On June 5, 2026, U.S. District Court for the District of Rhode Island declared unlawful and vacated certain policies enacted by USCIS that had frozen immigration benefits for nationals from 39 countries. Chief Judge John J. McConnell, Jr. vacated the USCIS policies that froze immigration benefits and held that all four challenged policies are unlawful under the Administrative Procedure Act. This decision opens the door to hundreds of thousands of pending immigration applications nationwide.
What changed
The Benefits Hold Policy placed an indefinite hold on adjudication of all immigration benefit requests, including adjustment of status, employment authorization, and naturalization, filed by individuals from thirty-nine Travel Ban Countries. The Global Asylum Hold Policy halted adjudication of all asylum and withholding of removal applications, regardless of the applicant’s country of origin. The Comprehensive Re-Review Policy required USCIS to re-review and reconsider already approved benefit requests for any individual from a Travel Ban Country who entered the United States on or after January 20, 2021. The Country-Specific Factors Policy updated the USCIS Policy Manual to direct adjudicators to treat country-specific factors from the travel ban as a significant negative factor when weighing discretion in benefit adjudications.
The court vacated all four policies, finding they violated the Administrative Procedure Act. Unlike earlier preliminary injunction wins in other districts, which had generally limited relief to named plaintiffs, the remedy here is vacatur of the underlying policies themselves, which carries far broader effect.
Why it matters
This ruling directly impacts your benefit adjudication timeline and client expectations. The 135-page ruling opens the door for hundreds of thousands of people with pending immigration-related applications to have these benefits unpaused. If you have clients from the 39 affected countries with stalled adjustment of status applications, employment authorization requests, or asylum cases, you should expect USCIS to resume adjudication absent a stay pending appeal.
However, implementation is not automatic. The government may appeal to the First Circuit, which is the most likely near-term step, as DHS has signaled in related litigation that it views these policies as core national security functions. The government may ask the district court or the First Circuit to stay the vacatur so the holds can remain in effect while the appeal proceeds, and whether a stay is granted will shape what happens to pending cases in the interim.
Way forward
- Monitor the First Circuit docket. The government is expected to file an appeal. If the court grants a stay pending appeal, the holds remain in place during litigation.
- Prepare benefit adjudication materials now. For clients with pending applications, gather supporting documentation and be ready to resubmit or supplement applications if USCIS requests additional evidence.
- Manage client expectations. Explain that while the court has vacated the policies, an appeal and potential stay are likely. Benefit adjudication may resume, but not immediately if the government obtains a stay.
- Track USCIS guidance. USCIS and DHS will issue implementation instructions as the litigation proceeds. Subscribe to agency alerts for updates on benefit processing.
Disclaimer
This article is for informational purposes only and is not legal advice. Folaform is a software company, not a law firm. Immigration law is complex and policy can change without notice. Consult a licensed immigration attorney about your specific situation and verify all information against the primary source linked above and the latest agency guidance.