Federal Court Vacates USCIS Policies Pausing Immigration Benefits for Nationals of 39 Countries

On June 5, Chief Judge John J. McConnell, Jr. of the U.S. District Court for the District of Rhode Island issued a landmark ruling in Dorcas International Institute of Rhode Island, et al. v. USCIS, et al., declaring unlawful and vacating four USCIS policies that had placed indefinite holds on immigration benefit adjudications for nationals of 39 countries subject to the president's travel ban. The court granted summary judgment in favor of a coalition of nonprofit organizations and labor unions, finding that USCIS violated the Administrative Procedure Act ("APA") by exceeding its statutory authority and acting in an arbitrary and capricious manner.

Background: USCIS Travel Ban Policies and the 2025–2026 Immigration Benefit Adjudication Holds

In late 2025, USCIS issued a series of policy memoranda implementing sweeping changes to its adjudication processes. These memoranda established what the court has categorized as four distinct policies. The travel ban itself originated with Executive Order 14161, issued on Jan. 20, 2025, which directed cabinet officials to identify countries with deficient vetting and screening information. The president subsequently issued Presidential Proclamation No. 10949 in June 2025, restricting entry of nationals from 19 countries, and Presidential Proclamation No. 10998 in December 2025, expanding the Travel Ban to 39 countries.

Federal Court Vacates Four USCIS Immigration Benefit Adjudication Policies

The court vacated all four USCIS policies in their entirety and issued a declaratory judgment finding them unlawful:

• The Global Asylum Hold Policy. USCIS halted all adjudications of asylum and withholding of removal applications, regardless of the applicant's country of origin. The court found this violated the INA's statutory mandate that asylum adjudications "shall be completed within 180 days after the date an application is filed" and USCIS's own regulation requiring that it "shall adjudicate the claim of each asylum applicant whose application is complete."
• The Benefits Hold Policy. USCIS placed a hold on all pending immigration benefit requests, including adjustment of status, employment authorization, extensions or changes of nonimmigrant status, advance parole renewals, and naturalization applications, for individuals from the 39 travel ban countries. The hold has impacted immigration filings for employees already working in valid status in the U.S. For example, employees in valid H-1B status have been unable to obtain timely work authorization for H-1B status extensions. The court concluded that "Congress has not empowered USCIS to categorically withhold adjudications of immigration benefits," noting that the relevant statutes and regulations impose mandatory adjudication duties on the agency.
• The Comprehensive Re-Review Policy. USCIS directed its personnel to conduct comprehensive re-reviews of all previously approved benefit requests for individuals from travel ban countries who entered the United States on or after Jan. 20, 2021. The court held that Congress prescribed specific individualized procedures for revoking or terminating benefits and that USCIS cannot circumvent those procedures through a wholesale re-review.
• The Country-Specific Factors Policy. USCIS amended its policy manual to direct adjudicators to treat "country-specific factors" from the travel ban, including a country's "insufficient vetting and screening information," as "significant negative” factors in discretionary benefit adjudications. The court found this policy violated the INA's anti-discrimination provision, 8 U.S.C. § 1152(a)(1)(A), which prohibits nationality-based discrimination in the immigrant visa process, including adjustment of status and employment authorization applications.

Employer and Immigration Compliance Implications Following the USCIS Travel Ban Ruling

This ruling has immediate and significant implications for employers and noncitizen employees from the 39travel ban countries:

• Resumption of adjudications. The vacatur means USCIS must resume processing and adjudicating the pending benefit applications that had been frozen under these policies. This includes applications for H-1B classification, employment authorization, adjustment of status, naturalization, and asylum. Employers with workers whose employment authorization documents expired during the hold period should be prepared for a potential surge in adjudication activity.
• Removal of negative country-of-origin factor. The Country-Specific Factors Policy, which directed adjudicators to treat an applicant's country of origin as a significant negative factor, has been vacated. This means applications for discretionary benefits should once again be adjudicated without the nationality-based penalty that the policy imposed.
• Potential for government appeal. Employers and individuals should be aware that the government may seek to appeal this ruling or pursue an emergency stay. However, absent a stay from a higher court, the vacatur is immediately effective. The court's decision aligns with rulings from at least eight other federal courts nationwide that reached similar conclusions on identical or nearly identical challenges.

This outcome is particularly welcome news for many healthcare institutions, particularly those hiring physicians to work in medically underserved areas, as many of these physicians are citizens of the thirty-nine affected countries.

Employers with affected workers should review their workforce to identify employees from the 39 travel ban countries whose benefit applications have been on hold and prepare to assist those employees in following up with USCIS on the status of their pending applications. Individuals with pending applications should consult with immigration counsel to confirm their applications are being processed in light of this ruling and to assess next steps.