Chief Judge John J. McConnell Jr. of the U.S. District Court for the District of Rhode Island ruled in Dorcas International Institute of Rhode Island v. USCIS that USCIS’s Travel Ban Countries policies violated both the Immigration and Nationality Act (INA) and the Administrative Procedure Act (APA). Unlike earlier preliminary injunction wins in other districts, which have generally limited relief to named plaintiffs, the remedy here is vacatur of the underlying policies themselves — carrying far broader effect.
What changed
The agency had thrown “the lives of countless immigrants living in the United States into indeterminate legal limbo” by placing an indefinite pause on the adjudication of immigration benefit requests for individuals from 39 African, Asian, Latin American, and Middle Eastern countries and by re‑opening already approved benefits, based solely on applicants’ countries of birth.
Judge McConnell held that each of the four policies at issue was declared unlawful, vacated, and set aside. The four policies vacated were:
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Benefits Hold Policy: Froze work permit (EAD) approvals, green card adjudications, naturalization, and other immigration benefits for nationals of approximately 39 countries designated “high risk” under executive travel bans.
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Global Asylum Hold Policy: Halted processing of all asylum claims across the board, regardless of country of origin.
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Comprehensive Re-Review Policy: Required USCIS to re-examine and reopen previously approved benefits for applicants from travel ban countries.
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Country-Specific Factors Policy: The policy requiring adjudicators to treat a foreign national being from a travel ban country as a negative factor in the adjudication of discretionary benefits applications.
Judge McConnell found that each policy violated the Administrative Procedure Act and conflicted with existing law, and additionally found that the policies were arbitrary and capricious because USCIS did not provide a reasoned explanation for enacting the policies, did not account for reliance interests in enacting the policies, and provided a pretextual reason for enacting the policies.
Why it matters
The vacatur operates nationwide and removes the legal basis for the freeze entirely. Being from a travel ban country should no longer subject foreign nationals to a USCIS adjudications hold or to review of previous USCIS approvals, and should no longer be considered a negative factor in discretionary USCIS adjudications.
However, immediate implementation is not guaranteed. As the government may seek a stay or appeal, the practical timing or long-term effect of any resumption in adjudication remains uncertain, and any resumption of adjudications is therefore subject to change.
For practitioners: Identify clients from Travel Ban Countries whose asylum, EAD, adjustment, or naturalization cases have stalled, been reopened, or had oath ceremonies cancelled since late 2025; confirm whether those delays were attributable to the now‑vacated policies; and consider targeted agency follow‑up or, where appropriate, litigation that invokes the vacatur and declaratory relief in Dorcas.
Way forward
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Audit your docket. If you have pending cases for clients from any of the 39 affected countries—whether EAD, green card, asylum, or naturalization—pull the file and note the filing date, any biometric completion, and last adjudication date or notice received.
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Send expedite requests. For cases with compelling financial hardship, job loss, or expiring work authorization, file a written request to USCIS field office(s) requesting expedited adjudication in light of the Dorcas vacatur. Reference the case name, case number, and the June 5, 2026 order date.
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Monitor for government appeal. The Trump Administration is expected to appeal the decision. Watch the District Court for the District of Rhode Island docket (Case No. 1:26-cv-00132-JJM-PAS) and the First Circuit Court of Appeals for motions to stay. A stay could temporarily halt implementation.
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Advise clients on next steps. Warn clients and employers that while the freeze is vacated, USCIS may move slowly to clear backlogs. Prepare realistic timelines and advise against relying on immediate approval.
Disclaimer
This article is for informational purposes and reflects the law as of June 5, 2026. It is not legal advice and does not establish an attorney-client relationship. Immigration law and policy can change without notice, and appeals or subsequent court orders may alter how this decision is applied. You should consult a licensed immigration attorney about your specific case and verify all guidance against the primary court order and current USCIS directives.