Case: State of Texas v. United States Department of Justice
7:26-cv-00070 | U.S. District Court for the Northern District of Texas
Filed Date: June 22, 2026
Closed Date: June 22, 2026
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Case Summary
This case challenged a Department of Justice (DOJ) rule, adopted in 2024, that rescinded a 2020 rule limiting immigration judges’ authority to administratively close immigration cases. To administratively close a case is to remove it from the court’s active docket, pausing adjudication until a later date. Critics of the rule, including the plaintiff, argued that the rule allowed immigration judges to effectively grant amnesty to unauthorized immigrants.
On June 22, 2026, the State of Texas filed this lawsuit in the U.S District Court for the Northern District of Texas. Texas sued the DOJ under the Administrative Procedure Act (APA) and the Take Care Clause in Article II of the United States Constitution. First, Texas argued that the rule violated the Immigration and Nationality Act (INA), which states: “At the conclusion of the proceeding the immigration judge shall decide whether an alien is removable from the United States.” 8 U.S.C. § 1229a(c)(1)(A). By allowing for immigration judges to administratively close cases, Texas argues that the rule allows them not to decide on an immigrant’s status. Second, Texas argued that the rule was an arbitrary and capricious agency action since it did not consider states’ reliance interests in effective adjudication of removal proceedings, the cost of keeping unauthorized immigrants in the United States due to administrative closures, how the rule may incentivize unauthorized immigration, how the rule interplays with other “policies of nonenforcement”, or separation-of-function concerns, and was pretextual, pointing to a statement by the Executive Office for Immigration Review (a sub-agency of the DOJ tasked with conducting removal proceedings) that administrative closures hinder, rather than aiding, docket management. Third, Texas argued that the rule bypassed the notice-and-comment period required by the APA for all rules in the Federal Register. Finally, Texas argued that the rule violated the Take Care Clause by allowing immigration judges to close all removal cases where the defendant only violated immigration law. Texas sought a declaratory judgment holding that the rule violated the APA and INA and that no statute authorizes immigration judges to administratively close or suspend adjudication of cases, vacatur of the rule, and a permanent injunction enjoining the defendants from implementing the rule.
The case was assigned to District Judge Reed O’Connor.
Immediately after the complaint was filed, the parties agreed to a consent decree, under which the DOJ abandoned the 2024 rule. On that same day, June 22, 2026, the Court ordered the rule invalid, holding that no statute authorizes immigration judges to administratively close or suspend adjudication of cases.
Summary Authors
Sam Black (8/3/2026)
People
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/73513959/parties/state-of-texas-v-united-states-department-of-justice/
O'Connor, Reed Charles (Texas)
Rogers, James K (Texas)
Tebo, Kyle (Texas)
Documents in the Clearinghouse
Resources
Docket
See docket on RECAP: https://www.courtlistener.com/docket/73513959/state-of-texas-v-united-states-department-of-justice/
Last updated July 26, 2026, 6:43 p.m.
Case Details
State / Territory:
Case Type(s):
Special Collection(s):
Trump Administration 2.0: Challenges to the Government
Key Dates
Filing Date: June 22, 2026
Closing Date: June 22, 2026
Case Ongoing: No
Plaintiffs
Plaintiff Description:
The plaintiff is the State of Texas.
Plaintiff Type(s):
Public Interest Lawyer: No
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Federal
United States Department of Justice
Defendant Type(s):
Case Details
Causes of Action:
Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.
Constitutional Clause(s):
Other Dockets:
Northern District of Texas 7:26-cv-00070
Available Documents:
Outcome
Prevailing Party: None Yet / None
Relief Sought:
Relief Granted:
Injunction / Injunctive-like Settlement
Source of Relief:
Form of Settlement:
Court Approved Settlement or Consent Decree
Issues
Immigration/Border:
Case Summary of State of Texas v. United States Department of Justice, Civil Rights Litig. Clearinghouse, https://clearinghouse.net/case/48322/ (last updated 8/3/2026).