A federal judge on Friday ruled that President Donald Trump’s administration had adopted a series of unlawful policies that have barred people from 39 countries from receiving decisions on applications for asylum, work permits, green cards and citizenship. Chief U.S. District Judge John McConnell in Providence, Rhode Island, struck down a slate of policies that the U.S. Citizenship and Immigration Services had adopted that he said left people from dozens of African, Asian, Latin American and Middle Eastern countries in “indeterminate legal limbo.”
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 court held that all four challenged policies are unlawful under the Administrative Procedure Act, declared them invalid, and set them aside.
The four policies vacated are:
- The Benefits Hold Policy
- The Global Asylum Hold Policy
- The Comprehensive Re-Review Policy
- The Country-Specific Factors Policy
The December 2, 2025 memorandum (PM-602-0192) imposed the initial adjudication hold tied to the nineteen-country list and placed a nationwide hold on asylum applications. The January 1, 2026 memorandum (PM-602-0194) expanded the hold to cover all thirty-nine Travel Ban Countries.
Judge McConnell also invalidated a USCIS policy that required immigrants from countries on the Trump administration’s travel ban list—who had already been approved for immigration benefits after entering the United States after 2021—to undergo a second review of their cases. Judge McConnell concluded that USCIS exceeded its statutory authority and violated the Administrative Procedure Act (APA).
The court did not merely require USCIS to reconsider the policies. The court vacated all four policies and declared them unlawful. At the same time, the court declined to issue a permanent injunction, concluding that vacatur and declaratory relief provided an adequate remedy.
Why it matters
This ruling has immediate, nationwide effect on pending immigration benefit applications. Unlike the earlier preliminary injunction wins in other districts, which have generally limited relief to the named plaintiffs in those cases, the remedy here is vacatur of the underlying policies themselves. That carries far broader effect.
If your client filed an I-485, I-539, I-765, I-131, N-400, or asylum application on or after January 1, 2026, and is a national of one of the 39 affected countries, USCIS may no longer lawfully hold the case pending. The judge has ordered USCIS to resume the processing of immigration applications filed by people from the 39 countries who were affected by Trump’s travel ban, as well as asylum applications.
Critical limitation: while some early reports suggested that the court had struck down the Administration’s travel ban itself, that is not what happened. Instead, the court targeted the mechanism USCIS used to implement portions of those restrictions through its internal adjudication practices. The Presidential Proclamations 10949 and 10998 (the travel ban itself) remain in effect; the court invalidated only USCIS’s use of those proclamations as a blanket reason to freeze benefit adjudications.
However, you should anticipate government appeal and possible stay motion. DHS is expected to appeal and very possibly to seek a stay. Until the dust settles, the status of pending cases for affected applicants could shift again, potentially more than once.
Way forward
Immediately:
- Check your open case inventory for nationals of the 39 affected countries. Identify all cases with pending benefit applications filed on or after January 1, 2026.
- Contact USCIS by phone and in writing to confirm that the adjudication hold has been lifted on each such case. Document the date and time of your inquiry and the officer’s response.
- Update your clients in writing that the court has ordered USCIS to resume adjudication. Note that DHS may appeal, and advise them to monitor your updates.
Next steps:
- Track the docket in Dorcas International Institute of Rhode Island v. USCIS, No. 1:26-cv-00132 (D.R.I.), for any government motion for stay or appeal.
- If a stay is granted, review whether your client’s case falls within any carve-out or exception that USCIS may attempt to implement.
- If your client has a case affected by the Comprehensive Re-Review Policy (the “second look” on approved benefits), prepare a motion to expedite or a request for immediate adjudication.
Disclaimer
This article is published by a software company for informational purposes only and does not constitute legal advice. You should not rely on this article as a substitute for consultation with a licensed immigration attorney or accredited representative. Always verify announcements and rulings against the primary source documents cited. Immigration policy can change without notice, and court orders may be modified on appeal or by stay motion. Consult a qualified practitioner before advising any client on the effect of this ruling on their specific case.