- Plaintiffs showed followers free exercise rights violated
- DHS didn’t show injunction will adversely impact interests
The Trump administration was preliminarily blocked by a federal court from conducting immigration raids in or near certain places of worship.
Religious groups showed that the administration’s new policy likely violates their free exercise rights, Judge Theodore D. Chuang said Monday for the US District Court for the District of Maryland.
The opinion is the latest to put Trump’s new immigration policies on hold. A federal judge in Seattle last month temporarily blocked the president’s birthright citizenship order and the US Court of Appeals for the Ninth Circuit last week declined to narrow the injunction. A New Hampshire federal judge also blocked that initiative earlier this month. The Justice Department has asked the US Court of Appeals for the Fourth Circuit to narrow a similar court order from another Maryland federal judge.
The Philadelphia Yearly Meeting of the Religious Society of Friends and other groups presented sufficient evidence that their followers are refraining from attending services because of the new policy and their religious exercise is being hindered, Chuang said. In contrast, the administration “provided no facts demonstrating how its interests, increased immigration enforcement or otherwise, would be materially and adversely impacted by an injunction,” he said.
Chuang rejected the Department of Homeland Security’s argument that the Immigration and Nationality Act prohibited the injunction. The provision DHS cited “bars only the grant of injunctive relief applicable beyond the circumstances of an individual alien,” he said.
The plaintiffs are likely to succeed on the merits of their claim that the new policy violates their right to expressive association under the First Amendment, Chuang said. The plaintiffs showed that the new policy provides no guidelines limiting the raids, burdens their right to communal worship by deterring congregants from attending services, and interferes with their ministry programs to help immigrants, he said.
Reductions in attendance significantly affects the plaintiffs’ expressive association because their beliefs require communal worship and activities, Chuang said.
The plaintiffs are also likely to succeed on their claim under the Religious Freedom Restoration Act, because the statute very broadly prohibits the government from interfering with religious liberty and they sufficiently alleged that the new policy will likely result in the decline of worshipers at services, Chuang said. DHS also didn’t provide a compelling governmental interest to warrant its intrusion into the plaintiffs’ religious rights, he said.
Chuang refused to issue a nationwide injunction, limiting his order to congregations that believe in communal worship, service to immigrants, and pacifism.
The plaintiffs, also include the New England Yearly Meeting of the Religious Society of Friends, Baltimore Yearly Meeting of the Religious Society of Friends, Adelphi Friends Meeting of the Religious Society of Friends, and Richmond Friends Meeting of the Religious Society of Friends.
The Department of Justice didn’t immediately respond to a request for comment.
Democracy Forward Foundation represents the plaintiffs.
The case is Philadelphia Yearly Meeting of the Religious Society of Friends v. DHS, D. Md., No. 8:25-cv-00243, preliminary injunction issued 2/24/25.
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