A Federal Court Just Struck Down Four Unlawful USCIS Policies — And Your Frozen Case Could Finally Move
The Freeze Is Over: Why Waiting in Silence Was Never the Answer
For months — in many cases, for years — thousands of immigrants across the United States have been living in a state of legal paralysis. Green card applications sitting untouched. Employment Authorization Documents frozen mid-process. Naturalization applications stalled just steps from the finish line. Asylum cases left in indefinite suspension with no explanation and no end in sight.
You did everything right. You filed on time. You paid the fees. You submitted the documents. And still nothing.
What most applicants didn't know is that their cases weren't delayed because of a mistake in their file. They were deliberately frozen by a series of unlawful internal government policies that a federal court has now struck down entirely.
On June 5, 2026, Chief Judge John J. McConnell, Jr. of the U.S. District Court for the District of Rhode Island issued a landmark ruling in Dorcas International Institute of Rhode Island v. United States Citizenship and Immigration Services (USCIS). The Court found that USCIS had unlawfully implemented multiple immigration adjudication restrictions — and ordered the reversal of four agency policies that had been silently freezing cases nationwide.
What USCIS Was Doing Behind the Scenes
Following Presidential Proclamation Nos. 10949 and 10998, USCIS quietly rolled out a series of internal policies that put the brakes on immigration adjudications for thousands of people from dozens of countries.
The agency's stated justification? Two isolated domestic security incidents involving Afghan nationals.
The Court wasn't buying it. Judge McConnell found a substantial disconnect between those two incidents and the sweeping, blanket restrictions that USCIS imposed on applicants from 39 countries — the vast majority of whom had absolutely nothing to do with any security concern.
The Court concluded that USCIS exceeded its statutory authority and acted in an arbitrary and capricious manner by:
- Failing to provide a reasoned explanation for the policies;
- Ignoring the significant reliance interests of hundreds of thousands of affected applicants;
- Implementing sweeping restrictions without adequate factual support; and
- Relying on what the Court itself described as "contrived" national security justifications.
The result: a nationwide reversal of all four challenged policies. USCIS has since confirmed they are no longer in effect and must be treated as though they never existed.
The Four Policies That Were Struck Down
1. The Benefits Hold Policy (PM-602-0192)
This policy imposed an indefinite freeze on the final adjudication of immigration benefit applications for nationals of 39 designated "high-risk" countries. Under this hold, your case could not be approved, denied, or moved forward in any way.
Cases affected:
- Adjustment of Status (Form I-485)
- Employment Authorization Documents (Form I-765)
- Naturalization Applications (Form N-400)
- Other immigration benefit requests subject to the hold
Who was affected: Nationals of all 39 countries designated under the administration's expanded Travel Ban framework.
2. The Asylum Hold Policy
This policy suspended final adjudications of applications for Asylum, Statutory Withholding of Removal, and protection under the Convention Against Torture (CAT) — regardless of the applicant's nationality.
Unlike the Benefits Hold, this one didn't even limit itself to specific nationalities. Every asylum seeker in the pipeline was caught in its net.
3. The Comprehensive Re-Review Policy (PM-602-0194)
Perhaps the most aggressive of the four, this policy required USCIS to go back and conduct secondary vetting and retrospective reviews of immigration benefits that had already been approved — ripping open closed cases and subjecting people to re-examination without cause.
Cases targeted for re-review:
- Asylum grants
- Permanent residence approvals
- Employment authorization documents
- Naturalization approvals
Who was targeted: Individuals from the 39 designated countries who entered the United States
on or after January 20, 2021.
4. The Country-Specific Factors Policy (PA-2025-26)
This policy amended the USCIS Policy Manual to instruct adjudicators to treat an applicant's nationality—or their country's perceived vetting infrastructure—as a heavily weighted negative factor in discretionary decisions.
In plain English: being from the wrong country became a mark against you, regardless of your individual merits, history, or qualifications.
The Court specifically called this what it was: an unlawful "country-of-origin penalty."
Cases affected: Adjustment of Status (Form I-485) and Employment Authorization (Form I-765).
What This Means for You Right Now
The Dorcas decision doesn't just make legal history — it has immediate, real-world consequences for thousands of immigrants whose cases were caught in these freezes.
If your Green Card, EAD, or Naturalization was frozen: Your case should now return to standard adjudication procedures under the ordinary statutory framework established by Congress. The holds have been lifted and USCIS has confirmed that cases are returning to normal processing channels.
If you completed your Naturalization process but were waiting for your oath ceremony: Your case should begin moving forward once standard vetting procedures are completed.
If your previously approved benefits were subject to re-review: USCIS may no longer conduct that blanket re-review process. Those approvals stand.
If your case was penalized for your nationality: USCIS may no longer use your country of origin as a negative factor when exercising discretionary judgment on your application.
However — and this is critical — the holds being lifted does not mean your case will automatically move on its own. If your application has been sitting stalled for months, USCIS will not necessarily prioritize it without a push. Staying informed and taking proactive legal action remains essential.
The Uncomfortable Truth About "Just Waiting"
The government counted on applicants doing nothing. These policies were never publicly announced. There was no letter to affected applicants, no official notification, no explanation for the sudden silence on their cases.
Thousands of people assumed the delay was normal. They waited. They called the USCIS hotline and got nowhere. They watched their lives put on hold — jobs, families, futures — by policies that a federal court has now confirmed were illegal from the start.
If your case has been frozen for an extended period and you haven't taken legal action, right now is the moment to change that.
Take Control of Your Case Today
At Goldstein Immigration Lawyers, we have been tracking the Dorcas litigation and are actively reviewing cases impacted by these now-vacated policies. If you believe your Green Card, EAD, naturalization, or asylum application was frozen due to any of these holds, we want to hear from you.
Your case deserves to move forward. Let us fight to make sure it does.
Review whether your case was affected by the vacated holds Identify the right legal strategy to push your case forward Ensure USCIS is no longer applying unlawful nationality-based penalties to your file
Take the Next Step
📞 Call us: (213) 262-2000
🌐 Visit: jgoldlaw.com
Frequently Asked Questions
Four USCIS internal policies: the Benefits Hold Policy (PM-602-0192), the Comprehensive Re-Review Policy (PM-602-0194), the Country-Specific Factors Policy Alert (PA-2025-26), and the Asylum Hold Policy. USCIS has confirmed all four are no longer in effect and are to be treated as though they never took effect.
Posted in: Blog, Litigation News