The Fourth Circuit upheld an injunction barring immigration officials from adopting a relaxed policy on enforcement actions in places of worship, following DHS’s rescission of a longstanding policy of limiting immigration enforcement actions at or near houses of worship in January 2025. The ruling affects eight specific houses of worship affiliated with Quaker, Sikh, and Cooperative Baptist Fellowship organizations and has implications for how practitioners advise clients at these and other faith-based locations.
What changed
The 4th U.S. Circuit Court of Appeals upheld an order limiting immigration enforcement at eight houses of worship, citing the Religious Freedom Restoration Act. U.S. District Judge Theodore Chuang in Maryland issued a preliminary injunction in February 2026 requiring DHS to act in accordance with its prior 2021 guidelines.
The injunction came after DHS rescinded a longstanding policy of limiting immigration enforcement actions at or near houses of worship in January 2025, and the injunction, granted by a Maryland-based federal judge, requires the department to revert to prior guidelines articulated in 2021 under Joe Biden.
The 4th Circuit’s ruling only addressed the claims that the policy violated the Religious Freedom Restoration Act, and the court opted against deciding the First Amendment issues. The panel was unanimous, with three judges joining the opinion.
Why it matters
The ruling creates enforceable protection for clients and worshipers at these eight specific locations while the underlying litigation proceeds. For practitioners representing individuals affiliated with these houses of worship, this means:
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Temporary but binding protection: DHS must follow the 2021 safeguards (limiting enforcement to locations away from the actual building and events, with narrow exceptions for warrants) at these sites during the pendency of the case. This is not a final judgment, but it is an interim order backed by federal appellate authority.
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Evidentiary burden met: The 4th Circuit said the plaintiffs, including Quaker organizations, Sikh Temple Sacramento, and the Cooperative Baptist Fellowship, offered evidence that the change was suppressing worship attendance and participation in immigrant-focused ministries. One Baptist congregation reported a 66% decline in attendance at its English-as-a-second-language classes. This concrete harm bolstered the preliminary injunction.
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Narrow scope: The injunction only covered entities affiliated with the plaintiffs and did not restrict DHS’s actions at any other places identified as sensitive locations in the Biden-era policy, such as shelters and hospitals. Practitioners should not assume the ruling extends beyond these eight named institutions.
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RFRA claim likely to succeed: The Fourth Circuit held that the plaintiffs are likely to succeed on their claim under the Religious Freedom Restoration Act, the 1993 statute that requires the government to show a compelling interest and the least restrictive means when its actions substantially burden religious exercise. This strengthens the plaintiffs’ position as the case proceeds to trial.
Way forward
If you represent clients, donors, or employees at any of the eight named houses of worship (located in Philadelphia, Baltimore, New York, and Sacramento), take these steps:
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Verify affiliation: Confirm that your client’s house of worship is one of the eight named plaintiffs in Philadelphia Yearly Meeting of the Religious Society of Friends v. DHS. The injunction applies only to those entities.
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Educate clients on scope: Counsel clients that the protection applies to immigration enforcement at or near the house of worship, not to their immigration status generally. An individual still faces potential enforcement at other locations or through other investigative means.
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Preserve documentation: If ICE or CBP initiates any enforcement action at or near these locations, document the date, time, officer names, and circumstances. Such evidence could support contempt findings if the agency violates the injunction.
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Monitor case progress: The Maryland injunction remains in place while the case continues before Judge Chuang. Check https://www.courthousenews.com/ and federal court dockets (PACER) for updates on the underlying merits litigation. A final judgment could uphold or dissolve the injunction.
Disclaimer
This article summarizes publicly available court decisions and is not legal advice. Articles.folaform.com is a software platform maintained by a technology company, not a law firm. Do not rely on this article as a substitute for consultation with a licensed immigration attorney or religious freedom specialist familiar with your specific facts and jurisdiction. Federal policy and court rulings can change without notice. Always verify your understanding against the primary source court order, which you can access through the U.S. Courts Public Access to Court Electronic Records (PACER) system or by requesting a copy from the U.S. District Court for the District of Maryland.