US appeals court blocks Trump immigration enforcement near some houses of worship

The 4th U.S. Circuit Court of Appeals has upheld a preliminary injunction blocking the Trump administration's 2025 immigration enforcement policy at specific Quaker, Sikh, and Baptist houses of worship. The unanimous panel ruled that the policy, which replaced Biden-era protections with officer discretion, likely violates the Religious Freedom Restoration Act by chilling attendance and burdening religious practice. The ruling is narrowly tailored to the plaintiffs, contrasting with a D.C. court decision that rejected a similar challenge.

4th Circuit immigration ruling

• ▪The 4th Circuit's ruling is narrowly tailored to apply only to the eight plaintiff houses of worship affiliated with Quaker, Sikh, and Cooperative Baptist Fellowship traditions.
• ▪The 4th Circuit panel consisted of Judge Barbara Milano Keenan and Judge Pamela Harris, both appointed by President Barack Obama, and Judge G. Steven Agee, appointed by President George W. Bush.
• ▪A three-judge panel of the U.S. Court of Appeals for the 4th Circuit unanimously upheld a preliminary injunction blocking the Trump administration's 2025 immigration enforcement policy at specific houses of worship.

Trump 2025 policy change

• ▪The Trump administration's 2025 policy directed immigration officers to use their discretion and a "healthy dose of common sense" when deciding whether to conduct enforcement actions in sensitive locations.
• ▪In January 2025, the Trump administration rescinded a 2021 Biden-era policy that restricted immigration enforcement actions in protected areas like places of worship, schools, and hospitals.
• ▪A Department of Homeland Security spokesperson stated in January 2025 that under the new policy, criminals would no longer be able to hide in America's schools and churches to avoid arrest.

Religious Freedom Restoration Act

• ▪The 4th Circuit panel ruled that the Department of Homeland Security's policy likely violates the Religious Freedom Restoration Act by substantially burdening the plaintiffs' free exercise of religion.
• ▪The Department of Homeland Security waived its defense under the Religious Freedom Restoration Act by failing to argue or present evidence that its policy served a compelling interest through the least restrictive means.
• ▪Judge G. Steven Agee characterized the Department of Homeland Security's failure to present its statutory defense to the district court as an "inexplicable failure."

Worship attendance decline

• ▪The plaintiffs in the lawsuit include the Cooperative Baptist Fellowship, which serves 750,000 Baptists; the Gurdwara Sahib West Sacramento, serving 30,000 Sikhs; and six Quaker Meetings.
• ▪The plaintiff houses of worship presented evidence that the 2025 policy caused a decline in attendance among immigrant worshipers, including a 66% drop in English-as-a-second-language classes at one Baptist congregation.

Contrasting D.C. court ruling

• ▪Judge Dabney Friedrich ruled that the Washington, D.C. plaintiffs lacked standing because they failed to show houses of worship were being singled out, attributing attendance drops to broader neighborhood enforcement.
• ▪In April 2025, U.S. District Judge Dabney Friedrich denied a preliminary injunction against the same Department of Homeland Security policy in a separate lawsuit brought by 27 Christian and Jewish organizations.

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