US Appeals Court Affirms Injunction Blocking Immigration Enforcement at Quaker, Sikh, and Baptist Houses of Worship

The US Court of Appeals for the Fourth Circuit affirmed a preliminary injunction Tuesday, preventing the US Department of Homeland Security (DHS) from conducting immigration enforcement actions at or near Quaker, Sikh, and Baptist houses of worship. The decision followed a lawsuit filed by six Quaker organizations, Sikh Temple Sacramento, and the Cooperative Baptist Fellowship (CBF) against the Trump administration over a policy permitting immigration enforcement near religious institutions.

The court’s opinion highlighted sworn declarations from congregations detailing how they have altered their worship practices since the policy change. Roni Kingsley, clerk of the Richmond Friends Meeting, noted that a member expressed concern about being mistaken for undocumented individuals and feared enforcement actions near the meeting. Similarly, Rev. Dr. Jeff Hayes of Oakland Baptist Church reported that immigrant congregants are now afraid to attend the church, citing the policy as a potential target for enforcement. One CBF congregation experienced a 66 percent drop in attendance at its English-as-a-second-language classes.

In *Philadelphia Yearly Meeting of the Religious Society of Friends v. US Department of Homeland Security*, No. 25-1512, a unanimous three-judge panel ruled that the documented attendance declines were a “predictable effect” of the 2025 policy, sufficient to establish standing. The panel also determined that the plaintiffs were likely to succeed on their claim that the policy violates the Religious Freedom Restoration Act (RFRA). Senior Judge Barbara Milano Keenan authored the opinion, joined by Judges Pamela Harris and G. Steven Agee, who also concurred separately. The panel found that DHS waived any compelling-interest defense by failing to raise it or present evidence below.

DHS rescinded a 2021 policy that limited enforcement near “protected areas,” including churches, schools, and hospitals, in a January 20, 2025 memo signed by then-Acting Secretary Benjamin Huffman. The memo eliminated “bright line rules” on enforcement locations, instructing agents to rely on their own discretion instead.

Six Quaker organizations, Sikh Temple Sacramento, and CBF filed the lawsuit in the US District Court for the District of Maryland. Judge Theodore Chuang granted a preliminary injunction in February 2025 covering the plaintiffs’ congregations but declined to extend it nationwide. Judge Agee’s concurrence emphasized the injunction’s narrow scope, noting that DHS may still make arrests at the plaintiffs’ properties with a warrant, in hot pursuit, or during genuine emergencies.

The plaintiffs stated in a joint statement that the ruling “reaffirms a fundamental promise of religious freedom.” They argued that the policy undermines the trust and safety of congregants, particularly those who are immigrants or fear deportation. The decision underscores the importance of protecting sacred spaces as places of refuge and worship, aligning with the biblical call to love neighbors and protect the vulnerable, as seen in Micah 6:8.

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