Courts Block PM-602-0192 and PM-602-0194, Undermining Presidential Proclamation

A Rhode Island federal court vacated two USCIS processing memoranda, and a California court later issued a nationwide injunction against them, ending the agency’s authority to keep covered applications frozen under those policies.

The first ruling came in Dorcas International Institute of Rhode Island, et al. v. USCIS, et al., No. 26-cv-00132-JJM-PAS (D.R.I.). The U.S. District Court for the District of Rhode Island vacated the memoranda on June 5, 2026, then entered final judgment six days later.

The litigation did not end there. In Red Eagle Law, L.C., et al. v. Joseph B. Edlow, No. 26-cv-04850-CRB (N.D. Cal.), the U.S. District Court for the Northern District of California issued a nationwide order on August 24, 2026, blocking the same policies again.

The rulings addressed USCIS directives that paused and reviewed pending benefit applications connected to designated high-risk countries. The agency’s stated concerns included screening, vetting, national security, and public safety.

USCIS issued the holds months apart

USCIS dated PM-602-0192 December 2, 2025, and PM-602-0194 January 1, 2026. The agency linked the directives to Presidential Proclamation 10949 and Presidential Proclamation 10998.

The memoranda instructed officers to stop, and later examine, certain pending cases. Public reporting described coverage extending to asylum-related filings and other immigration benefits.

The affected paperwork included Form I-129, Form I-140, Form I-539, Form I-765, and Form I-131. Those categories include petitions, applications to change or extend status, employment authorization requests, and travel-document requests.

The policies therefore reached more than one type of immigration benefit. They operated across a range of cases tied to nationality or country designation.

Courts rejected blanket treatment of large applicant groups

The central challenge focused on how the holds operated. Rather than directing officers to decide cases individually, the memoranda imposed categorical pauses on broad groups of pending applications.

That structure exposed the policies to Administrative Procedure Act-style challenges and requests for equitable relief. Federal judges found the broad freezes unlawful enough to issue injunctions and, in Rhode Island, vacatur.

Vacatur set aside the challenged memoranda in the earlier case. The later California order separately enjoined their enforcement nationwide and certified a class of affected applicants.

The California class includes nationals of 39 countries

The class certified in Red Eagle covers citizens or nationals of the 39 countries listed in either proclamation. It also includes certain applicants connected to the Palestinian Authority.

The court’s order covers applicants whose USCIS benefits had been held and had not received final adjudication. The practical result returned those matters to ordinary agency processing.

Returning cases to the normal queue does not require USCIS to approve them. The agency may still request evidence, interview applicants, and decide the underlying merits under its ordinary authority.

That distinction preserves case-by-case review. It prevents the memoranda alone from keeping covered filings in indefinite administrative limbo.

As of August 30, 2026, the two directives are not being enforced as live adjudication-hold rules. Federal courts have both vacated and enjoined them, while routine USCIS adjudication powers remain in place.

This article provides general information and is not legal advice. Consult a qualified immigration attorney about your specific case.