Garland v. Gonzalez
The Supreme Court ruled that federal district courts cannot issue class-wide injunctions ordering the government to provide bond hearings for detained immigrants, stripping courts of a key tool for protecting the rights of large groups of people at once.
The decision means immigrants who have been detained for months without a hearing must each file separate legal challenges rather than joining a class action — a significant hurdle given the obstacles most detained immigrants already face.
How it got here: Two federal district courts (in California and Washington) certified classes and issued class-wide injunctions; divided Ninth Circuit panels affirmed; the Supreme Court granted certiorari and added the §1252(f)(1) jurisdictional question for briefing.
The Case in Depth
What happened
Two groups of immigrants — from Mexico and El Salvador — had previously been ordered removed from the United States, reentered illegally, and were detained while applying for protection from deportation. They filed class action lawsuits arguing that immigrants held for more than six months are entitled to a bond hearing before an immigration judge. Federal courts in California and Washington agreed and issued class-wide orders requiring the government to provide those hearings.
The question before the Court
Can federal district courts issue class-wide court orders forcing the government to hold bond hearings for large groups of immigrants who have been detained for months pending removal?
The Court's answer
No. A provision of the Immigration and Nationality Act, §1252(f)(1), bars lower federal courts from issuing injunctions that interfere with the government's enforcement of key immigration laws, and the Court held that this bar covers class-wide injunctions. The statute does carve out one exception — courts can still grant relief as applied to "an individual alien against whom proceedings have been initiated" — but the Court read that singular phrase to mean one specific person, not an entire class.
Both district courts had ordered the government to provide bond hearings for large certified classes of detained immigrants, going well beyond any individual's case. Those orders violated the statutory bar. The Court also rejected the argument that the bar applies only when the government is acting lawfully, finding the plain text covers any court interference with how officials carry out the specified immigration enforcement provisions, regardless of whether the government is complying with the law.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Detained immigrants who believe they are being held unlawfully must now bring individual legal challenges instead of relying on a single class-wide court order that could protect everyone in the same situation. Most detained immigrants lack lawyers, are held far from their communities, and face language barriers — factors that make individual litigation especially difficult, according to the dissent.
What changes now
The cases go back to the Ninth Circuit for further proceedings consistent with the ruling. Detained immigrants can still seek bond hearings by filing individual legal challenges, but cannot use a single class-wide injunction to protect everyone in a similar situation. The Court left open whether §1252(f)(1) also bars class-wide declaratory relief — a court's formal declaration of what the law requires without an accompanying injunction — a question likely to be litigated in future cases.
What this does not decide
The Court explicitly did not decide whether §1252(f)(1) also bars class-wide declaratory relief (a formal legal declaration without an injunction). It also did not rule on whether injunctions covering multiple named plaintiffs — but not a certified class — are permissible. And it left open any challenge under the Administrative Procedure Act, which was not raised here.
Concurrences and dissents
Dissent in part — Justice Sotomayor
Justice Sotomayor concurred in the final judgment (because the government wins on the merits of the underlying immigration question) but dissented sharply from the majority's interpretation of §1252(f)(1). She argued that an injunction compelling the government to comply with a statute does not 'restrain the operation' of that statute — because unlawful agency action is not part of how a statute operates. She also argued the saving clause's phrase 'an individual alien' does not preclude class relief, pointing to established precedent that class actions are collections of individual claims. She warned the ruling will leave many vulnerable noncitizens effectively unable to protect their legal rights. Justice Breyer joined her opinion as to Parts II–A–2, II–B–2, and III.
How the Court got there
The legal reasoning, step by step
- The Court started with §1252(f)(1)'s text, which strips lower courts of 'jurisdiction or authority to enjoin or restrain the operation of' specified immigration enforcement provisions. 'Enjoin' means to order someone to do or not do something; 'restrain' means to hold someone back from a course of action. Together, these words bar courts from ordering federal immigration officials to either take or refrain from taking actions in carrying out the covered laws.
- The phrase 'operation of' those provisions refers to how they function in practice — through officials who implement and enforce them. So a court interferes with the 'operation' of those laws whenever it orders officials to act differently than they otherwise would, whether or not the officials are implementing the law correctly. The Court rejected the immigrants' argument that 'operation' means only lawful government action, noting it is common to speak of 'unlawful operation' of many things, and the statute's own prefatory clause applies 'regardless of the nature of the action or claim.'
- Section 1252(f)(1) contains one exception: courts may still grant relief 'with respect to the application of such provisions to an individual alien against whom proceedings under such part have been initiated.' Congress used the singular noun 'an alien' modified by 'individual' — a word meaning 'pertaining to one single person' — signaling that only person-specific relief is preserved.
- Prior Court statements in Reno v. American-Arab Anti-Discrimination Committee (1999) had already noted that §1252(f)(1) 'prohibits federal courts from granting classwide injunctive relief' while it 'does not extend to individual cases.' The Court reaffirmed that reading here as a direct holding.
- Both district courts' orders required bond hearings not just for the named plaintiffs but for all class members — entire groups of detained immigrants. Those orders 'enjoin or restrain the operation' of §1231(a)(6) by forcing officials to act in ways the government says the statute does not require. Because the orders extended beyond any single individual, they did not fall within the exception and were therefore unlawful.
- The Court also rejected the argument that the exception's reference to 'an individual' permits class-wide relief because a class is simply a collection of individuals. The statute says 'an individual,' not 'individuals,' and reading it otherwise would make §1252(f)(1)'s general prohibition meaningless. The Court declined to say whether the bar also covers injunctions benefiting multiple named plaintiffs in a single lawsuit, holding only that full class-wide relief was unlawful.
Doctrinal impact
Cases affected by this decision
Reaffirms Reno v. American-Arab Anti-Discrimination Comm. (525 U. S. 471)
Prior statement that §1252(f)(1) bars class-wide injunctive relief is now a direct holding of the Court.
Distinguishes Califano v. Yamasaki (442 U. S. 682)
Social Security Act ruling permitting class actions under 'any individual' language does not control because §1252(f)(1) limits rather than authorizes judicial review.