A federal judge in Rhode Island vacated USCIS policies that had frozen immigration benefits for nationals of thirty-nine countries, holding that all four challenged policies are unlawful under the Administrative Procedure Act and setting them aside. The decision has immediate consequences for practitioners with pending cases involving affected beneficiaries.
What changed
Chief Judge John J. McConnell Jr. of the United States District Court for the District of Rhode Island vacated the USCIS policies that have frozen immigration benefits for nationals of thirty-nine countries since late last year. The policies that were vacated had halted all asylum adjudications until March 30, 2026, suspended adjudications on all benefit applications (green cards, work permits, and naturalization) for nationals of 39 countries, ordered re-review of already-approved benefits for those nationals who entered on or after January 20, 2021, and directed adjudicators to treat an applicant’s country of origin as a “significant negative factor” in discretionary decisions.
The court found that USCIS claimed statutory and regulatory authority it does not possess, failed to provide the reasoned explanation the law requires, ignored the reliance interests of applicants, and justified the policies with national security concerns that the court characterized as pretextual. The Immigration and Nationality Act uses mandatory “shall” language requiring USCIS to adjudicate asylum applications within 180 days, naturalization applications within 120 days, and employment authorization and adjustment of status applications pursuant to specific regulatory timelines.
Why it matters
Applicants who had filed properly, paid their fees, completed biometrics, and attended interviews were left waiting for months with no decision, and in many cases lost work authorization, jobs, and legal status while their cases sat frozen. For practitioners, the ruling clears the legal path to resume adjudication and eliminates the categorical hold that had stopped all forward movement.
However, three critical risks remain. First, DHS is expected to appeal and very possibly to seek a stay, and until the dust settles, the status of pending cases for affected applicants could shift again, potentially more than once. Second, dozens of cases challenging the benefits holds are pending across federal district courts, and a nationwide vacatur out of Rhode Island changes the landscape, but circuit splits and competing rulings remain a real possibility. Third, practitioners should verify the current status of their individual pending cases with USCIS, as the agency may narrow or reframe the hold on a case-by-case basis rather than fully capitulate.
Way forward
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Check your pending case list. Identify all clients with nationals from the 39 affected countries and pending I-485, I-131, I-140, asylum, naturalization, or other benefit applications. Flag those frozen under PM-602-0192, PM-602-0194, or successor directives.
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Monitor USCIS guidance. The court’s order compels USCIS to resume processing; watch for agency policy reversals, FAQ updates, or written guidance on how the vacatur will be implemented on the adjudication floor.
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Prepare status/stage inquiries. For frozen cases, consider USCIS FOIA or e-Request to obtain status and establish that adjudication should now proceed under resumed timelines. Document the freeze to preserve grounds for any follow-up requests for expedited handling.
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Watch the appeal. Check ECF for the case (Dorcas International Institute v. USCIS, D.R.I. No. 1:26-cv-00132) and relevant appellate filings. A government appeal or stay motion could reverse the relief; be prepared to argue reliance interests and irreparable harm if needed in support of clients.
Disclaimer
Fola is not a law firm and does not provide legal advice. This article summarizes a federal court decision for informational purposes. Consult a licensed immigration attorney before taking action on any pending case. Immigration policy and adjudication practice can change rapidly; always verify the current status of your client’s case and USCIS guidance against the primary source materials, including the court opinion linked above and any superseding USCIS memoranda or notices.