On June 5, 2026,
U.S. District Judge John McConnell issued a scathing 135-page ruling blocking a sweeping federal freeze on immigration benefits
in what immigration advocates are calling one of the most significant court decisions on legal immigration this year.
In Dorcas International Institute of Rhode Island v. USCIS, Chief Judge John J. McConnell, Jr., of the U.S. District Court for the District of Rhode Island, found that each policy — the global asylum hold policy, the adjudication benefits hold policy, the comprehensive re-review policy, and the "country-specific factors" policy — violated the Administrative Procedure Act and conflicted with existing law.
The ruling blocked the Trump administration from freezing work permits, green cards, citizenship applications, and other immigration benefits for noncitizens from 39 countries affected by the government's travel bans, opening the door for hundreds of thousands of people with pending immigration-related applications to have these benefits unpaused.
Background: From a Shooting to a Nationwide Freeze
The policies at issue trace back to
the November 2025 shooting of two National Guard members in Washington, DC, by Rahmanullah Lakanwal, an Afghan immigrant and former CIA-backed fighter, who has pleaded not guilty.
In response, President Trump vowed to "permanently pause migration from all Third World Countries" and expanded travel bans to 39 nations.
USCIS followed with two policy memoranda. The December 2, 2025 memorandum (PM-602-0192) imposed the initial adjudication hold tied to the nineteen-country list and placed a nationwide hold on asylum applications. The January 1, 2026 memorandum (PM-602-0194) expanded the hold to cover all thirty-nine Travel Ban Countries.
Over the course of the last year, the Trump administration released numerous policies — often in response to dramatic news events — that directed USCIS to stop adjudicating cases from 39 countries (concentrated in Southwest Asia, Africa, and South America) on the basis of supposed security concerns. These policies impacted everything from temporary status visa petitions to green card applications, throwing thousands of people into a protracted period of uncertainty and limbo.
The Four Vacated Policies
The court vacated and set aside four distinct USCIS directives:
1. The Benefits Hold Policy —
Froze work permit (EAD) approvals, green card adjudications, naturalization, and other immigration benefits for nationals of approximately 39 countries designated "high risk" under executive travel bans, including Iran, Nigeria, and Venezuela.
2. The Global Asylum Hold Policy —
Halted processing of all asylum claims across the board, regardless of country of origin.
3. The Comprehensive Re-Review Policy —
Required USCIS to re-examine and reopen previously approved benefits for applicants from travel ban countries.
4. The Country-Specific Discretionary Factors Policy —
Directed USCIS officers to weigh travel ban executive proclamations as negative factors in individual benefit decisions — even for people already lawfully present in the United States.
The Court's Legal Reasoning
Judge McConnell's ruling rested on multiple grounds.
The Immigration and Nationality Act (INA) uses mandatory "shall" language requiring USCIS to adjudicate asylum applications within 180 days, naturalization applications within 120 days, and employment authorization and adjustment of status applications pursuant to specific regulatory timelines.
The judge additionally found that the policies were arbitrary and capricious because USCIS did not provide a reasoned explanation for enacting the policies, did not account for reliance interests in enacting the policies, and provided a pretextual reason for enacting the policies.
In particularly pointed language, the court called out the administration's stated national security justification.
McConnell found that USCIS tried to justify its actions "with pretextual concerns of 'national security' that mask anti-immigrant sentiments that it is forbidden from letting influence its decision making."
The court also relied on public statements by the President and the former DHS Secretary as probative evidence that the stated national security rationale masked impermissible animus.
After meeting with President Trump, then-DHS Secretary Kristi Noem described immigrants as "killers, leeches, and entitlement junkies" and said "WE DON'T WANT THEM. NOT ONE." Noem posted, and Trump shared, these comments literally the day before and the day of the policies' implementation.
Nationwide Relief Through Vacatur
A critical legal distinction in this ruling is the remedy chosen by the court.
Vacatur under the APA voids the policies themselves — they no longer exist as valid agency directives. This provides nationwide relief covering all affected individuals, not just the plaintiffs in this case.
Unlike the earlier preliminary injunction wins in other districts, which generally limited relief to the named plaintiffs in those cases, the remedy here is vacatur of the underlying policies themselves. That carries far broader effect.
Judge McConnell's decision went into effect immediately, requiring USCIS to stop implementing these policies and begin adjudicating applications from those impacted again.
Practical Implications for Affected Immigrants
"This is an enormous victory for hundreds of thousands of people that have been stuck in limbo for a significant period of time, many of whom have lost clarity about whether or not they would be able to obtain or maintain immigration status in the U.S.,"
Jorge Loweree, managing director of programs and strategy at the American Immigration Council, told Courthouse News.
Last year's USCIS rule changes led to the widespread cancellation of naturalization ceremonies for affected immigrants on the brink of getting their citizenship. Those ceremonies will now be rescheduled, thanks to McConnell's ruling.
However, affected applicants should understand important limitations.
The ruling does not guarantee outcomes for applicants, only that their cases will be processed.
While some early reports suggested that the court had struck down the administration's travel ban itself, that is not what happened. Instead, the court targeted the mechanism USCIS used to implement portions of those restrictions through its internal adjudication practices.
The decision did not consider and leaves in place all the restrictions on visa issuances for applicants outside the United States. Still, half of all legal immigrants (as measured by 2024 flows) are blocked by the State Department's 75-country visa processing freeze and the presidential proclamation blocking entry for nationals of 39 countries.
What Comes Next
The Trump administration can next appeal the decision to the First Circuit Court of Appeals. In previous cases, the administration has sought emergency "stays" of lower court decisions blocking their immigration policies and could do so in this case too. If the First Circuit denies such a stay, then the Trump administration would have to go straight to the Supreme Court and ask for an emergency decision on the court's "shadow docket."
A potential complication looms.
The government can appeal the opinion to the First Circuit, though that liberal-leaning circuit has been historically unkind to Trump's immigration agenda. Still, Loweree said he's disturbed at DHS Secretary Markwayne Mullin's refusal to commit to following court orders during a Capitol Hill appearance earlier this week.
Guidance for Applicants and Employers
For individuals with pending cases, immigration practitioners recommend the following steps:
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Anyone affected by the vacated holds should keep copies of receipt notices, RFEs, interview notices, and prior approval notices. Check the case weekly, respond to any USCIS notice by the stated deadline, and update any address change through USCIS right away.
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Companies with employees whose work authorization renewals or green card applications were paused under these policies should monitor the situation closely. If no stay is entered, USCIS should begin moving those cases forward.
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Project Unpause, which fought against the USCIS policies, encouraged affected applicants to "put in congressional inquiries about their cases as the hold will not apply to them so long as this ruling stands."
This is not automatic. Government agencies do not always move quickly to implement court rulings, especially when they intend to appeal.
Applicants should consult with experienced immigration counsel to understand how this ruling affects their specific circumstances and to develop a strategy for moving their cases forward.
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This article is for informational purposes only and does not constitute legal advice. Immigration law is subject to rapid change. If you believe you are affected by this ruling, please consult with a qualified immigration attorney.