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Federal District Court Vacates USCIS Policies That Paused Adjudications of Certain Benefit Requests
On June 05, 2026, the U.S. District Court for the District of Rhode Island vacated several USCIS policies, including its Benefits Holdy Policy, Global Asylum Hold Policy, Comprehensive Re-Review Policy, and Country-Specific Factors Policy.
Background
On December 2, 2025, U.S. Citizenship and Immigration Services (“USCIS”) issued a hold on all asylum applications (regardless of the applicant’s country of nationality), along with a hold on all other benefits for applicants from high-risk countries pursuant to the Presidential Proclamation 10949, issued June 4, 2025.
On January 01, 2025, USCIS issued a hold on all affirmative USCIS benefit adjudications filed by applicants from additional high risks countries (39 countries in total). The USCIS Policy was announced pursuant to Presidential Proclamation 10998.
In both USCIS Policy Announcements and the related Presidential Proclamations, the administration relied on Sections 212(f) and 215(a) of the Immigration and Nationality Act (INA), provisions that authorize the President to impose restrictions on noncitizens when deemed appropriate.
The Court’s Decision
The case was brought by a coalition of nonprofits and unions representing individuals from the thirty-nine countries challenging the legality of the USCIS policies and the federal agency’s implementation of the policies.
A central issue in the case was whether USCIS violated immigration laws that Congress had charged the federal agency with administering. The District Court noted USCIS, through issuing these policies, claimed statutory and regulatory authority that the federal agency did not, in fact, possess.
The District Court also held USCIS made decisions without the reasoned explanations the federal agency is required to provide, and that USCIS acted without regard for the reliance interests of applicants that (USCIS) must consider. Lastly, the District Court held USCIS justified the agency’s actions with pretextual concerns of “national security” that mask anti-immigrant sentiments, which the federal agency is prohibited from allowing be a factor in its decision-making.
The Court found the following USCIS Policies to be unlawful:
- Benefits Hold Policy – the pause on all adjudications of benefit requests submitted by applicants from one of the 39 outlined countries.
- Global Asylum Hold Policy – the pause on all asylum and withholding of removal applications, regardless of country of origin.
- Comprehensive Re-Review Policy – the policy of re-reviewing and re-considering previous decisions to approve immigration benefit requests for applicants from the outlined 39 countries who entered the U.S. during the Biden Administration.
- Country-Specific Factors Policy – the policy of considering the mere fact that an applicant is from a particular country as a negative discretionary factor in adjudicating discretionary benefits (such as Change/Extension of Status and Adjustment of Status applications)
As a result of the Court finding these USCIS policies unlawful, the policies were ordered vacated and set aside.
Potential Impact
This decision affects immigrants who are applicants for asylum from any country, as well as applicants for all USCIS affirmative benefits whose cases have been pending with USCIS.
The pause on USCIS applications is currently eliminated, but an appeal or further litigation could change that outcome.
Brown Immigration Law will continue to monitor the case and provide updates as new information becomes available.
At Brown Immigration Law, we are committed to keeping you informed of the latest developments and providing expert legal guidance during this uncertain time. If you or a loved one is impacted by these changes, our experienced attorneys are here to help you navigate your options and protect your rights. Stay connected with us for timely updates, and don’t hesitate to reach out for personalized assistance.
