Trump v. CASA Employer Impact: Limiting Nationwide Injunctions, Navigating Multistate Compliance Challenges

In Trump v. CASA (2025), the U.S. Supreme Court limited the ability of federal district court judges to issue nationwide or "universal" injunctions that have historically been used to block actions taken by the White House or federal agencies. The Court held that district courts cannot issue injunctions that prohibit enforcement of executive actions beyond the parties before the Court. 

This ruling will have a significant impact on employers who have already been subject to regulatory whiplash over recent years with policy changes between one administration and another. The CASA ruling adds a new level of legal uncertainty for employers trying to develop and enforce compliant policies where federal regulation may be stayed or vacated in certain jurisdictions yet is allowed to stand in other jurisdictions.

Adding to this uncertainty are the questions left open by the Court—which did not address nationwide class actions, a "potentially significant loophole," and whether the Administrative Procedure Act (APA) authorizes federal courts to vacate federal agency action—possible alternative avenues for plaintiff claims. And questions arise related to the status of other key regulations that have been challenged and stayed or vacated under the prior administration, such as the FTC's noncompete rule that was vacated with nationwide effect in Ryan L.L.C. v. Fed. Trade Comm’n (2024).

Listen as our expert panel examines the CASA ruling and the impact on employers. The panel will discuss open questions and offer best practices for guiding employer policy development and enforcement in this rapidly evolving regulatory environment.

I. Introduction

II. Trump v. CASA (2025)

A. Limiting nationwide injunction

B. Class actions?

C. Relief under the APA?

III. Employer impact

A. Past administration's regulation or EOs impacting employment that have been stayed or vacated

1. FTC noncompete rule and Ryan L.L.C. v. Fed. Trade Comm’n

B. Current administration's regulation or EOs related to employment and what to expect

C. Multistate employer challenges: policy development and enforcement

D. State law considerations

IV. Best practices and practitioner takeaways

The panel will review these and other important issues:

• What compliance challenges does CASA raise for employers, particularly those in multiple states?
• What immediate impact will the CASA ruling have on the current administration's regulation or EOs that have been stayed or vacated prior to the ruling? With what effect for employers?
• What effect may CASA have on other regulations that have been stayed or vacated on a national basis in prior administrations, such as the FTC's noncompete rule, that significantly impact employers?
• What are best practices for guiding employer clients through policy development and enforcement post-CASA?