Group Lawsuit challenging PM-602-0192 and PM-602-0194 holds as applied to pending I-765 Applications
After a break, we are offering a group lawsuit in April that is an opportunity for citizens of the 39 countries listed in Presidential Proclamations 10949 and 10998 to challenge the “hold” on the processing and/or adjudication of their Form I-765, Application for Employment Authorization (I-765 Application) 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 processing and adjudications of I-765 Applications is unlawful because it is based upon the national origin of the applicants, and because USCIS lacks the legal authority to do such a blanket suspension. In fact, multiple courts have already issued injunctions enjoining the holds, including: Varniab v Edlow (NDCA), Bowser v. Edlow (Mass.), Doe v. Trump (Mass.), and Doe v. USCIS (NDIL).
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 I-765 Applications are being processed, where the plaintiffs are domiciled, and the latest outcomes related to the 30+ lawsuits already pending challenging the holds.
Important Dates
Deadline to participate: April 22, 2026
Filing date for complaint: April 29, 2026
Filing date for motion for preliminary injunction: May 6, 2026
To participate in this group lawsuit project, an I-765 Applicant must meet the following four requirements:
(1) The applicant must be inside the United States;
(2) The applicant must have an I-765 Application pending (with I-797 receipt notice to prove it);
(3) The applicant must be a national of 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
(4) The applicant cannot be a plaintiff in any other active unreasonable delay/mandamus lawsuit challenging delays related to the I-765 application.
Cost to Participate
The attorney fee to participate as a plaintiff in the lawsuit will be $3,000 for each I-765 Applicant. This fee includes the cost of participation of all derivative beneficiaries who also have a pending I-765 (spouses and children) who also have I-765 pending, regardless of family size. (Note: Do not include young children as plaintiffs who do not have pending I-765 applications.)
The terms for payment are as follows: The initial attorney fee of $1,000 is due in advance of the representation, and the $2,000 balance is deferred until and due on July 1, 2026.
Note: the $2,000 backend payment is only deferred as a courtesy for the unpredicted hardship faced by victims of the hold. Participants who are not comfortable with this contingency are welcome to pre-pay the entire $3,000 attorney fees.
Exception: If you participated as a plaintiff in our previous group lawsuits for Form I-485 (internal case numbers: CM613, CM619, CM642, CM643), then participation as a plaintiff in this lawsuit too for your I-765 only is $1,000, with no deferred/back-end payment.
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.
No.
We want the court to enjoin, or block, the USCIS “hold” policies as they are applied to our participating plaintiffs. We will also ask the court to compel USCIS to make the delayed I-765 Application adjudications within 30 days.
We will decide after plaintiffs are onboarded, because only then will we best know what our options are.
No. Representation will be limited to court proceedings.
The fee for all families is the same. We only charge for the I-765 Applicant in the family. We do not charge extra for derivative spouses or children.
(Note: Do not include young children as plaintiffs who do not have pending I-765 applications.)
No. No litigation is ever guaranteed to win.
No.
No. In this lawsuit, we will only be seeking relief for named plaintiffs.
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