Rhode Island Federal Court Strikes Down USCIS Policies Suspending Immigration Benefits for Nationals of 39 Countries

In late 2025/early 2026, following the Trump administration’s renewed travel ban proclamations targeting certain countries (primarily in Africa, the Middle East, Asia, and Latin America), USCIS under Director Joseph Edlow issued several internal policy memoranda. These included:

• A Global Asylum Hold Policy pausing adjudication of asylum and withholding of removal applications (initially worldwide, later adjusted).
• A Benefits Hold Policy (or adjudication hold) indefinitely suspending decisions on a wide range of immigration benefits, including asylum, employment authorization documents (EADs/work permits), adjustment of status (green cards), naturalization, and other petitions, for nationals of 39 designated “high-risk”/travel-ban countries, plus those with Palestinian Authority-issued or endorsed documents.
• A Comprehensive Re-Review Policy requiring re-examination of previously approved benefits for individuals from these countries who entered the U.S. on or after January 20, 2021.
• A Country-Specific Factors Policy directing adjudicators to treat an applicant’s country of origin (from the travel-ban list) as a significant negative factor in discretionary decisions.

These policies affected tens or hundreds of thousands of applicants already in the U.S. who had followed legal processes (filing forms, paying fees, submitting biometrics, attending interviews). They created prolonged uncertainty, preventing work authorization, travel, status adjustments, and other benefits, often for months or indefinitely. Plaintiffs (a coalition of immigrant service nonprofits and labor unions, including Dorcas International Institute of Rhode Island) sued in the U.S. District Court for the District of Rhode Island, challenging the policies under the Administrative Procedure Act (APA) and the Fifth Amendment.

Issues

The core legal questions were whether USCIS had statutory or regulatory authority to categorically pause or suspend adjudications of benefits that Congress and regulations direct the agency to process (often using mandatory “shall” language with timelines, e.g., asylum within certain periods, naturalization within 120 days). Additional issues included whether the policies were arbitrary and capricious under the APA for lack of reasoned explanation, failure to consider reliance interests of applicants, and pretextual national security justifications; whether they were final agency actions reviewable by courts; standing/ripeness; and jurisdictional bars under the INA.

Decision

On June 5, 2026, in a 135-page Memorandum and Order (Case No. 1:26-cv-00132-JJM-PAS), Chief Judge John J. McConnell Jr. granted summary judgment to the plaintiffs on their APA claims. He declared each of the four challenged policies unlawful, vacated, and set them aside nationwide. The court found they were contrary to law (exceeding USCIS’s authority under the INA and conflicting with mandatory adjudication requirements) and arbitrary and capricious. It rejected the government’s jurisdictional, justiciability, and national security arguments against review. The court issued a declaratory judgment but declined a separate permanent injunction, finding vacatur sufficient. Constitutional claims were addressed separately (motion to dismiss).

Analysis of the Decision

Judge McConnell emphasized the rule of law applying equally: applicants who “followed the law” were punished solely based on nationality/birth, contrary to statutory mandates. Key holdings:

• No authority for categorical holds: The INA and regulations require adjudication; 8 U.S.C. § 1182(f) (travel ban authority) does not extend to pausing domestic benefit processing for those already in the U.S.
• Arbitrary and capricious: USCIS failed to provide a reasoned explanation linking isolated incidents (e.g., crimes by a couple of individuals) to blanket freezes on 39 countries plus global asylum. It ignored reliance interests (applicants who built lives expecting timely processing) and offered pretextual national security rationales amid anti-immigrant statements from administration officials.
• Broad relief: Nationwide vacatur ensures uniform application, preventing the agency from evading review by labeling policies “interim.”
• Broader implications: The ruling reinforces limits on agency power to reshape immigration via internal memos rather than notice-and-comment rulemaking or statutory changes. It highlights judicial skepticism of nationality-based distinctions in benefits adjudication absent clear authority. The government may appeal or seek a stay; implementation will require USCIS to resume processing affected cases.

Public Access Link: https://storage.courtlistener.com/recap/gov.uscourts.rid.61671/gov.uscourts.rid.61671.28.0.pdf

Citation: Dorcas International Institute of Rhode Island v. United States Citizenship and Immigration Services, No. 1:26-cv-00132-JJM-PAS, 2026 WL