A U.S. appeals court on Tuesday upheld a lower court's preliminary injunction that restricts federal immigration enforcement at eight specific houses of worship. The 4th U.S. Circuit Court of Appeals ruled that the current administration's enforcement policy likely violates the Religious Freedom Restoration Act (RFRA) by potentially hindering religious activities at these locations.
The legal dispute began after the Trump administration rescinded a 2021 Biden-era policy that had designated places of worship, schools, and hospitals as "protected areas" where immigration arrests were generally avoided. In January 2025, the Department of Homeland Security (DHS) replaced that guidance with a directive for agents to use "common sense" and discretion. Eight houses of worship from Quaker, Sikh, and Cooperative Baptist Fellowship traditions subsequently sued, alleging the change chilled attendance and impeded their ministry to immigrant communities.
A three-judge panel composed of Judges Barbara Milano Keenan, Pamela Harris, and G. Steven Agee issued the Tuesday ruling. Judge Keenan noted that a January 2025 statement from a DHS spokesperson, which said individuals would "no longer be able to hide" in churches to avoid arrest, established a "real and substantial" threat of enforcement. DHS maintains that U.S. Immigration and Customs Enforcement (ICE) does not target places of worship but argued it must retain the ability to make arrests in cases involving public safety or "dangerous illegal alien felons."
The scale of the impact is currently limited to the eight named plaintiffs, though the case is part of a broader series of legal challenges filed by religious groups across the country. By upholding the injunction, the court sets a precedent for how the Religious Freedom Restoration Act may be used to challenge federal immigration priorities when they intersect with religious practice. The ruling does not extend to other "sensitive locations" previously covered under the 2021 policy, such as hospitals or shelters, meaning enforcement operations in those areas continue under the current "common sense" discretionary guidelines.
What happens next depends on whether the administration chooses to appeal the 4th Circuit's decision to the U.S. Supreme Court or proceed with a full trial on the merits of the case. While the appeals court affirmed the preliminary injunction based on the RFRA claims, it declined to rule on the plaintiffs' First Amendment arguments at this stage. The district court's order requiring DHS to adhere to the 2021 guidelines for these specific houses of worship remains in effect until the litigation is resolved.
Explainers: The Religious Freedom Restoration Act (RFRA) is a 1993 federal law that prohibits the government from substantially burdening a person's exercise of religion unless it is the least restrictive means of furthering a compelling government interest. The Department of Homeland Security (DHS) is the federal cabinet department responsible for public security, including U.S. Immigration and Customs Enforcement (ICE).