The April Court Win Helped 83 People. The June 5 Ruling Helps Everyone.

What the Rhode Island court did on June 5

On June 5, 2026, Chief Judge John J. McConnell Jr. of the U.S. District Court for the District of Rhode Island issued a ruling in Dorcas International Institute of Rhode Island v. USCIS, No. 1:26-cv-00132. The plaintiffs were a coalition of nonprofits and unions — Dorcas International Institute, SEIU, UAW, African Communities Together, the Venezuelan Association of Massachusetts, and several others — representing thousands of people whose immigration benefit applications had been frozen since late 2025 based solely on their country of birth.

Judge McConnell declared all four challenged USCIS policies unlawful under the Immigration and Nationality Act and the Administrative Procedure Act, and vacated them. The operative word is vacatur. He did not issue a preliminary injunction blocking enforcement against specific named plaintiffs. He declared the policies themselves invalid — meaning they no longer have legal effect as a matter of general law.

The benefits freeze had been accumulating since December 2, 2025, when USCIS issued Policy Memo PM-602-0192 placing adjudicative holds on pending benefit applications for nationals of certain designated countries. A January 1, 2026 expansion through PM-602-0194 extended the same framework to 39 countries total. Thousands of people with pending I-485s, EAD renewals, naturalization applications, and other USCIS filings watched their cases stop moving — not denied, not explained, just stopped. As of June 5, that framework has no valid legal basis.

The four policies that got thrown out

The ruling addresses four separate USCIS policies that together constructed what practitioners have been calling the adjudication freeze.

The Benefits Hold Policy, through Policy Memos PM-602-0192 and PM-602-0194, placed final-adjudication holds on every category of pending immigration benefit for nationals of the 39 countries: I-485 adjustment of status, EAD work permits, advance parole, I-130 family petitions, I-140 employment petitions, and naturalization N-400. USCIS could keep collecting documents, scheduling interviews, and issuing RFEs — but it could not issue any final approval, denial, or dismissal. Cases that were otherwise fully ready for a decision did not get one.

The Global Asylum Hold Policy halted processing of all asylum claims across the board, not just for the 39-country nationals, affecting applicants already deep in the asylum pipeline. The Comprehensive Re-Review Policy required USCIS to reopen any immigration benefit approved on or after January 20, 2021, for nationals of designated countries — meaning a green card approved in 2022 or an EAD from 2023 was eligible for re-examination. USCIS never publicly disclosed how many such reviews it initiated or what outcomes they produced.

The Country-Specific Factors Policy directed adjudicators to treat an applicant's country of origin — being from a travel ban country — as a significant negative discretionary factor when evaluating benefit requests. With the May 21 AOS discretion memo already raising the bar on I-485 approvals generally, this added a compounding layer specifically targeting people from these countries. The court found all four policies unlawful. Not poorly implemented — unlawful.

The 39 countries, spelled out

The affected countries come from Presidential Proclamations 10949 and 10998, issued in late 2025, which divide into two tiers based on the severity of restriction.

The full-restriction tier covers 19 countries: Afghanistan, Burkina Faso, Burma, Chad, Republic of the Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Laos, Libya, Mali, Niger, Sierra Leone, Somalia, South Sudan, Sudan, Syria, and Yemen. The partial-restriction tier covers 20 more: Angola, Antigua and Barbuda, Benin, Burundi, Côte d'Ivoire, Cuba, Dominica, Gabon, The Gambia, Malawi, Mauritania, Nigeria, Senegal, Tanzania, Togo, Tonga, Venezuela, Zambia, Zimbabwe, and Turkmenistan.

For USCIS purposes, the trigger has always been nationality — meaning the passport you hold — not your current visa category, your employer, or how long you have been in the United States. An Iranian national on a valid H-1B with a pending I-485 was subject to the hold. A Nigerian national waiting on an EAD renewal was subject to the hold. A Venezuelan national with a naturalization application in the queue was subject to the hold. Being lawfully present under a valid visa did not exempt anyone. The country printed on your passport was what USCIS used to decide whether your case got a final decision.

Why this is different from the April ruling

On April 27, 2026, a federal court in Maryland issued a preliminary injunction blocking enforcement of PM-602-0192 and PM-602-0194 against the 83 named plaintiffs in that case. Only those 83. Every other person from the 39 countries whose case was frozen remained frozen. The Maryland court explicitly declined to issue nationwide relief.

The June 5 Rhode Island ruling is a different legal result. A preliminary injunction stops enforcement against specific parties while litigation continues. Vacatur declares the policy itself unlawful and sets it aside as a general matter. The policies no longer exist as valid legal instruments. USCIS cannot look at a non-plaintiff applicant and say this ruling does not apply to you — the policies USCIS was relying on are no longer valid policies.

That is why the relief here is nationwide. Not because the court granted nationwide relief as a discretionary choice, but because vacatur operates against the invalid policy itself, not against the government's enforcement power against specific individuals. Every case that was being held under those four policies is now being held under policies a federal court has declared unlawful.

The travel ban is still running. The adjudication freeze is not.

This distinction will cause confusion, and it is worth being direct about it. Judge McConnell did not vacate Presidential Proclamations 10949 or 10998. The travel bans those proclamations created are still in effect. If you are a national of one of the 39 countries and you are outside the United States, the entry restrictions and visa limitations those proclamations impose are still in place. Consular processing at U.S. embassies and consulates reflects the proclamations and has not changed.

What the court struck down is what USCIS did with those proclamations internally. The administration took the travel ban framework — designed to govern who can enter the United States — and extended it to govern how USCIS processed applications from people already inside the country with filings already pending. Judge McConnell found that USCIS could not implement that extension without going through notice-and-comment rulemaking under the APA. The holds were rules with legal effect on individual rights, issued as internal memos without public notice or comment. That procedural shortcut is the core of what the court found unlawful.

The practical consequence: entering the country is still governed by the travel bans. Getting a pending USCIS application decided — for someone already here — is no longer governed by the holds. Those are two separate questions, and the court's ruling speaks only to the second.

What the government does next

The government will appeal to the First Circuit Court of Appeals. That is certain. An appeal does not automatically suspend the district court's ruling. To pause the effect of the vacatur while the appeal proceeds, the government must separately file a motion for a stay — either from the district court or from the First Circuit.

If a stay is granted, the four policies effectively resume and USCIS goes back to holding final adjudications for the 39-country applicants. If a stay is denied, USCIS must operate as if the vacatur is in effect and cannot apply those policies to any applicant. The government obtained emergency stays in some immigration cases in 2025 and 2026 and was denied in others. The First Circuit's posture on the current administration's immigration enforcement actions has not been uniformly favorable to the government, but predicting any individual ruling is not something anyone can do with confidence.

Until the First Circuit acts on a stay request — which could take days or weeks — the default posture is that the vacatur stands. For applicants whose cases were frozen, this is the window. Stay motions in high-profile immigration cases have moved quickly in recent months. Do not assume the window is permanent.

What to do now if your case was frozen

If you are a national of one of the 39 designated countries and have a pending USCIS benefit application — I-485, EAD, naturalization, I-130, I-140 — contact your immigration attorney immediately. The June 5 ruling changed the legal landscape directly relevant to your case, and your attorney needs to know about it if they do not already.

Do not assume your case will be adjudicated within days. USCIS has not yet issued guidance on how it will resume processing cases held under the now-vacated policies, or in what sequence it will work through the backlog. The agency may comply slowly. Cases that were at final adjudication stage when the hold went into effect are in a different position from cases with more processing steps ahead. Your attorney can assess where your specific case stands and whether a service request or mandamus action — filing in federal court to compel USCIS to act — makes sense given the current posture.

Watch for an emergency stay motion from the government. If the First Circuit grants a stay, the holds resume. This ruling can be paused. Do not treat the current posture as the final state until the appeal is resolved.

This article is informational only and does not constitute legal advice. The ruling's effect on any specific case depends on nationality, the type of benefit application pending, how USCIS responds in practice, and whether the First Circuit issues a stay. Consult a licensed immigration attorney before making decisions based on this ruling.