Civil Procedure Symposium 139 Harv. L. Rev. 1791

Aggregation and the “Universal” Injunction


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Introduction

A crucial function of judicial review is not only “to say what the law is,”1 but also to provide the remedies to vindicate that law.2 Judicial review plays an especially important role when government officials act in ways that violate federal law, including when they violate the Constitution.3 When government officials violate the law, the judicial review function supports a remedy that requires officials to comply with federal law by ceasing to pursue the illegal policy or practice.

Such “compliance” injunctions have been given the label “universal” or “nationwide” injunctions insofar as they go beyond giving “complete relief to the plaintiffs before the court.”4 Among other things, this framing couches compliance injunctions as aggregation devices — as improper attempts to “create de facto class actions.”5 Although this characterization has never been entirely accurate,6 the majority in Trump v. CASA, Inc.7 embraced it and, as a result, narrowly construed the federal courts’ statutory authority to issue such injunctions in cases brought by individual plaintiffs.8 The CASA decision makes it imperative to reckon with “universal” injunctions through the lens of aggregation — specifically, through the lens of class actions under Rule 23 of the Federal Rules of Civil Procedure.9

In this Essay, we begin with a brief summary of the CASA decision’s holding regarding the availability of “universal” injunctions.10 Part II discusses the relationship between remedies and judicial review and the important role that such injunctions play in that regard. Part III explores how class actions could serve as an alternative path for federal courts, after engaging in judicial review, to make their decisions meaningful by requiring officials to comply with the law and to cease illegal actions or policies. We also respond to several objections to the use of class actions in this context. The final Part addresses some implications of the class action route to “universal” injunctions, identifying the core functional connection between class actions and such injunctions, but also acknowledging some of the problems that this class action route may pose.

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Footnotes
  1. ^ Marbury v. Madison, 5 U.S. (1 Cranch) 137, 177 (1803).

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  2. ^ Id. at 163 (“[I]t is a general and indisputable rule, that where there is a legal right, there is also a legal remedy by suit or action at law, whenever that right is invaded.” (quoting 3 William Blackstone, Commentaries *23)).

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  3. ^ E.g., United States v. Lee, 106 U.S. 196, 220–21 (1882).

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  4. ^ Trump v. CASA, Inc., 145 S. Ct. 2540, 2548 n.1, 2557 (2025).

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  5. ^ Id. at 2556 (quoting Smith v. Bayer Corp., 564 U.S. 299, 315 (2011) (emphasis omitted)). Professor Maureen Carroll describes individual plaintiff litigation to obtain compliance injunctions outside of class actions as “quasi-individual” actions. Maureen Carroll, Aggregation for Me, but Not for Thee: The Rise of Common Claims in Non-Class Litigation, 36 Cardozo L. Rev. 2017, 2020 (2015).

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  6. ^ See CASA, 145 S. Ct. at 2600 n.2 (Jackson, J., dissenting) (arguing that “the majority’s primary premise — that universal injunctions ‘grant relief to nonparties’ — is suspect” because “[w]hen a court issues an injunction (universal or otherwise), it does so via an order that governs the relationship between the plaintiff and the defendant”).

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  7. ^ 145 S. Ct. 2540 (2025).

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  8. ^ See supra notes 4–5 and infra notes 20–22 and accompanying text.

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  9. ^ See generally, e.g., David Marcus, The Class Action After Trump v. CASA, 73 UCLA L. Rev. Discourse 2 (2025) (discussing the role of class actions after the CASA decision). Class actions are not the only vehicle for obtaining compliance injunctions against governmental policies that violate federal law. See infra notes 24–29 and accompanying text (discussing how CASA did not rule out such relief either (a) in suits by individual, governmental, or associational plaintiffs in certain circumstances, or (b) when authorized by the vacatur provision of the Administrative Procedure Act).

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  10. ^ For an explanation of why we put “universal” injunctions in quotation marks, see Portia Pedro, Toward Establishing a Pre-Extinction Definition of “Nationwide Injunctions, 91 U. Colo. L. Rev. 847, 849–50 (2020).

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