Washington – On Monday, a federal judge in Maryland barred the Trump administration from carrying out immigration enforcement actions at specific places of worship for Quakers, Cooperative Baptists, and Sikhs who had filed a lawsuit challenging President Trump’s repeal of a Biden-era memo that prohibited immigration arrests at certain protected locations.
U.S. District Judge Theodore Chuang granted religious groups’ request for a narrow preliminary injunction in their challenge to Mr. Trump’s directive allowing federal immigration authorities to conduct enforcement actions at places of worship.
Chuang’s order does not overturn the administration’s policy nationwide, but only applies to houses of worship owned or used by the challengers — the Quakers, the Cooperative Baptist Fellowship, and the Sikh Temple.
The groups argued that the new policy, which allows immigration arrests in previously protected areas, violates their First Amendment rights and burdens the free exercise of religion under federal law.
Chuang, appointed by President Barack Obama, discovered that the threat of enforcement action at houses of worship attended by the three religious communities has reduced attendance not only by illegal immigrants, but also by those with legal status who are concerned about being mistaken for unauthorized immigrants.
The court concluded that the Trump administration’s new policy likely violates the rights of faith groups under the Religious Freedom Restoration Act and the First Amendment.
“Where plaintiffs’ communal religious exercise will be significantly and adversely affected by reductions in attendance resulting from immigration enforcement actions pursuant to the 2025 policy, armed law enforcement officers operating in or at places of worship pursuant to the 2025 policy will adversely affect the ability of Quakers and Sikhs to follow their religious beliefs or worship freely,” Chuang stated in a 59-page decision.
The court determined that the 2025 policy places a significant burden on the groups’ exercise of religion in terms of communal worship and the Cooperative Baptists’ immigrant-focused services.
“Immigration enforcement actions at plaintiffs’ places of worship pursuant to the 2025 policy would impose substantial pressure on plaintiffs’ to modify their behavior by preventing them from worshipping with a larger and more diverse group of congregants and thereby inhibiting their exercise of central facets of their respective religions,” according to Chuang.
He claimed that because the Trump administration’s new directive has already resulted in a decrease in attendance at communal worship, it “effectively compels” religious groups to worship with a smaller congregation and fewer immigrants, “even though their beliefs call for worship with as large and diverse a community as possible.”
“Plaintiffs have thus shown that religious exercise is being hindered by the 2025 policy for entire congregations, including United States citizens and immigrants with legal status, whose ability to worship is undermined by such reduced participation,” according to Chuang.
The judge ordered the Trump administration to reinstate a 2021 memorandum from then-Homeland Security Secretary Alejandro Mayorkas, which prohibited the department and its components from taking enforcement action in places that “require special protection,” such as schools, medical facilities, and places of worship. According to the memo, immigration enforcement actions should be avoided “to the greatest extent possible” at places of worship.
The court order requires President Trump’s Department of Homeland Security to follow the terms of the 2021 memo when pursuing enforcement actions at the three faith communities’ places of worship.
Chuang’s order does not prevent the Trump administration from making arrests in or near places of worship when a warrant is issued.
Skye Perryman, president and CEO of Democracy Forward, which filed the lawsuit on behalf of the religious groups, expressed gratitude to the court for limiting the policy.
“For decades, the government has recognized that everyone, regardless of immigration status, should be able to attend religious services without fear of a warrantless government raid. Religious institutions should not have to go to court to defend their right to freely worship and associate, which is guaranteed by our Constitution,” she said in a statement in response to the court’s ruling.
Mr. Trump’s directive to revoke the Biden administration’s memo was issued on his first day in office as part of a series of executive actions aimed at cracking down on immigration. The Trump administration replaced it with a directive stating that “it is not necessary” to “create clear guidelines on where our immigration laws can be enforced.”
According to a press release from the Department of Homeland Security, “criminals will no longer be able to avoid arrest by hiding in America’s schools and churches.” The Trump administration will not bind the hands of our brave law enforcement officers, but rather trusts them to use common sense.”
The Religious Society of Friends’ six meetings make up the Quakers. The Religious Society of Friends has practiced the Quaker faith in the United States since the 1600s, and “yearly meetings” are its highest governing bodies. The group has argued that the communal aspect of its worship is essential to the practice of the Quaker faith.
The Cooperative Baptist Fellowship is a network of churches, worshippers, and partners comprised of over 1,400 congregations. Its congregations exist in 37 states, the District of Columbia, and Puerto Rico. According to court filings, many congregations have a large number of immigrants as members, and some of the Cooperative Baptist Fellowship’s congregations engage in immigration and refugee ministry.
The Sikh Temple serves as a place of worship for the approximately 30,000 Sikhs who live near Sacramento, California. According to court documents, immigrants make up roughly half of the congregation.
