USCIS Policy Watch
USCIS Froze Green Card Decisions for Dozens of Designated Countries. A Federal Court Just Pushed Back.
Policy Memo PM-602-0194, effective January 1, 2026, placed adjudicative holds on all pending immigration benefits for nationals of dozens of designated countries — green cards, EADs, naturalization, adjustment of status. On April 27, a Maryland federal judge issued a preliminary injunction requiring USCIS to resume processing for 83 named applicants. Here is what the holds actually do, who they hit, and what the court ruling does and does not change.
What USCIS did starting January 1
On December 2, 2025, USCIS issued Policy Memo PM-602-0192, placing adjudicative holds on all pending immigration benefit applications for nationals from countries designated as high-risk under Presidential Proclamations 10949 and 10998. Then on January 1, 2026, PM-602-0194 expanded the same hold framework to 39 additional countries. The two memos together are what most immigration practitioners and forums have been calling the processing pause — though USCIS would push back on that framing.
The memos were not issued through notice-and-comment rulemaking. They were internal policy directives implementing the administration's enhanced screening and vetting priorities. From a legal standpoint, that procedural choice is one of the grounds a federal judge found legally vulnerable on April 27. From an operational standpoint, the memos took effect immediately and applied to thousands of applications already sitting in the pipeline.
USCIS cited Presidential Proclamations issued under section 212(f) of the Immigration and Nationality Act as the authority for the holds. The proclamations designated specific countries as presenting elevated national security concerns. The memos converted that executive authority into instructions for adjudicators: hold final decisions.
Which cases are frozen, and who is affected
The holds cover virtually every final immigration benefit decision. I-485 adjustment of status — the in-country green card application — is covered. So is naturalization, employment authorization (EAD), advance parole, I-130 family petitions, and I-140 employment petitions. The relevant criterion is nationality — the country whose passport the applicant holds — not their current immigration status or country of residence.
For employment-based applicants, the problem is specific. An applicant who filed I-485, paid the filing fee, completed biometrics, and waited through a multi-month processing queue can find their case stopped at the final approval step because of their nationality or the nationality of a derivative beneficiary. Cases where a spouse or child holds nationality from a designated country have been caught in the hold even when the primary applicant does not.
The full designated country list is tied to the two presidential proclamations and the memos. Countries mentioned explicitly in the Maryland court filings from April 27 include Iran, Syria, and Venezuela. The list has changed over time as the administration updated its country designations — meaning applicants who were not originally subject to a hold could become subject to one as the list evolved.
Processing can happen. Final decisions cannot.
USCIS was explicit in PM-602-0194 that the hold is on final adjudications, not on processing activity itself. Cases subject to the hold can still advance through many steps: biometrics can be scheduled and completed, background checks can proceed, Requests for Evidence can be issued and answered, and interviews can be conducted at field offices. What the hold prevents is a final approval, denial, or dismissal.
From the applicant's side, the distinction is hard to feel. A case might have had its biometrics collected, its RFEs answered, and its interview completed — and then it just stops. No approval notice comes. From every angle that involves sending documents to USCIS, the case looks finished, and the last step doesn't happen. This is qualitatively different from a standard processing backlog delay, and it requires a different response.
Several immigration law firms have been filing federal lawsuits rather than submitting normal service request inquiries, precisely because service requests do not work for a hold that is deliberately stopping final decisions. The April 27 Maryland ruling arose from a direct legal challenge to the memos themselves, which is a different but related approach.
The re-review of past approvals
PM-602-0194 does not only affect pending cases. The memo also subjects previously approved immigration benefits to comprehensive re-review, covering any benefit approved on or after January 20, 2021, for nationals of designated countries. The stated grounds for re-review are national security risks, identity concerns, or other eligibility issues USCIS believes warrant a second look.
The practical scope of this provision has not been publicly clarified. USCIS has not published data on how many re-review proceedings have been initiated under PM-602-0194, how many have resulted in rescission, or what internal standards apply. Immigration attorneys who have submitted FOIA requests seeking this information have received partial or delayed responses.
What this means practically is that an approved green card or work authorization from 2022 or 2023 is not necessarily final for a national of a designated country. The authority to re-examine it exists under the memo. Whether USCIS is actively exercising that authority at scale is unclear. People in this situation should know the provision exists even without specific USCIS action on their file.
What happened in Maryland on April 27
On April 27, 2026, Chief Judge George Russell III of the U.S. District Court for the District of Maryland issued a preliminary injunction in a case challenging PM-602-0192 and PM-602-0194. The 83 named plaintiffs were nationals from designated countries including Iran, Syria, and Venezuela, all with immigration benefit applications stalled under the holds. The court blocked USCIS Director Joseph B. Edlow from enforcing the two memos against those specific plaintiffs.
Judge Russell applied the standard four-part preliminary injunction test. He found the plaintiffs were likely to succeed on the merits, meaning the memos were legally vulnerable to the claims being made. He found they would likely suffer irreparable harm without the injunction: ongoing uncertainty about employment authorization, family separation risk, and exposure to status lapse if processing continued to stall. He found the public interest was served by the injunction.
The court declined to require USCIS to process all 83 applications within 30 days, as the plaintiffs had requested. The cases were at too many different stages — some had completed biometrics and were essentially awaiting a final review, while others had been filed more recently and had more processing steps ahead. A single blanket deadline would not have been workable.
What the court order doesn't fix
The April 27 ruling applies only to the 83 named plaintiffs. It is not a nationwide injunction. USCIS is not required by this order to process any other application from a national of a designated country. If you hold nationality from one of the affected countries and have a pending I-485 or other benefit application, but you are not one of those 83 plaintiffs, this order changes nothing about your case.
The injunction is preliminary, not final. It reflects the court's current assessment that the plaintiffs are likely to succeed — not a final determination that the memos are invalid. The Trump administration will almost certainly appeal. It may seek a stay of the injunction during the appeal, which would suspend the order's effect while litigation continues. Similar preliminary immigration injunctions from Maryland courts have faced aggressive DOJ countermoves in prior months.
What the ruling does do is place the memos in direct legal jeopardy. A federal district judge found on the record that PM-602-0192 and PM-602-0194 are likely unlawfully implemented. That is not a casual observation. It contributes to the litigation landscape for anyone thinking about challenging their own processing hold through federal court.
The national interest exception, described plainly
PM-602-0194 includes a national interest exception. The memo says it is available where an applicant's entry or continued presence would provide significant benefit to the United States. The examples given are a scientist working on a critical public health project, an engineer with specialized skills needed for key infrastructure, and someone with unique expertise supporting national security or economic interests.
The exception requires headquarters-level approval within USCIS, not a service center determination. Requests must be elevated above normal adjudication channels. How many exceptions have been approved since January 1 is not publicly known. Immigration attorneys who have submitted exception requests report limited transparency from USCIS about timelines and decision criteria.
The exception is not available simply because an employer considers an employee valuable. Most H-1B workers are valuable to their employers — that is not the standard. The memo asks whether the person's work is of unique significance to something larger than an individual employer's interests. That bar is meaningfully high, and it deserves an honest assessment before any attorney time is spent drafting a request.
What to actually do if your case is in this situation
The first step is confirming whether your case is actually subject to a PM-602-0194 hold. Not every applicant from a designated country is necessarily frozen. Some cases were approaching final adjudication when the memos took effect and may have been resolved before the holds propagated fully. Some benefit types are processed through different channels. Your immigration attorney should be able to tell you directly whether your case is subject to a hold and what it means for your timeline.
If your case is employment-based adjustment and you are currently authorized to work on H-1B or another nonimmigrant status, the hold on your I-485 does not by itself affect your current work authorization. Your legal right to work continues under your existing status. The hold delays the final green card approval, not your current employment authorization. That distinction matters if you are tracking when H-1B extensions are needed versus how close the I-485 is to final.
Federal mandamus litigation and direct legal challenges to the memos are both tools immigration attorneys are currently using for affected clients. They are legally different approaches with different requirements and different prospects. An attorney who handles federal court immigration cases can evaluate which fits your situation. This article is informational only and does not constitute legal advice. If your case may be affected by PM-602-0194, consult a licensed immigration attorney.