7 Ves. 251, 257, 32 Eng. Rep. 102, 104 (“[Y]ou cannot have an injunction except against a party to the suit”). In sum, under longstanding equity practice in Eng- land, there was no remedy “remotely like a national injunction.” Bray, Multiple Chancellors 425. Nor did founding-era courts of equity in the United States chart a different course. If anything, the approach traditionally taken by fed- eral courts cuts against the existence of such a sweeping remedy. Con- Cite as: 606 U. S. 831 (2025) 833 Syllabus sider Scott v. Donald, where the plaintiff successfully challenged the constitutionality of a law on which state offcials had relied to confscate alcohol that the plaintiff kept for personal use. See 165 U. S. 107, 109 (statement of case); id., at 111–112 (opinion of the Court). Although the plaintiff sought an injunction barring enforcement of the law against both himself and anyone “whose rights [were] infringed and threatened” by it, the Court permitted only relief benefting the named plaintiff. Id., at 115–117. In the ensuing decades, the Court consistently rebuffed requests for relief that extended beyond the parties. See, e. g., Perkins v. Lukens Steel Co., 310 U. S. 113, 123; Frothingham v. Mellon, decided with Massachusetts v. Mellon, 262 U. S. 447, 487–489. The Court's early refusals to grant relief to nonparties are consistent with the party-specifc principles that permeate the Court's understand- ing of equity. “[N]either declaratory nor injunctive relief,” the Court has said, “can directly interfere with enforcement of contested statutes or ordinances except with respect to the particular federal plaintiffs.” Doran v. Salem Inn, Inc., 422 U. S. 922, 931. In fact, universal injunc- tions were conspicuously nonexistent for most of the Nation's history. Their absence from 18th and 19th century equity practice settles the question of judicial authority. Page Proof Pending Publication While “equity is fexible,” Grupo Mexicano, 527 U. S., at 322, the Court's precedent emphasizes that its “fexibility is confned within the broad boundaries of traditional equitable relief.” Ibid. Because the universal injunction lacks a historical pedigree, it falls outside the bounds of a federal court's equitable authority under the Judiciary Act. Pp. 841–847. (c) Respondents' counterarguments are unavailing. Pp. 847–856. (1) In an effort to satisfy Grupo Mexicano's historical test, re- spondents claim that universal injunctions are the modern equivalent of the decree resulting from a “bill of peace”—a form of group litigation in the Court of Chancery. Respondents contend that the existence of this historic equitable device means that federal courts have the equitable authority to issue universal injunctions under the Judiciary Act. The analogy, however, does not work. True, “bills of peace allowed [courts of equity] to adjudicate the rights of members of dispersed groups with- out formally joining them to a lawsuit through the usual procedures.” Arizona v. Biden, 40 F. 4th 375, 397 (Sutton, C. J., concurring). Unlike universal injunctions, however, which reach anyone affected by execu- tive or legislative action, bills of peace involved a “group [that] was small and cohesive.” Bray, Multiple Chancellors 426. And unlike universal injunctions, which bind only the parties to the suit, decrees resulting from a bill of peace “would bind all members of the group, whether they 834 TRUMP v. CASA, INC. Syllabus were present in the action or not.” 7A C. Wright, A. Miller, & M. Kane, Federal Practice and Procedure § 1751, p. 10. The bill of peace lives in modern form, but not as the universal injunc- tion. It is instead analogous to the modern class action—which, in fed- eral court, is governed by Rule 23 of the Federal Rules of Civil Proce- dure. See ibid. Rule 23 requires numerosity (such that joinder is impracticable), common questions of law or fact, typicality, and repre- sentative parties who adequately protect the interests of the class. Fed. Rule Civ. Proc. 23(a). The requirements for a bill of peace were virtually identical. See 7A Wright, Federal Practice and Procedure § 1751, at 10, and n. 4. By forging a shortcut to relief that benefts parties and nonparties alike, universal injunctions impermissibly cir- cumvent Rule 23's procedural protections. Pp. 847–850. (2) Respondents contend that universal injunctions—or at least these universal injunctions—are simply an application of the principle that a court of equity may fashion a remedy that awards complete relief. But “complete relief ” is not synonymous with “universal relief.” It is a narrower concept, long embraced in the equitable tradition, that allows courts to “administer complete relief between the parties.” Kinney- Coastal Oil Co. v. Kieffer, 277 U. S. 488, 507 (emphasis added). To be Page Proof Pending Publication sure, party-specifc injunctions sometimes “advantag[e] nonparties,” Trump v. Hawaii, 585 U. S. 667, 717 (Thomas, J., concurring), but they do so only incidentally. Here, prohibiting enforcement of the Executive Order against the child of an individual pregnant plaintiff will give that plaintiff complete relief: Her child will not be denied citizenship. And extending the in- junction to cover everyone similarly situated would not render her relief any more complete. So the individual and associational respondents are wrong to characterize the universal injunction as simply an applica- tion of the complete-relief principle. The inquiry is more complicated for the state respondents, because the relevant injunction does not pur- port to directly beneft nonparties. Instead, the District Court for the District of Massachusetts decided that a universal injunction was neces- sary to provide the States themselves complete relief. As the States see it, their harms—fnancial injuries and the administrative burdens fowing from citizen-dependent benefts programs—cannot be remedied without a blanket ban on the enforcement of the Executive Order. Children often move across state lines or are born outside their parents' State of residence. Given the cross-border fow, the States say, a “patchwork injunction” would prove unworkable for the provision of certain federally funded benefts. The Government retorts that even if the injunction is designed to beneft only the States, it is “more burden- some than necessary to redress” their asserted harms, see Califano v. Cite as: 606 U. S. 831 (2025) 835 Syllabus Yamasaki, 442 U. S. 682, 702, and that narrower relief is appropriate. The Court declines to take up these arguments in the frst instance. The lower courts should determine whether a narrower injunction is appropriate, so we leave it to them to consider these and any related arguments. Pp. 850–854. (3) Respondents defend universal injunctions as a matter of policy; the Government advances policy arguments running the other way. As with most questions of law, the policy pros and cons are beside the point. Under the Court's well-established precedent, see Grupo Mexicano, 527 U. S., at 319, because universal injunctions lack a founding-era forebear, federal courts lack authority to issue them. Pp. 854–856. (d) To obtain interim relief, the Government must show that it is likely to suffer irreparable harm absent a stay. Nken, 556 U. S., at 434– 435. When a federal court enters a universal injunction against the Government, it “improper[ly] intru[des]” on “a coordinate branch of the Government” and prevents the Government from enforcing its policies against nonparties. INS v. Legalization Assistance Project of Los Angeles County Federation of Labor, 510 U. S. 1301, 1306 (O'Connor, J., in chambers); see also Maryland v. King, 567 U. S. 1301, 1303 (Roberts, C. J., in chambers) (“ `[A]ny time a State is enjoined by a court from effectuating statutes enacted by representatives of its people, it suffers Page Proof Pending Publication a form of irreparable injury' ” (alteration in original)). The Court's practice also demonstrates that an applicant need not show it will pre- vail on the underlying merits when it seeks a stay on a threshold issue. See, e. g., Gutierrez v. Saenz, 603 U. S. 937; Offce of Personnel Manage- ment v. American Federation of Government Employees, 604 U. S. –––. The Government here is likely to suffer irreparable harm from the Dis- trict Courts' entry of injunctions that likely exceed the authority con- ferred by the Judiciary Act. And the balance of equities does not coun- sel against awarding the Government interim relief: A partial stay will cause no harm to respondents because they will remain protected by the preliminary injunctions to the extent necessary and appropriate to afford them complete relief. Pp. 859–861. (e) When a court concludes that the Executive Branch has acted un- lawfully, the answer is not for the court to exceed its power, too. The Government's applications for partial stays of the preliminary injunc- tions are granted, but only to the extent that the injunctions are broader than necessary to provide complete relief to each plaintiff with standing to sue. Pp. 861–862. Applications for partial stays granted. Barrett, J., delivered the opinion of the Court, in which Roberts, C. J., and Thomas, Alito, Gorsuch, and Kavanaugh, JJ., joined. Thomas, J., fled a concurring opinion, in which Gorsuch, J., joined, post, 836 TRUMP v. CASA, INC. Syllabus p. 862. Alito, J., fled a concurring opinion, in which Thomas, J., joined, post, p. 866. Kavanaugh, J., fled a concurring opinion, post, p. 868. So- tomayor, J., fled a dissenting opinion, in which Kagan and Jackson, JJ., joined, post, p. 879. Jackson, J., fled a dissenting opinion, post, p. 921. Solicitor General Sauer argued the cause for applicants in all cases. Jeremy Feigenbaum, Solicitor General of New Jersey, ar- gued the cause for state and city respondents. K e l s i B. Co r k r a n a r g u e d t h e c a u s e f o r p r i v a t e respondents.† †Briefs of amici curiae urging the denial of the applications were fled in all cases for B. A. M. N. (The Coalition to Defend Affrmative Action et al.) by Shanta Driver; for Common Cause by Gregory L. Diskant; for Local Governments et al. by Jonathan Miller, David R. Gault, Atleen Kaur, John P. Markovs, Christian D. Menefee, and Lyndsey M. Olson; for the Restaurant Law Center et al. by Angelo I. Amador, Thomas Ward, Gabriel K. Gillett, Elizabeth Gaudio Milito, and Karen R. Harned; for Scholars of Consitutional Law and Immigration by Elizabeth B. Wydra Page Proof Pending Publication and Brianne J. Gorod; for the Student Political Research Initiative for New Governance (SPRING) et al. by Zachary Wolfe; for Gabriel J. Chin et al. by Darryl M. Woo and Neel Chatterjee; for Suzette Malveaux et al. by Suzette Malveaux, pro se; for Alan B. Morrison, pro se; and for Mila Sohoni by Kevin K. Russell and Daniel Woofter. Briefs of amici curiae urging the grant of the applications were fled in all cases for the State of Iowa et al. by Brenna Bird, Attorney General of Iowa, and Eric Wessan, Solicitor General, and by the Attorneys General for their respective States as follows: Steve Marshall of Alabama, Tim Griffn of Arkansas, James Uthmeier of Florida, Raúl R. Labrador of Idaho, Theodore E. Rokita of Indiana, Kris Kobach of Kansas, Liz Murrill of Louisiana, Lynn Fitch of Mississippi, Andrew T. Bailey of Missouri, Austin Knudsen of Montana, Michael T. Hilgers of Nebraska, Drew Wrig- ley of North Dakota, Dave Yost of Ohio, Gentner Drummond of Oklahoma, Alan Wilson of South Carolina, Marty Jackley of South Dakota, Ken Pax- ton of Texas, Derek E. Brown of Utah, and Bridget Hill of Wyoming; for the State of West Virginia by John B. McCuskey, Attorney General of West Virginia, Michael Williams, Solicitor General, Jay Alan Sekulow, Jordan A. Sekulow, Stuart J. Roth, Donn S. Parsons, Walter M. Weber, and Liam R. Harrell; for America's Future et al. by William J. Olson, Jeremiah L. Morgan, Robert J. Olson, John C. Eastman, Alexander Ha- berbush, Michael Boos, Richard B. Sanders, Kerry L. Morgan, John Cite as: 606 U. S. 831 (2025) 837 Opinion of the Court Justice Barrett delivered the opinion of the Court. The United States has fled three emergency applications challenging the scope of a federal court's authority to enjoin Government offcials from enforcing an executive order. Traditionally, courts issued injunctions prohibiting executive offcials from enforcing a challenged law or policy only against the plaintiffs in the lawsuit. The injunctions before us today refect a more recent development: district courts asserting the power to prohibit enforcement of a law or pol- icy against anyone. These injunctions—known as “univer- sal injunctions”—likely exceed the equitable authority that Congress has granted to federal courts.1 We therefore I. Harris III, Mark J. Fitzgibbons, Jeffrey C. Tuomala, Patrick M. Mc- Sweeney, J. Mark Brewer, Joseph W. Miller, and Phillip L. Jauregui; for the Claremont Institute's Center for Constitutional Jurisprudence by John C. Eastman and Alexander Haberbush; for the Immigration Re- Page Proof Pending Publication form Law Institute by Christopher J. Hajec; for Members of Congress by R. Trent McCotter, Daniel Z. Epstein, and Joel B. Ard; for Edwin Meese III by J. Christian Adams; and for Joshua Steinman by Judd E. Stone II. Briefs of amici curiae were fled in all cases for the State of Tennessee by Jonathan Skrmetti, Attorney General of Tennessee, J. Matthew Rice, Solicitor General, and Whitney D. Hermandorfer; for Members of the U. S. Congress by Jonathan Weinberg; for the National Immigrant Justice Center by Charles Roth; for Corey J. Biazzo, pro se; for David Boyle, pro se; for William T. Dickson, pro se; for G. Antaeus B. Edelsohn by Joan Deborah B. Edelsohn; and for James E. Pfander, pro se, by Jeffrey T. Green. Briefs of amici curiae were fled in No. 24A884 for the Chamber of Commerce of the United States of America by Elbert Lin, Erica N. Pe- terson, and Jennifer B. Dickey; and for Legal Historians by Virginia Grace Davis. 1 Such injunctions are sometimes called “nationwide injunctions,” re- fecting their use by a single district court to bar the enforcement of a law anywhere in the Nation. But the term “universal” better captures how these injunctions work. Even a traditional, parties-only injunction can apply beyond the jurisdiction of the issuing court. Steele v. Bulova Watch Co., 344 U. S. 280, 289 (1952) (When “exercising its equity powers,” a dis- 838 TRUMP v. CASA, INC. Opinion of the Court grant the Government's applications to partially stay the in- junctions entered below. I The applications before us concern three overlapping, uni- versal preliminary injunctions entered by three different District Courts. See 763 F. Supp. 3d 723 (Md. 2025), appeal pending, No. 25–1153 (CA4); 765 F. Supp. 3d 1142 (WD Wash. 2025), appeal pending, No. 25–807 (CA9); Doe v. Trump, 766 F. Supp. 3d 266 (Mass. 2025), appeal pending, No. 25–1170 (CA1). The plaintiffs—individuals, organizations, and States—sought to enjoin the implementation and enforce- ment of President Trump's Executive Order No. 14160.2 See Protecting the Meaning and Value of American Citizen- ship, 90 Fed. Reg. 8449 (2025). The Executive Order identi- fes circumstances in which a person born in the United States is not “subject to the jurisdiction thereof ” and is thus not recognized as an American citizen. See ibid. Specif- Page Proof Pending Publication cally, it sets forth the “policy of the United States” to no longer issue or accept documentation of citizenship in two scenarios: “(1) when [a] person's mother was unlawfully pres- ent in the United States and the person's father was not a United States citizen or lawful permanent resident at the time of said person's birth, or (2) when [a] person's mother's trict court “may command persons properly before it to cease or perform acts outside its territorial jurisdiction”). The difference between a tradi- tional injunction and a universal injunction is not so much where it applies, but whom it protects: A universal injunction prohibits the Government from enforcing the law against anyone, anywhere. H. Wasserman, “Na- tionwide” Injunctions Are Really “Universal” Injunctions and They Are Never Appropriate, 22 Lewis & Clark L. Rev. 335, 338 (2018). 2 The Government does not dispute—nor could it—that the individual plaintiffs have standing to sue. But it argues that the States lack third- party standing because their claims rest exclusively on the rights of indi- viduals. Application for Partial Stay of Injunction in No. 24A884, pp. 28– 32. It also challenges the District Courts' authority to grant relief to the organizations' members who are not identifed in the complaints. See id., at 22. We do not address these arguments. Cite as: 606 U. S. 831 (2025) 839 Opinion of the Court presence in the United States was lawful but temporary, and the person's father was not a United States citizen or lawful permanent resident at the time of said person's birth.” Ibid. The Executive Order also provides for a 30-day ramp- up period. During that time, the order directs executive agencies to develop and issue public guidance regarding the order's implementation. See id., at 8449–8450. The plaintiffs fled suit, alleging that the Executive Order violates the Fourteenth Amendment's Citizenship Clause, § 1, as well as § 201 of the Nationality Act of 1940, 54 Stat. 1138 (codifed at 8 U. S. C. § 1401). In each case, the District Court concluded that the Executive Order is likely unlawful and entered a universal preliminary injunction barring vari- ous executive offcials from applying the policy to anyone in the country. And in each case, the Court of Appeals denied the Government's request to stay the sweeping relief. See 2025 WL 654902 (CA4, Feb. 28, 2025); 2025 WL 553485 (CA9, Feb. 19, 2025); 131 F. 4th 27 (CA1 2025). Page Proof Pending Publication The Government has now fled three nearly identical appli- cations seeking to partially stay the universal preliminary injunctions and limit them to the parties. See Application for Partial Stay of Injunction in No. 24A884; Application for Partial Stay of Injunction in No. 24A885; Application for Par- tial Stay of Injunction in No. 24A886.3 The applications do not raise—and thus we do not address—the question whether the Executive Order violates the Citizenship Clause or Nationality Act. The issue before us is one of remedy: whether, under the Judiciary Act of 1789, federal courts have equitable authority to issue universal injunctions. II The question whether Congress has granted federal courts the authority to universally enjoin the enforcement of an ex- ecutive or legislative policy plainly warrants our review, as 3 Because the applications are materially identical, we cite only the appli- cation in No. 24A884 throughout the rest of the opinion. 840 TRUMP v. CASA, INC. Opinion of the Court Members of this Court have repeatedly emphasized. See, e. g., McHenry v. Texas Top Cop Shop, Inc., 604 U. S. –––, ––– (2025) (Gorsuch, J., concurring in grant of stay) (“I would . . . take this case now to resolve defnitively the question whether a district court may issue universal injunctive re- lief ”); Labrador v. Poe, 601 U. S. 1110, 1116 (2024) (Gorsuch, J., joined by Thomas and Alito, JJ., concurring in grant of stay) (“[T]he propriety of universal injunctive relief [is] a question of great signifcance that has been in need of the Court's attention for some time”); Griffn v. HM Florida- ORL, LLC, 601 U. S. –––, ––– (2023) (statement of Kava- naugh, J., joined by Barrett, J., except as to footnote 1, respecting denial of application for stay) (Universal injunc- tions present “an important question that could warrant our review in the future”); Trump v. Hawaii, 585 U. S. 667, 713 (2018) (Thomas, J., concurring) (“If [universal injunctions'] popularity continues, this Court must address their legal- Page Proof Pending Publication ity”). On multiple occasions, and across administrations, the Solicitor General has asked us to consider the propriety of this expansive remedy. See, e. g., Application for Stay of In- junction in McHenry v. Texas Top Cop Shop, Inc., O. T. 2024, No. 24A653 (Biden administration); Brief for Petitioners in Trump v. Hawaii, O. T. 2017, No. 17–965 (frst Trump administration). It is easy to see why. By the end of the Biden administra- tion, we had reached “a state of affairs where almost every major presidential act [was] immediately frozen by a federal district court.” W. Baude & S. Bray, Comment, Proper Par- ties, Proper Relief, 137 Harv. L. Rev. 153, 174 (2023). The trend has continued: During the frst 100 days of the second Trump administration, district courts issued approximately 25 universal injunctions. Congressional Research Service, J. Lampe, Nationwide Injunctions in the First Hundred Days of the Second Trump Administration 1 (May 16, 2025). As the number of universal injunctions has increased, so too has the importance of the issue. Cite as: 606 U. S. 831 (2025) 841 Opinion of the Court III A The Government is likely to succeed on the merits of its argument regarding the scope of relief. See Nken v. Holder, 556 U. S. 418, 434 (2009) (holding that for a stay application to be granted, the applicant must make “ `a strong showing that [it] is likely to succeed on the merits' ”). A universal injunction can be justifed only as an exercise of equitable authority, yet Congress has granted federal courts no such power.4 The Judiciary Act of 1789 endowed federal courts with ju- risdiction over “all suits . . . in equity,” § 11, 1 Stat. 78, and still today, this statute “is what authorizes the federal courts to issue equitable remedies,” S. Bray & E. Sherwin, Reme- dies 442 (4th ed. 2024). Though fexible, this equitable au- thority is not freewheeling. We have held that the statutory grant encompasses only those sorts of equitable remedies Page Proof Pending Publication “traditionally accorded by courts of equity” at our country's inception. Grupo Mexicano de Desarrollo, S. A. v. Alliance Bond Fund, Inc., 527 U. S. 308, 319 (1999); see also, e. g., Payne v. Hook, 7 Wall. 425, 430 (1869) (“The equity jurisdic- tion conferred on the Federal courts is the same that the High Court of Chancery in England possesses”).5 We must therefore ask whether universal injunctions are suffciently “analogous” to the relief issued “ `by the High Court of Chancery in England at the time of the adoption of the 4 Our decision rests solely on the statutory authority that federal courts possess under the Judiciary Act of 1789. We express no view on the Gov- ernment's argument that Article III forecloses universal relief. 5 See also Guaranty Trust Co. v. York, 326 U. S. 99, 105 (1945) (“[T]he federal courts [have] no power that they would not have had in any event when courts were given `cognizance,' by the frst Judiciary Act, of suits `in equity' ”); Boyle v. Zacharie & Turner, 6 Pet. 648, 658 (1832) (“[T]he settled doctrine of this court is, that the remedies in equity are to be administered, not according to the state practice, but according to the practice of courts of equity in the parent country”). 842 TRUMP v. CASA, INC. Opinion of the Court Constitution and the enactment of the original Judiciary Act.' ” Grupo Mexicano, 527 U. S., at 318–319 (quoting A. Dobie, Handbook of Federal Jurisdiction and Procedure 660 (1928)). The answer is no: Neither the universal injunction nor any analogous form of relief was available in the High Court of Chancery in England at the time of the founding. Equity offered a mechanism for the Crown “to secure justice where it would not be secured by the ordinary and existing proc- esses of law.” G. Adams, The Origin of English Equity, 16 Colum. L. Rev. 87, 91 (1916). This “judicial prerogative of the King” thus extended to “those causes which the ordinary judges were incapable of determining.” 1 J. Pomeroy, Eq- uity Jurisprudence § 31, p. 27 (1881). Eventually, the Crown instituted the “practice of delegating the cases” that “came before” the judicial prerogative “to the chancellor for his sole decision.” Id., § 34, at 28. This “became the common mode Page Proof Pending Publication of dealing with such controversies.” Ibid. Of importance here, suits in equity were brought by and against individual parties. Indeed, the “general rule in Eq- uity [was] that all persons materially interested [in the suit were] to be made parties to it.” J. Story, Commentaries on Equity Pleadings § 72, p. 74 (2d ed. 1840) (Story). Injunc- tions were no exception; there were “sometimes suits to re- strain the actions of particular offcers against particular plaintiffs.” S. Bray, Multiple Chancellors: Reforming the National Injunction, 131 Harv. L. Rev. 417, 425 (2017) (Bray, Multiple Chancellors) (emphasis added). And in certain cases, the “Attorney General could be a defendant.” Ibid. The Chancellor's remedies were also typically party specifc. “As a general rule, an injunction” could not bind one who was not a “party to the cause.” F. Calvert, Suits in Equity 120 (2d ed. 1847); see also Iveson v. Harris, 7 Ves. 251, 257, 32 Eng. Rep. 102, 104 (1802) (“[Y]ou cannot have an injunc- tion except against a party to the suit”). Suffce it to say, then, under longstanding equity practice in England, there Cite as: 606 U. S. 831 (2025) 843 Opinion of the Court was no remedy “remotely like a national injunction.” Bray, Multiple Chancellors 425. Nor did founding-era courts of equity in the United States chart a different course. See 1 Pomeroy, Equity Jurispru- dence § 41, at 33–34. If anything, the approach traditionally taken by federal courts cuts against the existence of such a sweeping remedy. Consider Scott v. Donald, where the plaintiff successfully challenged the constitutionality of a law on which state offcials had relied to confscate alcohol that the plaintiff kept for personal use. See 165 U. S. 107, 109 (1897) (statement of case); id., at 111–112 (opinion of the Court). Although the plaintiff sought an injunction barring enforcement of the law against both himself and anyone else “whose rights [were] infringed and threatened” by it, this Court permitted only a narrower decree between “the par- ties named as plaintiff and defendants in the bill.” Id., at 115–117.6 Page Proof Pending Publication In the ensuing decades, we consistently rebuffed requests for relief that extended beyond the parties. See, e. g., Per- kins v. Lukens Steel Co., 310 U. S. 113, 123 (1940) (“The bene- fts of [the court's] injunction” improperly extended “to bid- ders throughout the Nation who were not parties to any proceeding, who were not before the court[,] and who had 6 Though the principal dissent claims otherwise, we do not treat Scott as “dispositive.” Post, at 905 (opinion of Sotomayor, J.). Under Grupo Mexicano de Desarrollo, S. A. v. Alliance Bond Fund, Inc., 527 U. S. 308 (1999), the lack of a historical analogue is dispositive. Scott simply illustrates that as late as 1897, this Court adhered to a party-specifc view of relief. And while the principal dissent relies on Smyth v. Ames, 169 U. S. 466, 518 (1898), as a counterexample to Scott, see post, at 905 (opinion of Sotomayor, J.), it is unclear why. Even supporters of the universal injunction recognize that “the decree [that Smyth] affrmed did not reach beyond the parties.” M. Sohoni, The Lost History of the “Universal” In- junction, 133 Harv. L. Rev. 920, 939 (2020); Smyth, 169 U. S., at 476–477 (statement of case) (quoting circuit court order that enjoined state offcials from enforcing the statute “against said railroad companies” (emphasis added)). 844 TRUMP v. CASA, INC. Opinion of the Court sought no relief ”); cf. Frothingham v. Mellon, decided with Massachusetts v. Mellon, 262 U. S. 447, 487–489 (1923) (con- cluding that the Court lacked authority to issue “preventive relief ” that would apply to people who “suffe[r] in some in- defnite way in common with people generally”); Bray, Multi- ple Chancellors 433 (explaining that the Frothingham analy- sis “intertwines concepts of equity, remedies, and the judicial power”). As Justice Nelson put it while riding circuit, “[t]here is scarcely a suit at law, or in equity, . . . in which a general statute is interpreted, that does not involve a ques- tion in which other parties are interested.” Cutting v. Gil- bert, 6 F. Cas. 1079, 1080 (No. 3,519) (CC SDNY 1865). But to allow all persons subject to the statute to be treated as parties to a lawsuit “would confound the established order of judicial proceedings.” Ibid. Our early refusals to grant relief to nonparties are consist- ent with the party-specifc principles that permeate our un- Page Proof Pending Publication derstanding of equity. “[N]either declaratory nor injunctive relief,” we have said, “can directly interfere with enforce- ment of contested statutes or ordinances except with respect to the particular federal plaintiffs.” Doran v. Salem Inn, Inc., 422 U. S. 922, 931 (1975); see also Gregory v. Stetson, 133 U. S. 579, 586 (1890) (“It is an elementary principle that a court cannot adjudicate directly upon a person's right with- out having him either actually or constructively before it. This principle is fundamental”); Baude & Bray, 137 Harv. L. Rev., at 168 (noting the “party-specifc understanding of what equitable remedies do”). In fact, universal injunctions were not a feature of federal- court litigation until sometime in the 20th century. See Bray, Multiple Chancellors 448–452 (discussing various ra- tionales for the birth of the universal injunction); see also Application in No. 24A884, at 17–18. The D. C. Circuit is- sued what some regard as the frst universal injunction in 1963. See Wirtz v. Baldor Elec. Co., 337 F. 2d 518, 535 (en- joining the Secretary of Labor “with respect to the entire Cite as: 606 U. S. 831 (2025) 845 Opinion of the Court [electric motors and generators] industry,” not just the named plaintiffs to the lawsuit).7 Yet such injunctions re- mained rare until the turn of the 21st century, when their use gradually accelerated. See Bray, Multiple Chancellors 439–443 (referencing Flast v. Cohen, 392 U. S. 83 (1968), and Harlem Valley Transp. Assn. v. Stafford, 360 F. Supp. 1057 (SDNY 1973)). One study identifed approximately 127 uni- versal injunctions issued between 1963 and 2023. See Dis- trict Court Reform: Nationwide Injunctions, 137 Harv. L. Rev. 1701, 1705 (2024). Ninety-six of them—over three quarters—were issued during the administrations of Presi- dent George W. Bush, President Obama, President Trump, and President Biden. Ibid. The bottom line? The universal injunction was conspicu- ously nonexistent for most of our Nation's history. Its ab- sence from 18th- and 19th-century equity practice settles the question of judicial authority.8 See Grupo Mexicano, 527 Page 7 Proof There is some Pending dispute about whether WirtzPublication was the frst universal injunction. Professor Mila Sohoni points to other possible 20th-century examples, including West Virginia Bd. of Ed. v. Barnette, 319 U. S. 624 (1943), Pierce v. Society of Sisters, 268 U. S. 510 (1925), and Lewis Publish- ing Co. v. Morgan, 229 U. S. 288 (1913). See Sohoni, 133 Harv. L. Rev., at 943; Brief for Professor Mila Sohoni as Amica Curiae 3; see also post, at 898–899 (opinion of Sotomayor, J.). But see M. Morley, Disaggregating the History of Nationwide Injunctions: A Response to Professor Sohoni, 72 Ala. L. Rev. 239, 252–256 (2020) (disputing these examples). Regard- less, under any account, universal injunctions postdated the founding by more than a century—and under Grupo Mexicano, equitable authority exercised under the Judiciary Act must derive from founding-era practice. 527 U. S., at 319. It also bears emphasis that none of these cases ad- dresses the propriety of universal relief. Like a “drive-by-jurisdictional rulin[g],” implicit acquiescence to a broad remedy “ha[s] no precedential ef- fect.” Steel Co. v. Citizens for Better Environment, 523 U. S. 83, 91 (1998). 8 The principal dissent faults us for failing to identify a single founding- era case in which this Court held that universal injunctions exceed a federal court's equitable authority. See post, at 905–906 (opinion of Sotomayor, J.). But this absence only bolsters our case. That this Court had no occa- sion to reject the universal injunction as inconsistent with traditional eq- uity practice merely demonstrates that no party even bothered to ask for 846 TRUMP v. CASA, INC. Opinion of the Court U. S., at 318–319. That the absence continued into the 20th century renders any claim of historical pedigree still more implausible. Even during the “deluge of constitutional liti- gation that occurred in the wake of Ex parte Young, through- out the Lochner Era, and at the dawn of the New Deal,” universal injunctions were nowhere to be found. M. Morley, Disaggregating the History of Nationwide Injunctions: A Response to Professor Sohoni, 72 Ala. L. Rev. 239, 252 (2020) (footnotes omitted). Had federal courts believed themselves to possess the tool, surely they would not have let it lie idle. Faced with this timeline, the principal dissent accuses us of “misunderstand[ing] the nature of equity” as being “fr[o- zen] in amber . . . at the time of the Judiciary Act.” Post, at 906 (opinion of Sotomayor, J.). Not so. We said it be- fore, see supra, at 841, and say it again: “[E]quity is fexible.” Grupo Mexicano, 527 U. S., at 322. At the same time, its “fexibility is confned within the broad boundaries of tradi- tional equitable relief.” 9 Ibid. A modern device need not Page Proof Pending Publication such a sweeping remedy—because no court would have entertained the request. Cf. Grupo Mexicano, 527 U. S., at 332 (“[E]quitable powers con- ferred by the Judiciary Act of 1789 did not include the power to create remedies previously unknown to equity jurisprudence”). 9 Notwithstanding Grupo Mexicano, the principal dissent invokes Ex parte Young, 209 U. S. 123 (1908), as support for the proposition that eq- uity can encompass remedies that have “no analogue in the relief exercised in the English Court of Chancery,” because Ex parte Young permits plain- tiffs to “obtain plaintiff-protective injunctions against Government off- cials,” and the English Court of Chancery “could not enjoin the Crown or English offcers,” post, at 907 (opinion of Sotomayor, J.). But contrary to the principal dissent's suggestion, Ex parte Young does not say—either explicitly or implicitly—that courts may devise novel remedies that have no background in traditional equitable practice. Historically, a court of equity could issue an antisuit injunction to prevent an offcer from engag- ing in tortious conduct. Ex parte Young justifes its holding by reference to a long line of cases authorizing suits against state offcials in certain circumstances. See 209 U. S., at 150–152 (citing, e. g., Osborn v. Bank of United States, 9 Wheat. 738 (1824); Governor of Georgia v. Madrazo, 1 Pet. 110 (1828); and Davis v. Gray, 16 Wall. 203 (1873)). Support for the principal dissent's approach is found not in Ex parte Young, but in Justice Ginsburg's partial dissent in Grupo Mexicano, which eschews the govern- Cite as: 606 U. S. 831 (2025) 847 Opinion of the Court have an exact historical match, but under Grupo Mexicano, it must have a founding-era antecedent. And neither the universal injunction nor a suffciently comparable predeces- sor was available from a court of equity at the time of our country's inception. See id., at 333. Because the universal injunction lacks a historical pedigree, it falls outside the bounds of a federal court's equitable authority under the Ju- diciary Act.10 See id., at 318–319. B Respondents raise several counterarguments, which the principal dissent echoes. First, they insist that the univer- sal injunction has a suffcient historical analogue: a decree resulting from a bill of peace. Second, they maintain that universal injunctions are consistent with the principle that a court of equity may fashion complete relief for the parties. Third, they argue that universal injunctions serve important policy objectives. Page Proof Pending Publication1 In an effort to satisfy Grupo Mexicano's historical test, respondents claim that universal injunctive relief does have a founding-era forebear: the decree obtained on a “bill of peace,” which was a form of group litigation permitted in English courts. See Opposition to Application in No. 24A884 (CASA), pp. 30–31; see also Brief for Professor Mila Sohoni as Amica Curiae 6–8. This bill allowed the Chancel- lor to consolidate multiple suits that involved a “common claim the plaintiff could have against multiple defendants” or “some kind of common claim that multiple plaintiffs could have against a single defendant.” Bray, Multiple Chancel- lors 426; see How v. Tenants of Bromsgrove, 1 Vern. 22, 23 ing historical approach in favor of “[a] dynamic equity jurisprudence.” 527 U. S., at 337 (opinion concurring in part and dissenting in part). 10 Nothing we say today resolves the distinct question whether the Ad- ministrative Procedure Act authorizes federal courts to vacate federal agency action. See 5 U. S. C. § 706(2) (authorizing courts to “hold unlaw- ful and set aside agency action”). 848 TRUMP v. CASA, INC. Opinion of the Court Eng. Rep. 277 (1681) (suit by a lord against his tenants collec- tively); Brown v. Vermuden, 1 Ch. Ca. 283, 22 Eng. Rep. 802 (1676), and Brown v. Vermuden, 1 Ch. Ca. 272, 22 Eng. Rep. 796 (1676) (suit by a parson against lead miners in a parish, who named four of their members to defend the suit in a representative capacity). Universal injunctions are analo- gous to this traditional equitable device, respondents say, so federal courts have authority under the Judiciary Act to issue them. The analogy does not work. True, “bills of peace allowed [courts of equity] to adjudicate the rights of members of dis- persed groups without formally joining them to a lawsuit through the usual procedures.” Arizona v. Biden, 40 F. 4th 375, 397 (CA6 2022) (Sutton, C. J., concurring); see Story §§ 120–135 (discussing representative suits). Even so, their use was confned to limited circumstances. See 7A C. Wright, A. Miller, & M. Kane, Federal Practice and Proce- Page Proof Pending Publication dure § 1751, p. 10, and n. 4 (4th ed. 2021) (citing Adair v. New River Co., 11 Ves. 429, 32 Eng. Rep. 1153 (Ch. 1803)). Unlike universal injunctions, which reach anyone affected by legis- lative or executive action—no matter how large the group or how tangential the effect—a bill of peace involved a “group [that] was small and cohesive,” and the suit did not “resolve a question of legal interpretation for the entire realm.” Bray, Multiple Chancellors 426. And unlike universal injunctions, which bind only the parties to the suit, decrees obtained on a bill of peace “would bind all members of the group, whether they were present in the action or not.” 7A Wright, Federal Practice and Procedure § 1751, at 10; see Smith v. Sworm- stedt, 16 How. 288, 303 (1854) (When “a court of equity per- mits a portion of the parties in interest to represent the en- tire body . . . the decree binds all of them the same as if all were before the court”); see also Story § 120 (“[I]n most, if not in all, cases of this sort, the decree obtained upon such a Bill will ordinarily be held binding upon all other persons standing in the same predicament”). As Chief Judge Sutton Cite as: 606 U. S. 831 (2025) 849 Opinion of the Court aptly put it, “[t]he domesticated animal known as a bill of peace looks nothing like the dragon of nationwide injunc- tions.” Arizona, 40 F. 4th, at 397 (concurring opinion). The bill of peace lives in modern form, but not as the uni- versal injunction. It evolved into the modern class action, which is governed in federal court by Rule 23 of the Federal Rules of Civil Procedure. 7A Wright, Federal Practice and Procedure § 1751, at 10 (“It was the English bill of peace that developed into what is now known as the class action”); see Hansberry v. Lee, 311 U. S. 32, 41 (1940) (“The class suit was an invention of equity”). And while Rule 23 is in some ways “more restrictive of representative suits than the original bills of peace,” Rodgers v. Bryant, 942 F. 3d 451, 464 (CA8 2019) (Stras, J., concurring), it would still be recognizable to an English Chancellor. Rule 23 requires numerosity (such that joinder is impracticable), common questions of law or fact, typicality, and representative parties who adequately Page Proof Pending Publication protect the interests of the class. Fed. Rule Civ. Proc. 23(a). The requirements for a bill of peace were virtually identical. See 7A Wright, Federal Practice and Procedure § 1751, at 10, and n. 4 (citing Adair, 11 Ves. 429, 32 Eng. Rep. 1153). None of these requirements is a prerequisite for a universal injunction. Rule 23's limits on class actions underscore a signifcant problem with universal injunctions. A “ `properly con- ducted class action,' ” we have said, “can come about in fed- eral courts in just one way—through the procedure set out in Rule 23.” Smith v. Bayer Corp., 564 U. S. 299, 315 (2011); Fed. Rule Civ. Proc. 23(a) (“One or more members of a class may sue or be sued as representative parties on behalf of all members only if ” Rule 23(a)'s requirements are satisfed (emphasis added)). Yet by forging a shortcut to relief that benefts parties and nonparties alike, universal injunctions circumvent Rule 23's procedural protections and allow “ `courts to “create de facto class actions at will.” ' ” Smith, 564 U. S., at 315 (quoting Taylor v. Sturgell, 553 U. S. 880, 850 TRUMP v. CASA, INC. Opinion of the Court 901 (2008)). Why bother with a Rule 23 class action when the quick fx of a universal injunction is on the table? Cf. Grupo Mexicano, 527 U. S., at 330–331 (“Why go through the trouble of complying with local attachment and garnishment statutes when this all-purpose prejudgment injunction is available?”). The principal dissent's suggestion that these suits could have satisfed Rule 23's requirements simply proves that universal injunctions are a class-action work- around. Post, at 902–903 (opinion of Sotomayor, J.). The taxpayer suit is a similarly inadequate historical anal- ogy. Contra, post, at 901–902. In a successful taxpayer suit, a court would enjoin the collection of an unlawful tax against “taxpayers joined as co-plaintiffs, or by one taxpayer suing on behalf of himself and all others similarly situated.” 1 Pomeroy, Equity Jurisprudence § 260, at 277. To be sure, some state courts would occasionally “enjoin the enforce- ment and collection” of taxes against an “entire community,” even when a “single taxpayer su[ed] on his own account.” Page Proof Pending Publication Id., at 277–278. But the practice of extending relief “with respect to any taxpayer” was not adopted by state courts until the mid-19th century, and even then, not all states were willing to provide such sweeping relief. See Bray, Multiple Chancellors 427. This post-founding practice of some state courts thus sheds minimal light on federal courts' equitable authority under the Judiciary Act. What is more, in Froth- ingham, we refused to allow a single taxpayer to challenge a federal appropriations act. 262 U. S., at 486–487. That counsels against placing much, if any, reliance on taxpayer suits as justifcation for the modern universal injunction. 2 Respondents contend that universal injunctions—or at least these universal injunctions—are consistent with the principle that a court of equity may fashion a remedy that awards complete relief. See Opposition to Application in No. 24A884 (CASA), at 22–25; Opposition to Application in Cite as: 606 U. S. 831 (2025) 851 Opinion of the Court No. 24A885 (Washington), pp. 28–32; Opposition to Applica- tion in No. 24A886 (New Jersey), pp. 31–39. We agree that the complete-relief principle has deep roots in equity. But to the extent respondents argue that it justifes the award of relief to nonparties, they are mistaken.11 “Complete relief ” is not synonymous with “universal re- lief.” It is a narrower concept: The equitable tradition has long embraced the rule that courts generally “may adminis- ter complete relief between the parties.” Kinney-Coastal Oil Co. v. Kieffer, 277 U. S. 488, 507 (1928) (emphasis added). While party-specifc injunctions sometimes “advantag[e] nonparties,” Trump, 585 U. S., at 717 (Thomas, J., concur- ring), they do so only incidentally. Consider an archetypal case: a nuisance in which one neighbor sues another for blasting loud music at all hours of the night. To afford the plaintiff complete relief, the court has only one feasible option: order the defendant to turn her Page 11 Proof Justice Jackson, Pending for her Publication part, thinks the “premise” that universal injunctions provide relief to nonparties is “suspect” because, in her view, “[n]onparties may beneft from an injunction, but only the plaintiff gets relief.” Post, at 928–929, n. 2 (dissenting opinion). The availability of contempt proceedings suggests otherwise. Consider the civil contempt context. Under “traditional principles of equity practice,” courts may “impos[e] civil contempt sanctions to `coerce [a] defendant into compliance' with an injunction.” Taggart v. Lorenzen, 587 U. S. 554, 560 (2019) (quot- ing United States v. Mine Workers, 330 U. S. 258, 303–304 (1947)). Gener- ally, civil contempt proceedings occur between the original parties to the lawsuit. See Gompers v. Bucks Stove & Range Co., 221 U. S. 418, 444– 445 (1911). But a federal court's “power in civil contempt proceedings is determined by the requirements of full remedial relief ” to “effect compli- ance with its decree.” McComb v. Jacksonville Paper Co., 336 U. S. 187, 193–194 (1949). And “[w]hen an order grants relief for a nonparty,” as is the case with universal injunctions, “the procedure for enforcing the order is the same as for a party.” Fed. Rule Civ. Proc. 71; see, e. g., Zamecnik v. Indiana Prairie School Dist. No. 204, 636 F. 3d 874, 879 (CA7 2011). So a nonparty covered by a universal injunction is likely to reap both the practical beneft and the formal relief of the injunction. See M. Smith, Only Where Justifed: Toward Limits and Explanatory Requirements for Nationwide Injunctions, 95 Notre Dame L. Rev. 2013, 2019 (2020). 852 TRUMP v. CASA, INC. Opinion of the Court music down—or better yet, off. That order will necessarily beneft the defendant's surrounding neighbors too; there is no way “to peel off just the portion of the nuisance that harmed the plaintiff.” Rodgers, 942 F. 3d, at 462 (Stras, J., concurring); see A. Woolhandler & C. Nelson, Does History Defeat Standing Doctrine? 102 Mich. L. Rev. 689, 702 (2004). But while the court's injunction might have the practical effect of benefting nonparties, “that beneft [is] merely inci- dental.” Trump, 585 U. S., at 717 (Thomas, J., concurring); see also 3 J. Pomeroy, Equity Jurisprudence § 1349, pp. 380– 381 (1883).12 As a matter of law, the injunction's protection extends only to the suing plaintiff—as evidenced by the fact that only the plaintiff can enforce the judgment against the defendant responsible for the nuisance. If the nuisance per- sists, and another neighbor wants to shut it down, she must fle her own suit.13 The individual and associational respondents are therefore wrong to characterize the universal injunction as simply an Page Proof Pending Publication application of the complete-relief principle. Under this principle, the question is not whether an injunction offers complete relief to everyone potentially affected by an alleg- edly unlawful act; it is whether an injunction will offer com- plete relief to the plaintiffs before the court. See Califano v. Yamasaki, 442 U. S. 682, 702 (1979) (“[I]njunctive relief should be no more burdensome to the defendant than neces- sary to provide complete relief to the plaintiffs” (emphasis added)). Here, prohibiting enforcement of the Executive 12 There may be other injuries for which it is all but impossible for courts to craft relief that is complete and benefts only the named plaintiffs. See, e. g., Shaw v. Hunt, 517 U. S. 899 (1996) (racially gerrymandered con- gressional maps). 13 The new plaintiff might be able to assert nonmutual offensive issue preclusion. See Parklane Hosiery Co. v. Shore, 439 U. S. 322, 331–332 (1979) (setting forth prerequisites for applying the doctrine). But nonmu- tual offensive issue preclusion is unavailable against the United States. United States v. Mendoza, 464 U. S. 154, 155 (1984). That universal in- junctions end-run this rule is one of the Government's objections to them. Cite as: 606 U. S. 831 (2025) 853 Opinion of the Court Order against the child of an individual pregnant plaintiff will give that plaintiff complete relief: Her child will not be denied citizenship. Extending the injunction to cover all other similarly situated individuals would not render her re- lief any more complete. The complete-relief inquiry is more complicated for the state respondents, because the relevant injunction does not purport to directly beneft nonparties. Instead, the District Court for the District of Massachusetts decided that a uni- versal injunction was necessary to provide the States them- selves with complete relief. See 766 F. Supp. 3d, at 288.14 The States maintain that the District Court made the right call. See Opposition to Application in No. 24A886 (New Jer- sey), at 31–39. As the States see it, their harms—fnancial injuries and the administrative burdens fowing from citizen-dependent benefts programs—cannot be remedied without a blanket ban on the enforcement of the Executive Order. See, e. g., Page Proof Pending Publication id., at 9–11. Children often move across state lines or are born outside their parents' State of residence. Id., at 31, 35. Given the cross-border fow, the States say, a “patchwork injunction” would prove unworkable, because it would re- quire them to track and verify the immigration status of the parents of every child, along with the birth State of every child for whom they provide certain federally funded bene- fts. Ibid. The Government—unsurprisingly—sees matters differ- ently. It retorts that even if the injunction is designed to beneft only the States, it is “more burdensome than neces- sary to redress” their asserted harms. Califano, 442 U. S., at 702. After all, to say that a court can award complete 14 The District Court for the Western District of Washington acknowl- edged the state respondents' complete-relief argument but primarily granted a universal injunction on the basis that the “extreme nature of the equities . . . alone warrant[ed] nationwide relief.” 765 F. Supp. 3d 1142, 1153 (2025). 854 TRUMP v. CASA, INC. Opinion of the Court relief is not to say that it should do so. Complete relief is not a guarantee—it is the maximum a court can provide. And in equity, “the broader and deeper the remedy the plain- tiff wants, the stronger the plaintiff 's story needs to be.” S. Bray & P. Miller, Getting into Equity, 97 Notre Dame L. Rev. 1763, 1797 (2022). In short, “[t]he essence of equity jurisdic- tion has been the power of the Chancellor to do equity and to mould each decree to the necessities of the particular case.” Hecht Co. v. Bowles, 321 U. S. 321, 329 (1944). Leaning on these principles, the Government contends that narrower relief is appropriate. For instance, the Dis- trict Court could forbid the Government to apply the Execu- tive Order within the respondent States, including to chil- dren born elsewhere but living in those States. Application in No. 24A884, at 23. Or, the Government says, the District Court could direct the Government to “treat covered chil- dren as eligible for purposes of federally funded welfare ben- efts.” Ibid. It asks us to stay the injunction insofar as it Page Proof Pending Publication sweeps too broadly. We decline to take up these arguments in the frst in- stance. The lower courts should determine whether a nar- rower injunction is appropriate; we therefore leave it to them to consider these and any related arguments. 3 Respondents also defend universal injunctions as a matter of policy. They argue that a universal injunction is some- times the only practical way to quickly protect groups from unlawful government action. See Opposition to Application in No. 24A884 (CASA), at 26–27; see also A. Frost, In De- fense of Nationwide Injunctions, 93 N. Y. U. L. Rev. 1065, 1090–1094 (2018) (suggesting that universal injunctions are appropriate when not all interested individuals can come quickly to court); post, at 914–915 (Sotomayor, J., dissenting). Respondents also contend that universal injunctions are an appropriate remedy to preserve equal treatment among indi- Cite as: 606 U. S. 831 (2025) 855 Opinion of the Court viduals when the Executive Branch adopts a facially unlaw- ful policy. Opposition to Application in No. 24A884 (CASA), at 25–27; cf. post, at 899 (Sotomayor, J., dissenting). And they suggest that forcing plaintiffs to proceed on an individ- ual basis can result in confusion or piecemeal litigation that imposes unnecessary costs on courts and others. See Oppo- sition to Application in No. 24A885 (Washington), at 31–32; Frost, 93 N. Y. U. L. Rev., at 1098–1101; see also post, at 908 (Sotomayor, J., dissenting). So, they insist, universal injunctions must be permitted for the good of the system. The Government advances policy arguments running the other way. Echoing Chief Judge Sutton, the Government asserts that avoiding a patchwork enforcement system is a justifcation that “lacks a limiting principle and would make nationwide injunctions the rule rather than the exception” for challenges to many kinds of federal law. Arizona, 40 F. 4th, at 397 (concurring opinion). It stresses—as the prin- cipal dissent also observes—that universal injunctions incen- Page Proof Pending Publication tivize forum shopping, since a successful challenge in one ju- risdiction entails relief nationwide. See Application in No. 24A884, at 19–20; see also post, at 899–900 (opinion of Soto- mayor, J.). In a similar vein, the Government observes that universal injunctio