A federal judge struck down Trump administration policies that instituted an indefinite pause on processing asylum and green card applications submitted by people from certain countries. Chief Judge John J. McConnell, Jr. of the U.S. District Court for the District of Rhode Island vacated all four challenged policies, declaring them unlawful under the Administrative Procedure Act and setting them aside. This ruling affects thousands of applicants whose cases have been frozen and has immediate implications for how you advise clients on application status and timing.
What changed
USCIS imposed the adjudication holds via two policy memoranda: December 2, 2025 (PM-602-0192), which tied an initial hold to a nineteen-country list and imposed a nationwide hold on asylum applications, and January 1, 2026 (PM-602-0194), which expanded the hold to cover all thirty-nine Travel Ban Countries. The agency stopped processing applications for green cards, work permits, and citizenship from people from those countries, leaving many individuals already in the U.S. legally in perpetual limbo.
The court held that all four challenged policies are unlawful under the Administrative Procedure Act and declared them invalid and set aside. Judge McConnell found that USCIS claims statutory and regulatory authority it does not possess, makes decisions without the reasoned explanations required by law, acts without regard for the reliance interests of applicants, and justifies its actions with pretextual concerns of ‘national security’ that mask anti-immigrant sentiments.
The ruling struck down four specific policies: a global asylum hold, a benefits hold on work permits, green cards, and naturalizations, a comprehensive review policy to look at already-decided cases, and the country-specific ban, which required officers to treat certain nationalities as riskier.
Why it matters
Unlike earlier preliminary injunction wins in other districts that have limited relief to named plaintiffs, this remedy is vacatur of the underlying policies themselves, which carries far broader effect. You now have a binding district court ruling—not a preliminary injunction—that invalidates the entire framework USCIS used to justify these freezes.
The judge noted the affected immigrants “filed the appropriate paperwork, paid the required filing fees, submitted to the requested biometrics collections, and attended the necessary in person interviews”—yet applicants who had done all this were left waiting for months with no decision, and in many cases lost work authorization, jobs, and legal status while their cases sat frozen. Other immigrants will benefit, including asylum applicants, workers relying on employment authorization, green card applicants, and those applying for citizenship; many had faced losing their jobs after their work permits expired, had been left without legal status, and had been separated from family members.
DHS is expected to appeal and may seek a stay, so the status of pending cases for affected applicants could shift again, potentially more than once, until the dust settles. You should plan for both scenarios: immediate processing if the ruling stands, and potential reimposition if stayed on appeal.
Way forward
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Identify affected clients: If a client filed an asylum, green card, work permit, or citizenship application from one of the 39 Travel Ban Countries and the case was frozen after December 2025, the policy now blocking it has been vacated. Begin preparing to move the case forward.
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Request expedited processing: Contact USCIS to request that cases frozen under these policies be prioritized for adjudication now that the legal basis for the hold no longer exists. Judge McConnell said USCIS needs to restart application processing for all immigrants impacted by the pause.
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Monitor appeal and stay motions: Expect DHS to appeal and possibly seek a stay. Monitor the Rhode Island federal court docket (Dorcas International Institute v. USCIS, 1:26-cv-00132) and the First Circuit for developments. If a stay is granted, frozen cases may be halted again pending appeal.
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Preserve the record: If USCIS attempts to reinstate or apply variant versions of these policies, document the rejection with reference to the McConnell ruling and the vacatur order.
Disclaimer
This article summarizes a federal court decision and is not legal advice. Immigration law is fact-intensive, and the application of this ruling to any particular case depends on individual circumstances. Consult a licensed immigration attorney in your jurisdiction to discuss your specific situation and strategy. This policy landscape is rapidly evolving; verify current USCIS guidance and the status of any pending appeals before relying on this summary.