Federal Court Strikes Down USCIS Benefits Freeze for Nationals of 39 Countries in Dorcas v USCIS: What the Dorcas Decision Means for Applicants

On June 5, 2026, in Dorcas International Institute of Rhode Island v. USCIS, a federal district court in Rhode Island issued one of the most consequential immigration rulings of the year, declaring unlawful and vacating four USCIS policies that had placed the immigration cases of hundreds of thousands of people from 39 countries in indefinite limbo. The decision is effective nationwide. If you or a family member has had an immigration application frozen since late 2025, this ruling directly affects you.

Background: How We Got Here

In June 2025, the President issued Presidential Proclamation 10949, implementing a new travel ban restricting entry of nationals from 19 countries identified as posing screening and vetting concerns. A second proclamation, issued in December 2025, expanded that list to 39 countries spanning Africa, Asia, Latin America, and the Middle East.

Following a terrorist attack plot in 2024 and a shooting incident in Washington, D.C. in November 2025, USCIS issued a series of internal policy memoranda that went well beyond restricting entry at the border. The agency directed its officers to take the following sweeping actions:

• Benefits Hold Policy: USCIS placed an indefinite hold on all pending immigration benefit requests, including green card applications, work permit renewals, and naturalization petitions, filed by nationals of the 39 designated countries.
• Global Asylum Hold Policy: USCIS suspended adjudications of all asylum and withholding of removal applications, regardless of the applicant’s country of origin. Every asylum applicant in the country, from any nationality, was affected.
• Comprehensive Re-Review Policy: USCIS directed officers to re-open and reconsider previously approved immigration benefits for nationals of the 39 countries who had entered the United States on or after January 20, 2021, even where those benefits had already been fully adjudicated and granted.
• Country-Specific Factors Policy: USCIS updated its Policy Manual to instruct adjudicators to treat an applicant’s country of origin, specifically if that country appeared on the travel ban list, as a significant negative factor in all discretionary benefit adjudications.

The result was that individuals from these 39 countries who had done everything right, filed their applications, paid their fees, submitted biometrics, and attended interviews, were categorically blocked from receiving final decisions on their cases. Not because of anything they had done, but because of where they were born.

The Lawsuit and the Court’s Ruling

A coalition of nonprofit organizations and labor unions filed suit in the U.S. District Court for the District of Rhode Island, challenging all four policies under the Administrative Procedure Act (APA) and the Fifth Amendment. The plaintiffs included Dorcas International Institute of Rhode Island, the Refugee Dream Center, the Service Employees International Union (SEIU), the United Auto Workers (UAW), and several other immigrant advocacy organizations collectively representing thousands of affected applicants.

On June 5, 2026, Chief Judge John J. McConnell, Jr. issued a 135-page opinion granting summary judgment to the plaintiffs on all of their APA claims. The court declared each of the four challenged policies unlawful and vacated them in their entirety. The ruling is nationwide in scope.

Why the Court Ruled Against USCIS

The court found the USCIS policies unlawful on three independent grounds, each of which alone would have been sufficient to vacate the policies.

First, contrary to law. The court held that USCIS simply did not have the legal authority to implement these policies. The agency relied on INA Section 212(f), the provision that gives the President authority to restrict entry of certain noncitizens for national security reasons. But the court found that this provision authorizes entry restrictions at the border, and does not empower USCIS to unilaterally freeze the domestic adjudication of immigration benefits for people already lawfully present in the United States. Congress set specific statutory timelines and procedures for adjudicating immigration benefits, and USCIS cannot override those through internal memoranda.

Second, arbitrary and capricious. Even if USCIS had possessed the legal authority to act, the court found that the agency failed to provide a reasoned explanation for its policies, ignored the substantial reliance interests of the hundreds of thousands of applicants who had built their lives, jobs, and family plans around pending applications, and acted in a manner inconsistent with its own stated rationale.

Third, and most striking, pretextual. The court found that the national security justification offered by USCIS was not the real reason for the policies. The opinion pointed to a damning inconsistency: at the same time USCIS claimed these 39 countries posed such serious security threats that all benefit adjudications had to be frozen, the agency quietly carved out exceptions for athletes competing in the 2026 World Cup and the 2028 Summer Olympics, as well as medical physicians. The court wrote that a security risk that evaporates when an applicant can help win a soccer match, or treat patients, is not a genuine security rationale. Combined with public statements by the President and former DHS Secretary Kristi Noem expressing hostility toward immigrants from these countries in terms that went far beyond security concerns, the court concluded the policies were issued based on impermissible anti-immigrant sentiment, not legitimate national security grounds.

What the Court Did and Did Not Do

It is important to understand precisely what this ruling covers and what it does not.

• The court vacated all four challenged USCIS policies. The Benefits Hold Policy, Global Asylum Hold Policy, Comprehensive Re-Review Policy, and Country-Specific Factors Policy are declared unlawful and set aside. USCIS is no longer authorized to enforce them.
• The ruling is nationwide. Unlike some earlier preliminary injunction decisions in other districts that were limited to the named plaintiffs, vacatur voids the policies themselves. The relief extends to all affected applicants across the country.
• The travel ban itself was not struck down. The court was careful to distinguish between the presidential travel ban proclamations, which restrict entry at the border, and the USCIS policies that improperly extended those restrictions into the domestic adjudications process. The travel ban remains in effect. What has been struck down is USCIS’s attempt to use the travel ban as authority to freeze benefit adjudications inside the United States.
• No permanent injunction was issued. The court declined to enter a permanent injunction, finding that vacatur of the policies provided complete relief. If the government attempts to reissue similar policies under a different name, affected parties can return to court.
• Constitutional claims were not decided. Plaintiffs also brought Fifth Amendment due process and equal protection claims. The court declined to rule on those claims, applying the doctrine of constitutional avoidance, because the APA ruling provided full relief.

What This Means for Affected Applicants

If you are a national of one of the 39 designated countries and have had a pending immigration application frozen since late 2025, the policies that were blocking your case have now been declared unlawful. In theory, USCIS should resume processing affected applications. In practice, there are several important caveats.

Government agencies do not always act immediately following adverse court rulings. USCIS may comply gradually, seek a stay of the order pending appeal, or take other administrative steps that delay implementation. Applicants should not expect their cases to resolve overnight.

The 39 countries covered by the ruling include Afghanistan, Angola, Antigua and Barbuda, Benin, Burkina Faso, Burma, Burundi, Chad, Cote d’Ivoire, Cuba, Dominica, Equatorial Guinea, Eritrea, The Gambia, Gabon, Haiti, Iran, Laos, Libya, Malawi, Mali, Mauritania, Niger, Nigeria, Republic of the Congo, Senegal, Sierra Leone, Somalia, South Sudan, Sudan, Syria, Tanzania, Togo, Tonga, Turkmenistan, Venezuela, Yemen, Zambia, and Zimbabwe, as well as individuals holding Palestinian Authority travel documents.

Affected applicants with pending green card, work permit, asylum, or naturalization applications should contact an experienced immigration attorney to understand how this ruling applies to their specific case and what steps to take now.

An Appeal Is Likely

The government is widely expected to appeal this ruling to the U.S. Court of Appeals for the First Circuit. The administration has consistently and aggressively appealed adverse immigration decisions in lower courts, and this ruling, given its scope and the directness of the court’s pretext finding, is virtually certain to be contested.

The government may also seek a stay of the order pending appeal, which would suspend the ruling’s effect while the appeal is litigated. Whether a stay is granted will depend on the First Circuit’s assessment of the government’s likelihood of success on appeal, among other factors. Given the strength and scope of the district court’s opinion, a stay is far from guaranteed, but it cannot be ruled out.

Separately, the government could attempt to reissue revised policies that address the procedural and substantive deficiencies identified by the court. The opinion left open the possibility that USCIS could implement more targeted, properly justified policies built on a stronger administrative record, though the pretext finding will make that a difficult path.

The bottom line: this ruling is an important and immediate victory for affected applicants, but it is not necessarily the final word. The legal landscape surrounding these policies will continue to evolve, and affected individuals should monitor developments closely with the help of counsel.

A Note on What This Case Represents

The court’s opinion opens with a pointed observation. The individuals affected by these policies had, in the court’s words, followed the law and done things the right way. They filed the correct forms, paid the required fees, submitted to biometric collection, and attended interviews. They did everything the legal immigration system asked of them. What they could not control was their country of birth.

The court’s ruling affirms a principle that sits at the foundation of administrative law: that government agencies must follow the rules that Congress made, provide genuine reasons for their actions, and treat the people they regulate with the consistency and fairness the law requires. That principle, the court held, applies to immigration agencies just as it applies to any other.

Is Your Case Affected? Contact Us.

Parandian Law represents individuals and families in all areas of U.S. immigration law, including green card applications, asylum, employment authorization, naturalization, and cases affected by travel ban policies. We are monitoring the Dorcas decision and its aftermath closely and advising clients on how to respond.

If you have a pending immigration case that has been stalled due to a USCIS hold, or if you have questions about how this ruling may affect your situation, contact us to schedule a consultation.

If you have questions about how these developments affect your specific situation, contact our White Plains office at (914) 793-2626 or click the link below for a consultation.