A federal court has vacated four USCIS policies that froze immigration benefit adjudications for applicants from travel ban countries. The court vacated policies that placed indefinite holds on adjustment of status, employment authorization, and naturalization filings by individuals from thirty-nine Travel Ban Countries. The decision eliminates blocks that left applicants waiting for months after completing interviews and paying fees.
What changed
USCIS issued two policy memoranda: PM-602-0192 on December 2, 2025, imposing an initial adjudication hold tied to a nineteen-country list and placing a nationwide hold on asylum applications, and PM-602-0194 on January 1, 2026, expanding the hold to cover all thirty-nine Travel Ban Countries.
The court vacated four distinct policies: the Benefits Hold Policy (freezing all immigration benefit requests including adjustment of status and work authorization), the Global Asylum Hold Policy (halting all asylum and withholding of removal applications regardless of country of origin), the Comprehensive Re-Review Policy, and the Country-Specific Factors Policy.
The Comprehensive Re-Review Policy required USCIS to re-review and reconsider already approved benefit requests for individuals from Travel Ban Countries who entered the United States on or after January 20, 2021, and the Country-Specific Factors Policy directed adjudicators to treat travel ban factors as a significant negative factor in discretionary adjudications.
The court denied the plaintiffs’ request for a permanent injunction, finding vacatur sufficient.
Why it matters
The adjudication holds left applicants who had filed properly, paid fees, completed biometrics, and attended interviews waiting for months with no decision, and in many cases losing work authorization, jobs, and legal status while cases sat frozen. This decision restores the path to adjudication for thousands of pending cases.
Practitioners with clients affected by these holds now have a court ruling supporting their demand for USCIS to resume processing. However, DHS is expected to appeal and very possibly seek a stay, meaning the status of pending cases could shift again pending further litigation. You should monitor the government’s next filing and any appellate stay motion closely, as the practical effect of this ruling may shift depending on what relief is sought.
The court’s decision also affects future adjudications: USCIS cannot apply the blanket holds or the country-specific negative discretion guidance that were at issue. However, individual vetting and security checks are not precluded.
Way forward
- Review affected pending cases immediately. If you have clients from the thirty-nine Travel Ban Countries with stalled adjustment of status, employment authorization, naturalization, or asylum applications, this ruling may unlock their cases. Determine the filing date and current status.
- Prepare a follow-up submission. Consider whether a letter to the adjudicating office referencing the vacated policies and requesting expedited adjudication is warranted for your client.
- Monitor the appeal. Check federal court dockets and USCIS announcements for news of any government appeal or stay application. Your strategy for clients may need to shift if the stay is granted.
- Document the hold dates. For clients who lost work authorization or other status while the hold was in place, preserve records of the freeze period—this may be relevant for future filings, fee waivers, or discretionary considerations.
Disclaimer
This article is provided by a software company, not a law firm, and does not constitute legal advice. Immigration policy is subject to change without notice, and appeals or stay decisions may alter the practical effect of this ruling. Verify the current status of this decision and its application to your specific client situation by consulting a licensed immigration attorney and checking the primary court decision and any subsequent appellate filings. The information here is accurate as of the publication date but may be superseded by government action or further litigation.