June 08, 2026
In the current climate of frequent immigration policy changes and heightened scrutiny, we want to highlight a significant and favorable judicial development affecting USCIS adjudication practices.
In Dorcas v. USCIS, decided by the United States District Court for the District of Rhode Island on Friday, June 5, 2026, the court ruled that several USCIS policies that effectively paused the adjudication of certain immigration benefits are unlawful. Specifically, the court vacated the following policies:
- Benefits Hold Policy
- Global Asylum Hold Policy
- Comprehensive Re-Review Policy
- Country-Specific Factors Policy
Because the court vacated these policies in their entirety, the ruling may have nationwide implications, rather than being limited to Rhode Island. However, as this decision was issued at the district court level, it is likely to be appealed to the U.S. Court of Appeals for the First Circuit. At the time of this publication, the government has not yet formally responded to the ruling.
Notably, the court issued a strong rebuke of USCIS’s actions, stating that the agency “has neither followed the law nor done things the right way.” The court found that USCIS:
- Claimed statutory and regulatory authority it does not possess
- Failed to provide required reasoned explanations for its decisions
- Disregarded the reliance interests of applicants
- Relied on pretextual national security concerns that improperly masked prohibited considerations
Key Findings
The court made several critical determinations:
- Violation of the Administrative Procedure Act (APA): The policies were deemed contrary to law, arbitrary and capricious, and unsupported by adequate reasoning.
- Improper National Security Justifications: USCIS’s reliance on national security concerns was found to be insufficient and pretextual.
- Discriminatory Impact: The policies involved nationality-based decision-making that conflicts with statutory prohibitions on such discrimination.
- Lack of Legal Authority: USCIS cannot impose broad, indefinite pauses on adjudicating immigration benefits without clear statutory authorization.
The decision reinforces that federal immigration agencies must operate within the bounds of governing statutes and regulations, provide reasoned decision-making, and avoid discriminatory practices.
What This Means for Applicants
At present, this ruling does not result in immediate procedural changes. However, if upheld, it could have substantial long-term implications:
- Thousands of delayed applications—including asylum and permanent residence cases—may resume processing rather than remaining in indefinite limbo
- The government’s ability to impose sweeping adjudication pauses based on policy preferences or nationality-related concerns may be significantly curtailed
- The decision strengthens accountability requirements for USCIS in future policymaking and adjudication practices
We will continue to monitor developments closely, particularly any appeal or implementation guidance issued by USCIS or the Department of Justice.
If you have questions about how this decision may affect your case or your organization, please contact our office for guidance.