- A federal judge ruled the USCIS hold unlawful after the agency blocked cases from thirty-nine countries.
- USCIS Deputy Director Alfonso-Royals claimed Nigerian records are notorious for forgery and unreliable identity management.
- Processing has resumed pending an appeal in the First Circuit Court following the June twenty twenty-six ruling.
(RHODE ISLAND) – USCIS faced a court challenge over an interagency adjudicative hold affecting 39 countries, with Deputy Director Angelica Alfonso-Royals telling a federal court that Nigerian records are frequently forged and identity verification is unreliable, before a judge declared the policies unlawful and ordered processing to resume.
Angelica Alfonso-Royals filed the declaration on June 19, 2026, in the U.S. District Court in Rhode Island. She wrote that “Nigerian officials are notorious for forging documents” and that “many Nigerian marriage and divorce events are not recorded in formal government databases. When they are, record-keeping is poor to non-existent.”
Her filing tied those assertions to the agency’s defense of a broad hold on immigration cases from countries the administration classified as high risk. USCIS also argued that Nigeria and other affected countries possess little to no credible identity management infrastructure.
At issue were internal USCIS directives PM-602-0192, dated December 2, 2025, PM-602-0194, dated January 1, 2026, and Policy Alert PA 2025-26. Those measures halted adjudication of Form I-485 green card cases, Form I-765 work permit requests, and asylum applications for nationals of 39 countries.
Nigeria was among the countries swept into the hold, along with Afghanistan, Iran, and Venezuela. The policy also required a comprehensive re-review of benefits approved on or after January 20, 2021.
The administration linked the policy to national security concerns raised in Presidential Proclamations 10949 and 10998. Those proclamations followed a November 2025 shooting in Washington, D.C., involving an Afghan national.
| Date | Event | Actors | Impact |
|---|---|---|---|
| November 2025 | Shooting in Washington, D.C., cited in later presidential actions | White House | National security concerns became the stated basis for new screening measures |
| December 2, 2025 | PM-602-0192 took effect | USCIS | Part of the framework for the adjudicative hold |
| January 1, 2026 | PM-602-0194 took effect | USCIS | Expanded internal guidance tied to halted adjudications |
| June 11, 2026 | Judge ruled policies unlawful | Chief Judge John J. McConnell Jr. | USCIS was ordered to lift holds and resume processing |
| June 12, 2026 | USCIS said it would resume processing | USCIS Newsroom | Agency complied while seeking further review |
| June 19, 2026 | Deputy director filed declaration on Nigerian records | Angelica Alfonso-Royals | Government defended the hold with allegations about document fraud and weak identity systems |
| June 22, 2026 | Appeal pending in the First Circuit | U.S. Court of Appeals for the First Circuit | Processing continues, but the case remains active |
Chief Judge John J. McConnell Jr. ruled on June 11, 2026, in Dorcas International Institute of Rhode Island v. USCIS, Case No. 1:26-cv-00132 (D.R.I. 2026). He found the policies “unlawful, null, and void“ and said USCIS exceeded its authority.
McConnell also wrote that the agency acted with “anti-immigrant malice” while invoking national security. His order required USCIS to lift the adjudicative hold and resume work on affected filings.
USCIS responded a day later. In a June 12, 2026 statement, the agency said it disagreed with the judgment but would resume processing pending benefit requests while pursuing further judicial review.
That response left two tracks in place at once. Applications moved again, but the government sought an emergency stay and appealed to the U.S. Court of Appeals for the First Circuit by June 22, 2026.
⚠️ Legal ruling: The policies were deemed unlawful, but the case remains fluid because appellate review and emergency stay requests may change how fast USCIS processes affected cases.
The hold reached well beyond one form type. It covered adjustment of status cases under Form I-485, employment authorization requests under Form I-765, and asylum cases, with related travel issues affecting some applicants using Form I-131.
| Policy | Effective date | Affected benefits | Affected nationalities |
|---|---|---|---|
| PM-602-0192 | December 2, 2025 | I-485, I-765, asylum-related adjudications | Nationals of 39 countries, including Nigeria, Afghanistan, Iran, and Venezuela |
| PM-602-0194 | January 1, 2026 | I-485, I-765, asylum-related adjudications | Nationals of 39 countries, including Nigeria, Afghanistan, Iran, and Venezuela |
| Policy Alert PA 2025-26 | Late 2025 | Related screening and re-review measures | Nationals of 39 countries |
Nigerian applicants bore a heavy share of the disruption. The litigation says tens of thousands were delayed for more than six months, leaving green card and work permit cases stalled.
Even with formal holds lifted, the language in Alfonso-Royals’ declaration may shape adjudications. Nigerian applicants may face sharper review of birth, marriage, and divorce records, especially where local registries are incomplete.
That scrutiny typically appears through Requests for Evidence, known as RFEs. Cases involving civil documents may draw follow-up demands for secondary evidence, translation issues, or proof tied to identity and family history.
USCIS has long had authority to question document authenticity in individual cases. The dispute in Rhode Island turned on whether the agency could impose a blanket hold across nationalities and reopen already approved benefits on a mass basis.
The court said no. McConnell’s order treated the policy as an executive overreach that bypassed normal statutory limits on how USCIS adjudicates applications and how it revisits earlier approvals.
✅ For Nigerian applicants: Monitor updates from uscis.gov, the First Circuit docket, and the Rhode Island case record. As processing resumes, applicants may want to gather civil records, prior submissions, and possible secondary evidence in case an RFE arrives.
Official records anchoring the dispute include the USCIS Policy Manual, the USCIS Newsroom statement dated June 12, 2026, the White House proclamations, and the Rhode Island court filings. Those documents show both the agency’s national security rationale and the court’s rejection of the hold.
The case also shows how quickly processing rules can shift during litigation. A pending appeal does not erase the district court’s order, but an emergency stay, if granted, may alter how USCIS handles affected cases while the First Circuit reviews the dispute.
This article discusses ongoing litigation and government actions related to national security and immigration policy; readers should understand that policy and legal outcomes can change with new court decisions.
Legal analysis is informational and not a substitute for lawyer advice.
