Group Lawsuit challenging PM-602-0192 and PM-602-0194 holds, including motions for preliminary injunction and class certification
We are offering a class action group lawsuit that is an opportunity for citizens of the 39 countries listed in Presidential Proclamations 10949 and 10998 to challenge the “hold” on the adjudication of USCIS benefits caused by the December 2, 2025 USCIS Policy Memorandum, PM-602-0192, and January 1, 2026 Policy Memorandum, PM-602-0194.
In sum, we believe the blanket withholding of USCIS adjudications is unlawful because it is based upon the national origin of the applicants or petitioners, and because USCIS lacks the legal authority to do such a blanket suspension, and because the blanket suspension violates the Administrative Procedures Act.
In fact, multiple courts have already issued injunctions enjoining the holds, including: Varniab v Edlow (NDCA), Bowser v. Edlow (Mass.), Doe v. Trump (Mass.), Doe v. USCIS (NDIL), Behdin v Edlow (NDCA), Karimi v. Mullin (WD Arkansas), Abdulraheemzai v Noem (NDCA), and Saghafi v Edlow (Maryland).
We will be filing this group lawsuit in a U.S. District Court to be determined by your attorneys with the goal of maximizing a successful outcome, mitigating potential issues with venue and joinder, based on factors like where the applications of named plaintiffs are being processed, where the plaintiffs are domiciled, and the latest outcomes related to the 30+ lawsuits already pending challenging the holds.
A small subset of plaintiffs will be selected as class representatives, and as such, featured in the motion for class certification alongside declarations explaining why they will make appropriate class representatives.
Important Dates
Deadline to participate: May 14, 2026
Filing date for complaint: May 21, 2026
Filing date for motions for class certification and preliminary injunction: May 28, 2026
To participate in this group lawsuit project, an applicant must meet the following three requirements:
(1) The applicant must have a pending benefit application with USCIS (with I-797 receipt notice to prove it);
(2) The applicant must be a national of a country; or be born in a country, or be petitioned by someone born in a country impacted by President Trump’s June 4, 2025, travel ban called Restricting The Entry Of Foreign Nationals To Protect The United States From Foreign Terrorists And Other National Security And Public Safety Threats; or his December 15, 2025, travel ban called Restricting and Limiting the Entry of Foreign Nationals to Protect the Security Of the United States; and
(3) The applicant cannot be a plaintiff in any other active unreasonable delay/mandamus lawsuit challenging delays related to the pending benefit that is being included and registered in this lawsuit. In other words, if you have a receipt number listed in another lawsuit, we don’t want that receipt number listed in this lawsuit.
Cost to Participate
The attorney fee to participate as a plaintiff in the lawsuit will be $1,400 for each Principal Applicant. This fee includes the cost of participation of all derivative beneficiaries (spouses and children) who also have benefits pending with USCIS, regardless of family size.
(Note: Do not include spouses or children as plaintiffs who do not have pending benefit applications.)
The terms for payment are as follows: The attorney fee of $1,400 is due in advance of the representation.
Afghanistan, Angola, Antigua and Barbuda, Benin, Burkina Faso, Burma, Burundi, Chad, Republic of the Congo, Cote d’Ivoire, Cuba, Dominica, Equatorial Guinea, Eritrea, Haiti, Gabon, The Gambia, Iran, Laos, Libya, Malawi, Mali, Mauritania, Niger, Nigeria, Palestinian Authority, Sierra Leone, Senegal, Somalia, South Sudan, Sudan, Syria, Tanzania, Togo, Tonga, Turkmenistan, Venezuela, Yemen, Zambia, and Zimbabwe.
Yes. It is our understanding that the country of birth of the petitioner can trigger the hold on your benefit application.
Yes. It is our understanding that the applicant's country of birth, regardless of current citizenship, triggers the hold.
Yes. USCIS does not provide the “dual national” exception as listed in the Presidential Proclamations, and you are therefore subject to the hold, and we recommend you participate.
We want the court to enjoin, or block, the USCIS “hold” policies as they are applied to all, including named plaintiffs, through class certification. However, if court is unwilling to certify the class, we will seek relief for named plaintiffs only. Finally, we will ask the court to compel USCIS to make the delayed application adjudications within 60 days.
We will decide on the court venue after plaintiffs are onboarded (and we know where they live), and we assess what orders from other pending cases we are tracking have said as of that time, because only then can we make the best decision on that issue.
No. Representation will be limited to court proceedings.
The fee for all families is the same. We only charge for participation of the Principal Applicant in the family. We do not charge extra for derivative spouses or children.
(Note: Do not include spouses or children as plaintiffs who do not have pending applications.)
No. The fee to participate is $1,400 per family, for all benefits.
We will fight hard for class certification, as we know the government will oppose. However, if the court ultimately does not want to certify a class, we will focus on relief for our named plaintiffs in the lawsuit.
No. No litigation is ever guaranteed to win.
If a participant asks to be removed up to 24 hours before filing of the lawsuit, we will refund the attorney fees, less $120 for administrative fees. There are no refunds once the lawsuit has been filed.
FOR QUESTIONS NOT ANSWERED ABOVE, CONTACT US:
ENGLISH
Curtis Lee Morrison
Telegram: https://telegram.im/@curtisatlaw
Whatsapp: https://wa.me/17146613446
ALBANIAN
Florian - Whatsapp: https://wa.me/19294539176
FARSI:
Farshad: https://wa.me/18595509377
https://telegram.im/@Farshad_Amirkhani
MANDARIN
Chuck – WeChat ID: Xiaoxing_ChuckGuoEsq
NEPALI
Dibin - Telegram: https://telegram.im/@DibinPokharel
SPANISH:
Elsi - Telegram: https://wa.me/14049160065
SOMALI
Abdullahi - Telegram:http://telegram.im/@Abdullahi_Abdi
TAGALOG/CEBUANO
Garrett – Telegram: https://telegram.im/@GarrettMay
GERMAN
Rabea – Telegram: https://telegram.im/@RabeaK
RUSSIAN:
Takhmina - Telegram: https://t.me/tahminnabi
Gulnaz - Telegram: http://telegram.im/Gulnaz_Law
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