USCIS Benefits Freeze Ruling 2026: First Circuit Appeal Could Impact Adjustment of Status Green Cards

On June 5, 2026, Chief Judge John J. McConnell Jr. of the U.S. District Court in Rhode Island vacated four USCIS policies in Dorcas Int'l Institute of Rhode Island v. USCIS. The court found that USCIS exceeded its statutory authority and violated the Administrative Procedure Act (APA) by freezing immigration benefit adjudications through internal policy memos rather than formal rulemaking. The four struck-down policies had suspended adjudications for nationals from designated travel-ban countries, treated nationality as a negative discretionary factor, mandated re-review of previously approved benefits, and imposed country-specific adjudication restrictions. A June 11 clarifying order made the vacatur unambiguous, giving the government 24 hours to report on compliance. On June 12, 2026, USCIS filed an appeal with the U.S. Court of Appeals for the First Circuit. USCIS simultaneously updated its website, expressed disagreement with the ruling, but confirmed it will no longer enforce Policy Memos 601-0192, 602-0194, and 2025-23 while the appeal proceeds. A stay of the district court decision pending appeal remains a possibility. For EB-3 applicants and employers, the immediate practical effect is that USCIS must currently process benefit applications — including adjustment of status, Employment Authorization Documents, and naturalization — without applying the frozen policies. However, the litigation remains fluid and outcomes could reverse. The First Circuit's decision is expected to be one of the most consequential immigration administrative law rulings of 2026, setting boundaries on how broadly executive agencies may restrict immigration benefits through internal guidance. Employers and foreign nationals should monitor developments closely over the coming weeks.