The US Court of Appeals for the Fourth Circuit recently upheld a preliminary injunction that prevents the Department of Homeland Security (DHS) from carrying out immigration enforcement operations at or near certain religious sites. The ruling protects Quaker, Sikh, and Baptist places of worship, which had challenged a policy introduced during the Trump administration. This policy allowed for enforcement actions without the constraints set by previous guidelines.
The court’s decision highlights the impact that the enforcement policy had on religious communities, as congregations reportedly altered their worship practices in response. The opinion referenced statements from affected congregants, such as a member of the Richmond Friends Meeting who expressed concerns about being mistakenly identified as undocumented. Oakland Baptist Church also observed that some immigrant congregants were hesitant to attend services, fearing potential enforcement actions. At another community, there was a notable drop in attendance for English-as-a-second-language classes, emphasizing how deeply the policy affected the congregants’ sense of security.
In Philadelphia Yearly Meeting of the Religious Society of Friends v. US Department of Homeland Security, the Fourth Circuit panel determined that these documented attendance declines were adequate to establish legal standing. The panel ruled that the plaintiffs were likely to succeed with their claim that the enforcement policy infringes upon the Religious Freedom Restoration Act (RFRA). Notably, the DHS had failed to convincingly argue any compelling governmental interest in support of its policy.
This ruling came after a January 2025 memo from then-Acting Secretary Benjamin Huffman, which dismantled the previous “protected areas” policy. The DHS memo, issued on President Trump’s first day back in office, instructed agents to utilize personal discretion, removing specific restrictions against enforcement in sensitive locations like churches and schools.
The lawsuit, initially filed by six Quaker organizations, Sikh Temple Sacramento, and the Cooperative Baptist Fellowship (CBF) in the US District Court for the District of Maryland, resulted in Judge Theodore Chuang granting a preliminary injunction. However, this was limited to the plaintiffs and was not nationwide. Judge G. Steven Agee, in his concurrence, pointed out that the injunction does not entirely prevent DHS from making arrests at these religious sites, allowing actions to proceed under certain conditions such as presenting a warrant, engaging in hot pursuit, or dealing with emergencies.
The ruling has been lauded by the plaintiffs as a reinforcement of religious liberty. They have emphasized their commitment to continue legal proceedings to uphold the protection of religious freedom across all congregations. In contrast, the DHS has voiced its stance that criminals should not leverage religious sites as sanctuaries from arrest, reaffirming its trust in agents to make judicious decisions.
As this litigation progresses, the injunction remains active, with the case returning to district court for further deliberations on its merits. The legal battle underscores ongoing tensions regarding immigration enforcement policies and their intersection with religious freedoms. It also raises broader questions about how these policies impact the exercise of religious rights and the perceived safety of immigrant communities within their places of worship.