On June 27, 2025, the U.S. Supreme Court issued a decision in Trump v. CASA, Inc. that significantly limits the reach of nationwide injunctions, a ruling that could have major implications for employers across the country.
The Court held that federal courts likely overstep their authority when blocking rules or policies nationwide, unless the relief is narrowly tailored to apply only to the plaintiffs involved in the case. As a result, we expect a wave of legal motions to immediately roll back existing nationwide injunctions, many of which have been keeping significant regulatory changes on hold.
What this means for employers
Previously blocked federal rules, especially those related to employment and workplace compliance, may soon be enforceable again for employers not directly tied to the underlying lawsuits. Some of the rules that may be impacted include, but is not limited to:
- Overtime Rule 1.0 (2016): Salary threshold for white-collar overtime exemptions.
- EEO-1 Component 2 Reporting (2019): Pay data by race and gender.
- Public Charge Rule (2019–2021): Immigration restrictions affecting foreign worker eligibility.
- Joint Employer Standards (2020): Definitions impacting franchise and staffing relationships.
- Union Election Rules (2020–2022): Changes to union election procedures.
- COVID-19 Vaccine Mandates (2021): OSHA’s ETS for large employers.
- FTC Non-Compete Ban (2024): Nationwide injunctions currently pausing the rule.
- Overtime Rule 2.0 (2024): Updated FLSA salary thresholds.
- Title IX Regulations (2025): Gender identity protections affecting educational employers.
What you can do now
With most nationwide injunctions now likely to be considered overbroad, courts will begin reinstating previously enjoined rules unless you or your business were specifically involved in the litigation. Employers should prepare for potential compliance obligations to return quickly and unexpectedly, and may need to consider filing their own private actions to ensure they continue to receive the benefit of any vulnerable nationwide injunction that they consider necessary to their business.
We are here to help you review your current practices and ensure you’re ready to respond as these regulations come back online.
Please reach out to Partners Arnold Shokouhi, Tarig Anani, Jesse Hoffman, or Jim Sherry with any questions or for support tailored to your specific situation.
Source: JD Supra, “SCOTUS Will Soon Decide if Federal Courts Can Issue Nationwide Injunctions” (June 2025)