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Keywords

plaintiffdefendantprecedentinjunctionmotionnonprofitcitizenship

plaintiffdefendantinjunctionmotioncitizenship

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Doe v. Trump

Facts

The case arose from an executive order titled 'Protecting the Meaning and Value of American Citizenship' issued by President Trump on January 20, 2025. This order identified two categories of individuals born in the U.S. who would not automatically receive citizenship and directed federal agencies to stop recognizing citizenship for these individuals born after February 19, 2025. The plaintiffs, including an expectant mother and two nonprofit organizations, argued that the order would cause irreparable harm to them and their members, who would be treated as noncitizens.

The EO, however, does not directly concern immigration; rather, it seeks to define the scope of birthright citizenship in the United States.

Issue

The main legal issue was whether the executive order issued by President Trump, which sought to limit birthright citizenship, violated the Citizenship Clause of the Fourteenth Amendment and other constitutional provisions.

The EO identifies two 'categories of individuals born in the United States' to whom the EO says 'the privilege of United States citizenship does not automatically extend,' then directs federal departments and agencies to cease issuing or accepting 'documents recognizing United States citizenship' for such individuals born after February 19, 2025.

Rule

The court applied the established interpretation of the Citizenship Clause, which recognizes birthright citizenship for individuals born in the U.S., regardless of their parents' immigration status, as reaffirmed by Supreme Court precedent.

The plaintiffs are also likely to succeed on the merits of their claims. In a lengthy 1898 decision, the Supreme Court examined the Citizenship Clause, adopting the interpretation the plaintiffs advance and rejecting the interpretation expressed in the EO.

Analysis

The court found that the plaintiffs were likely to succeed on the merits of their claims based on settled Supreme Court precedent regarding the Citizenship Clause. The court rejected the defendants' arguments that citizenship depended on the status of the parents and emphasized that the Citizenship Clause does not impose a domicile requirement. The plaintiffs demonstrated that they would suffer irreparable harm if the executive order were implemented, while the defendants would not face any harm from the injunction.

The plaintiffs have also satisfied the other preliminary-injunction factors. Each plaintiff faces irreparable harm, the defendants face none, and the public interest favors enjoining the EO.

Conclusion

The court granted the plaintiffs' motions for a preliminary injunction, preventing the implementation of the executive order, as the plaintiffs were likely to succeed on the merits and faced irreparable harm.

Accordingly, the plaintiffs in each case are entitled to an injunction preventing implementation of the EO.

Who won?

The plaintiffs prevailed in the case because the court found that they were likely to succeed on the merits of their claims and would suffer irreparable harm if the executive order were enforced.

For these reasons, the plaintiffs' motions are ALLOWED.

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