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In Donald J. Trump, President of the United States, et al. v. J.G.G., et al., the Supreme Court granted the government’s application to vacate temporary restraining orders issued by the District Court for the District of Columbia, which had blocked the removal of several Venezuelan detainees allegedly affiliated with the foreign terrorist organization Tren de Aragua (TdA). The detainees challenged President Trump’s Proclamation No. 10903, issued under the Alien Enemies Act (AEA), which authorized their detention and removal.

The Court construed the TROs as appealable injunctions and held that the detainees’ claims must be brought in habeas corpus. Because the claims necessarily challenged the legality of confinement and removal under the AEA, they fell within the “core” of habeas jurisdiction. As such, jurisdiction and venue lay solely in the district of confinement—Texas—not in the District of Columbia. The Court emphasized that equitable relief cannot be sought outside habeas in this context, relying on precedents such as Ludecke v. Watkins and Heikkila v. Barber.

Although the detainees are entitled to judicial review regarding their classification and removal under the AEA—including notice and an opportunity to seek habeas relief—the proper venue to litigate those claims is the district of confinement. The Court clarified that such notice must be given promptly to allow detainees to exercise those rights before removal occurs.

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In Department of Education, et al. v. California, the Supreme Court in a per curiam decision granted the federal government’s application to stay a district court order that had mandated continued payment of certain education-related grants. The District Court for the District of Massachusetts had issued a temporary restraining order (TRO) on March 10, 2025, barring the termination of grant payments and requiring the government to pay both past-due and ongoing obligations. The lower court found that the states challenging the terminations were likely to succeed on their claims under the Administrative Procedure Act (APA).

The Supreme Court, however, treated the TRO as a de facto preliminary injunction and concluded that the district court likely lacked jurisdiction to order monetary payments under the APA. Citing precedents such as Sampson v. Murray and Great-West Life & Annuity Ins. Co. v. Knudson, the Court emphasized that the APA does not waive sovereign immunity for claims that essentially seek money damages or enforce a contractual obligation to pay money—relief instead governed by the Tucker Act and reserved to the Court of Federal Claims.

The Court also held that the government demonstrated a likelihood of success on appeal and that the balance of equities favored a stay. Respondents had not shown they would suffer irreparable harm, particularly because they had the resources to continue their programs and could seek recovery in another forum if successful. The Court concluded that any harm resulting from program shutdowns would be self-imposed.

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In Medical Marijuana, Inc. v. Horn, the Supreme Court affirmed the Second Circuit and held that a plaintiff may seek treble damages under the civil RICO statute for injuries to business or property, even if those injuries stem from a personal injury. Douglas Horn was fired after testing positive for THC, allegedly caused by using a CBD product marketed as THC-free. He sued the manufacturer under RICO, claiming his job loss constituted a business injury. The district court dismissed the case, applying the so-called “antecedent personal injury bar,” which precludes recovery under RICO for business losses resulting from personal injury. The Second Circuit reversed.

Writing for the Court, Justice Barrett rejected the categorical bar. The Court held that while civil RICO does not authorize damages for personal injuries themselves, it does not exclude claims for business or property losses merely because they originate from a personal injury. Drawing on the statute’s text, the Court emphasized the ordinary meaning of “injured in his business or property” and declined to import tort-based limitations or narrow definitions unsupported by the statutory language. The Court also declined to adopt a rigid rule for distinguishing personal from business injuries, finding such distinctions difficult to apply and inconsistent with prior precedent.

Justice Barrett delivered the opinion of the Court, joined by Justices Sotomayor, Kagan, Gorsuch, and Jackson. Justice Jackson filed a concurring opinion. Justice Thomas dissented. Justice Kavanaugh filed a dissenting opinion, joined by Chief Justice Roberts and Justice Alito.

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