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United States v. Texas (2016)

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Supreme Court of the United States
United States v. Texas
Docket number: 15-674
Court: United States Supreme Court
Court membership
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy • Clarence Thomas • Ruth Bader Ginsburg • Steven G. Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan

United States v. Texas is a United States Supreme Court case that was decided on June 23, 2016. The case concerned the constitutionality of President Barack Obama's (D) executive action Deferred Action for Parents of Americans and Lawful Permanent Residents (DAPA), issued in 2014, and whether the action violated the Administrative Procedure Act. Click here to read more about the case background.

On June 23, 2016, the Court issued a 4-4 per curiam opinion affirming the United States Court of Appeals for the Fifth Circuit order blocking DAPA's implementation.[1][2] Click here to read more on the outcome of the case.


Background

See also: President Obama's Immigration Accountability Executive Actions

On November 20, 2014, President Obama announced his Immigration Accountability Executive Actions in a speech delivered in the East Room of the White House. The actions proposed expanding the Deferred Action for Childhood Arrivals (DACA) program and creating the Deferred Action for Parents of U.S. Citizens and Lawful Permanent Residents (DAPA) program. DACA allowed individuals who were brought to the United States as children to receive relief from being deported for a period of time if they meet certain criteria. DAPA proposed delaying the deportation of parents of U.S. citizens or lawful permanent residents and providing them with work permits, as long as they were in the United States since January 1, 2010, and did not pose a threat to national security or public safety.[3]

Since DACA and DAPA were executive actions and not the result of new legislation from Congress, there was debate about whether such actions were constitutional. Soon after President Obama's announcement, Texas and 25 states sued the administration in the United States District Court for the Southern District of Texas to block DAPA's implementation. The states claimed that DAPA violated the Administrative Procedure Act for two reasons: (1) it was essentially a new law that had not received public comment, a necessary component of rulemaking; and (2) it was arbitrary and capricious—a standard for judicial review and appeal, often in administrative procedure cases.[4] The states also asserted that DAPA violated the Take Care Clause of the United States Constitution directing the president to "take Care that the Laws be faithfully executed." The United States sought to have the case dismissed on the grounds that the states did not have standing—the legal right to sue.[1]

In its ruling, the district court held that the states did have standing to sue and issued a preliminary injunction, blocking DAPA's implementation. On appeal, the United States Court of Appeals for the 5th Circuit affirmed the district court ruling, holding, "Reviewing the district court’s order for abuse of discretion, we affirm the preliminary injunction because the states have standing; they have established a substantial likelihood of success on the merits of their procedural and substantive APA claims; and they have satisfied the other elements required for an injunction."[5] Implementation of the DAPA program was blocked until a final ruling on the case.[1][5]

The United States appealed to the United States Supreme Court, which agreed to hear the case on January 19, 2016. Oral arguments were held on April 18, 2016.[1]


Questions presented

The court limited oral arguments to the following questions:[6]
  • "Whether a State that voluntarily provides a subsidy to all aliens with deferred action has Article III standing and a justiciable cause of action under the Administrative Procedure Act (APA), 5 U.S.C. 500 et seq., to challenge the Guidance because it will lead to more aliens having deferred action.
  • "Whether the Guidance is arbitrary and capricious or otherwise not in accordance with law.
  • "Whether the Guidance was subject to the APA's notice-and-comment procedures.
  • "Whether the Guidance violates the Take Care Clause of the Constitution, Art. II, §3."

Outcome

On June 23, 2016, the Court issued a 4-4 per curiam opinion affirming the United States Court of Appeals for the Fifth Circuit order blocking DAPA's implementation.[1][2]

The one-sentence opinion read as follows:[2][7]

“ The judgment is affirmed by an equally divided Court.[8] ”
—Supreme Court of the United States


Aftermath

On October 3, 2016, the Supreme Court rejected a request from the U.S. Department of Justice to rehear the case. These rulings were preliminary ones on the merits of the case; after merits are decided, full cases are typically heard by the lower courts.[9]

On November 16, 2016, Texas and the U.S. Department of Justice filed a joint motion with the U.S. District Court for the Southern District of Texas, asking for a stay in proceedings due to the election of President Donald Trump (R) and the impending change in administration. The stay was granted and both parties were given until June 15, 2017, to decide how to proceed.[10]

On June 15, U.S. Secretary of Homeland Security John Kelly rescinded DAPA, making the case moot. DACA was left in tact.[11]

See also

External links

Footnotes

  1. ↑ 1.0 1.1 1.2 1.3 1.4 Oyez, "United States v. Texas," accessed July 11, 2025
  2. ↑ 2.0 2.1 2.2 Supreme Court of the United States, United States v. Texas, decided June 23, 2016
  3. ↑ The White House, "FACT SHEET: Immigration Accountability Executive Action," November 20, 2014
  4. ↑ Cornell Law School Legal Information Institute, "capricious," accessed July 11, 2025
  5. ↑ 5.0 5.1 5th U.S. Circuit Court of Appeals, State of Texas et al v. USA, decided November 25, 2015
  6. ↑ Supreme Court of the United States, "15-674 UNITED STATES V. TEXAS - QP REPORT," archived February 8, 2017
  7. ↑ The Washington Post, "Equally divided Supreme Court affirms lower court decision on Obama immigration policies," June 23, 2016
  8. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
  9. ↑ BuzzFeed News, "Supreme Court Ends Last Hope For Obama’s Immigration Actions," October 3, 2016
  10. ↑ U.S. District Court for the Southern District of Texas, "Texas v. United States," November 18, 2016
  11. ↑ The Washington Post, "Kelly revokes Obama order shielding immigrant parents of U.S. citizens," June 15, 2017
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