A D.C. federal judge on Friday declined to issue an injunction barring the Trump administration from carrying out immigration raids or arrests in places of worship while litigation over the raids is ongoing, ruling that religious groups haven't shown a credible threat of enforcement, "at least at this juncture."
U.S. District Judge Dabney L. Friedrich denied the motion for a preliminary injunction lodged by a coalition of 27 Christian and Jewish organizations representing millions of congregants. Notably, Judge Friedrich said that the religious groups don't have standing to challenge the directives cited in the suit, largely because those directives don't instruct law enforcement to target churches or synagogues or "treat places of worship as high priority locations for immigration enforcement."
The Trump administration's rollback of a policy limiting when immigration arrests could take place in sensitive locations like churches and hospitals is merely a "modest change in the internal guidance" that the U.S. Department of Homeland Security is giving its immigration officers, the judge said.
It doesn't mandate conducting enforcement activities during worship services, nor does it seem that places of worship are being singled out, Judge Friedrich said.
"Since the policy rescission took effect over 10 weeks ago, only one enforcement action has taken place at the hundreds of plaintiffs' member congregations," she said. "The plaintiffs can point to only three instances, since Jan. 20, 2025, where any immigration enforcement action has taken place in or near any place of worship anywhere in the country, even under the current administration's more vigorous immigration priorities and increased [Immigration and Customs Enforcement] quotas."
That "limited pattern further undermines the inference that actions against plaintiffs' congregations are imminent," according to the order.
The religious groups sued in February, claiming that their ability to practice their faith has been restricted by the immigration raids. Specifically, they say fear is driving down attendance and interfering with their ability to minister to immigrants, including those who've entered the country unlawfully.
The coalition is alleging violations of the First Amendment and the Religious Freedom Restoration Act. The RFRA, passed in 1993, is intended to protect religious freedom by banning the government from doing anything that substantially burdens the practice of someone's religion unless that action, law or policy is the least restrictive way to accomplish whatever interest the government is pursuing.
Friday's ruling comes a week after a hearing on the injunction, during which Judge Friedrich appeared skeptical about the religious groups' argument.
The religious groups have argued that the shift is a violation of the RFRA. But Judge Friedrich asked during the hearing, "How can you say across the board that there's not an instance in which it would be the least restrictive means to go into a church and arrest an alien? Congress has given ICE the authority to do that."
In Friday's order, Judge Friedrich said that although the groups do claim ICE has surveilled near their premises, they haven't shown any direct link between the surveillance and "an actual or pending immigration raid at a church or synagogue."
"Absent evidence of specific directives to immigration officers to target plaintiffs' places of worship, or a pattern of enforcement actions, the court finds no credible threat of imminent enforcement," the judge said. "Accordingly, the plaintiffs lack standing to assert a pre-enforcement challenge."
As for decreasing attendance at the groups' churches and synagogues, the groups haven't yet offered enough evidence showing that the policy change "— as opposed to the administration's broader immigration crackdown — has caused the widespread congregant absences from religious services," Judge Friedrich said. Rather, the evidence offered by the groups suggests that congregants "are staying home to avoid encountering ICE in their own neighborhoods, not because churches or synagogues are locations of elevated risk," according to the order.
"For similar reasons, the plaintiffs have not shown that a preliminary injunction would redress their alleged attendance injury," she said.
According to the suit, both the First Amendment and the RFRA require DHS to use the least restrictive means to conduct immigration enforcement. Any raids conducted in so-called sensitive locations like churches require "exigent circumstances or a judicial warrant," the complaint states.
For decades, federal policy has directed immigration officers to avoid enforcement actions in places of worship except under extraordinary circumstances. The Trump administration rescinded that policy on day one, calling on agents to "use common sense" when conducting immigration enforcement activities near places of worship and other sensitive locations.
At the time of the policy shift, DHS said "criminals will no longer be able to hide in America's schools and churches to avoid arrest."
The groups claim that the abrupt policy reversal flouts proper rulemaking procedures, including the requirement that such policy shifts be supported by reasoned justifications and take into consideration the potential adverse impacts. Here, the administration fell short on both fronts, they said.
DHS Assistant Secretary Tricia McLaughlin said in a statement that the ruling "is a victory in President Trump and Secretary [Kristi] Noem's fight to make Americans and our communities safer in part by stopping violent criminals from using churches to evade law enforcement."
"We are protecting our schools, places of worship by preventing criminal aliens and gang members from exploiting these locations and taking safe haven there because these criminals knew law enforcement couldn't go inside under the Biden administration," McLaughlin said.
She added that "our officers use discretion."
"Officers would need secondary supervisor approval before any action can be taken in locations such as a church or a school," McLaughlin said. "We expect these to be extremely rare."
Counsel for the groups didn't immediately respond to requests for comment late Friday.
The religious groups are represented by Kelsi Brown Corkran, Shelby B. Calambokidis, Julia Gegenheimer, Alexandra Lichtenstein and Kate Talmor of the Institute for Constitutional Advocacy and Protection.
The government is represented by Kristina Wolfe of the U.S. Department of Justice's Civil Division.
The case is Mennonite Church USA et al. v. Department of Homeland Security et al., case number 1:25-cv-00403, in the U.S. District Court for the District of Columbia.
–Additional reporting by Nadia Dreid. Editing by Michael Watanabe.
Update: This article has been updated to include comment from DHS.
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