The Supreme Court on Monday sided with the Trump administration in Noem v. Perdomo, voting 6-3 to lift a lower court injunction that had restricted federal immigration enforcement in Los Angeles. The decision, issued on the court’s emergency "shadow docket," did not include a signed majority opinion explaining the rationale; all six Republican-appointed justices voted with the majority and the three Democratic-appointed justices dissented.
In a separate concurrence, Justice Brett Kavanaugh wrote that factors such as "apparent ethnicity" and language can be relevant to the reasonable-suspicion analysis in immigration stops when combined with other indicators. Justice Sonia Sotomayor issued a dissent that warned the ruling risks legalizing racial profiling of Latinos, writing, "We should not have to live in a country where the Government can seize anyone who looks Latino, speaks Spanish, and appears to work a low wage job. Rather than stand idly by while our constitutional freedoms are lost, I dissent."
The ruling removes restrictions imposed in July by U.S. District Judge Maame Ewusi-Mensah Frimpong, whose temporary order barred federal officers from stopping or detaining people in Los Angeles "solely" because of any one of four factors or any combination of them: apparent race or ethnicity, speaking Spanish or English with an accent, presence at locations such as agricultural workplaces or day-labor pickup sites, or the type of work performed. Frimpong's order did not prevent immigration officers from considering those factors when they were accompanied by additional, independent grounds for reasonable suspicion.
Frimpong reached her order after a series of immigration operations in Los Angeles that she found often targeted workers at job sites and other locations where the government believed undocumented immigrants congregate. Her findings cited operations that detain workers at car washes, farms and packing houses, and a raid that stopped multiple day laborers outside a Westlake Home Depot. The judge also identified incidents she said suggested racial targeting and stops without adequate justification, including a case in which agents detained an American-born man, Jason Brian Gavidia, until he produced identification showing lawful status.
The case turned on what courts can practically do to curtail enforcement practices that plaintiffs say produce repeated, unlawful encounters. The government argued that federal courts should be reluctant to issue broad, prospective injunctions regulating law enforcement behavior, invoking precedents that limit such relief. The Trump administration's briefs cited the Supreme Court's 1983 decision in City of Los Angeles v. Lyons, which has long constrained plaintiffs' ability to obtain injunctions barring future police conduct unless they can demonstrate a likelihood of repeated injury, and the Court's recent decision in Trump v. CASA, which advised caution about injunctions that extend relief beyond the parties to a suit.
Frimpong countered that narrow, individual relief would be inadequate because officers would have no practical way to determine which individuals were covered by a limited injunction. "It would be a fantasy to expect that law enforcement could and would inquire whether a given individual was among the [plaintiffs] before proceeding with a seizure," she wrote when issuing the order.
Legal scholars and advocacy groups had framed the dispute around competing limits on judicial power and the realities of enforcement. Some observers noted the order was modest in scope because it did not bar enforcement entirely but only prohibited reliance "solely" on the enumerated factors. Others cautioned that categorical bans can conflict with long-established Fourth Amendment principles that permit officers to consider context-specific details, such as consistent presence at locations where undocumented day laborers seek work, when forming reasonable suspicion.
The decision also intersects with recent Supreme Court rulings that narrow remedies available against federal officers. In Hernández v. Mesa (2020) and Egbert v. Boule (2022), the court curtailed the circumstances in which plaintiffs can recover money damages for constitutional violations by federal agents, significantly limiting the practical deterrence of individual lawsuits. As a result, even successful challenges to particular stops often produce limited relief.
The lower court injunction appears to have had concrete effects on enforcement activity in Los Angeles. Citing research from the Cato Institute, some analysts reported a marked reduction in immigration arrests in the city while the order was in place. With the injunction lifted, immigration enforcement in the region is likely to resume under the broader standards the administration favors, subject to whatever supervision lower courts may still exercise in individual cases.
The case highlights the tension between judges' traditional reluctance to issue broad prophylactic rulings against law enforcement and plaintiffs' claims that isolated lawsuits will not stop recurring constitutional violations. Lyons established a demanding standard for future-oriented injunctions, requiring plaintiffs to show a real and immediate threat of repetition; that precedent was central to the government's argument before the Supreme Court. CASA, decided in the spring, further complicated the standard by cautioning against injunctions that extend protections beyond the specific parties to the litigation, although the Court allowed such relief in narrow circumstances when necessary to provide complete relief.
Practically speaking, those who say they were unlawfully stopped may still seek relief in individual suits or motions to enforce rights, but legal experts note the available remedies are limited and often slow-moving. Plaintiffs pursuing litigation against federal officers face substantial obstacles, including the narrowing of Bivens-style claims for monetary damages and the lack of guaranteed legal counsel in immigration proceedings. Even when courts find a stop unlawful, the remedy is frequently limited to exclusion of evidence, return of property, or orders specific to named plaintiffs, rather than broad prohibitions that would change enforcement practices across a jurisdiction.
The Supreme Court's decision in Noem v. Perdomo therefore underscores how the court's procedural and remedial doctrines shape the practical reach of constitutional protections against government action. By acting on the shadow docket without a full, signed majority opinion, the court allowed the federal government to proceed without establishing a detailed, published rule for lower courts in future cases. The immediate legal effect is to restore the enforcement approach that the Trump administration adopted for operations in Los Angeles, while leaving open the possibility of further litigation about what constitutes reasonable suspicion in immigration stops under the Fourth Amendment.
The ruling will be closely watched by civil liberties groups, immigrant advocates and local officials who argued that the prior raids led to repeated encounters with people who were legally present, and by the administration and its supporters, who contend that the ability to use contextual factors is necessary to enforce immigration laws. The balance the courts strike between avoiding blanket injunctions and protecting individuals from discriminatory or arbitrary enforcement will continue to shape litigation and enforcement practice in Los Angeles and beyond.