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Casey Pitts struck down two Trump administration ICE enforcement policies Tuesday, ruling in a 71-page opinion that the agency and the Justice Department's Executive Office for Immigration Review failed to meet the reasoned-explanation standard required under the Administrative Procedure Act.
The decision vacates ICE's 2025 policy removing restrictions on civil immigration arrests at courthouses and a separate agency waiver extending permissible detention in short-term holding facilities from 12 hours to 72 hours.
Pitts, nominated by former President Joe Biden, found both policies "devoid of rational explanation." Vacatur, Not Injunction — a Procedural Distinction With Teeth The ruling is nationwide in effect but structured differently from the broad nationwide injunctions the Supreme Court invalidated in its 2025 decision in Trump v.
Rather than ordering the government not to enforce the policies, Pitts vacated them — removing the policies themselves under the APA. A vacatur eliminates the rule; an injunction merely blocks its application.
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