On June 5, 2026, the U.S. District Court for the District of Rhode Island declared unlawful and vacated certain policies enacted by the U.S. Citizenship and Immigration Services (USCIS) that effectively halted the adjudication of immigration applications filed by nationals of various countries. To take a deeper dive and to understand how this decision came down, it is important to review the recent immigration policies enacted by the Trump administration.
The Travel Bans
As our June 9, 2025, blog post discussed, on June 4, 2025, President Trump issued the Presidential “Proclamation Restricting the Entry of Foreign Nationals to Protect the United States from Foreign Terrorists and Other National Security and Public Safety Threats.” It essentially restricted or partially restricted the entry of foreign nationals of nearly 20 countries concentrated in the Middle East, sub-Saharan Africa, Asia, and Latin America. The blog post lists out the countries and categorizes them based on the types of entry restrictions imposed.
Then, on December 16, 2025, President Trump issued another Proclamation: “Restricting and Limiting the Entry of Foreign Nationals to Protect the Security of the United States” which expanded the list of countries whose nationals were subject to entry restrictions to 39.
USCIS Policies
In the midst of these travel bans coming into effect, USCIS began implementing measures restricting the final adjudication and decisions of certain applications filed by individuals from these countries.
First, on November 27, 2025, USCIS issued a Policy Alert (not a formal memorandum) that instructed USCIS officers to apply the applicant’s country of birth or nationality, such as those specified in President Trump’s June 2025 travel ban, as a significant negative factor in adjudicating immigration applications.
Second, on December 2, 2025, USCIS issued a Policy Memorandum that requires its officers to halt all decisions on all applications for asylum and withholding of removal; pause adjudications of all applications filed by those specifically from the travel ban countries listed on the June 2025 travel ban; and conduct a re-review of immigration applications already approved filed by individuals from the countries listed on the June 2025 travel ban.
Finally, on January 1, 2026, USCIS issued another Policy Memorandum that extended the applicability of the December 2025 Memorandum to the countries listed in the updated December 2025 travel ban. Our blog post from January 9, 2026, goes into depth on the full list of countries and its applicability.
While USCIS lifted some aspects of its policy on March 30 and April 30, 2026, such as resuming processing of asylum applications filed by nationals from the non-travel-ban countries, petitions filed by U.S. citizens, adoptions, citizenship oath ceremonies, certain special immigrant petitions, certain work permit applications and applications associated with physicians, the core components of the pause remained in effect, placing numerous foreign nationals, as well as family and employer petitioners, in significant uncertainty.
The Federal Court Decision
Then, on June 5, 2026, the U.S. District Court for the District of Rhode Island ruled the USCIS adjudication pauses, the Asylum Hold Policy, the re-review policy, and the country-specific factors policy were unlawful and therefore vacated. The Court determined such policies violated the Immigration and Nationality Act, the Administrative Procedure Act and longstanding precedent inhibiting USCIS’s ability to apply “arbitrary and capricious” measures against applicants. As a result, the Court vacated the policies and issued a declaratory judgment that the policies were unlawful.
Of note is that the Court did not suppress the June 2025 and December 2025 travel bans, whose applicability extends to those traveling into the United States from abroad. The Court decision only focuses on the particular policies implemented by USCIS for immigration applications filed to the agency. As of time of this writing, the June 2025 and December 2025 travel bans remain in effect.
Potential Aftermath
With this Court decision, USCIS’s Policy Memoranda that implemented these pauses, holds, re-reviews and country-specific determinations are no longer in effect. However, the government retains the discretion to appeal the decision to the Federal Circuit Court of Appeals and request the appellate court stay the decision of the lower court while the litigation progresses. As of the time of this writing, no appeal has been filed. Also important to note, the court ruling does not affect the recent USCIS Adjustment of Status memo that was issued on May 26.
While the June 5 court ruling is a reprieve for those who have been affected by this policy, the applicability of this recent decision in the future remains uncertain.
Our Immigration Practice Group is carefully watching and analyzing federal immigration decisions. If you have questions on this or any other immigration topic, please contact attorney Christian P. Burr at (860) 240-6131 or cburr@harrisbeachmurtha.com, or the Harris Beach Murtha attorney with whom you most frequently work.
This alert is not a substitute for advice of counsel on specific legal issues.
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