Batalla Vidal v. Nielsen, 279 F.Supp.3d 401

DACA (Deferred Action for Childhood Arrivals) was created by DHS in 2012 to grant discretionary deferred action and work authorization to certain immigrants brought to the U.S. as children; nearly 800,000 relied on it.
On September 5, 2017, Attorney General Sessions and Acting DHS Secretary Duke announced a phased rescission of DACA: reject new initial applications, limit renewals, but continue adjudicating certain pending/near-term renewals.
Plaintiffs (individuals, states, and organizations) sued, alleging the rescission violated the Administrative Procedure Act (APA) and other laws; they sought a preliminary injunction to preserve DACA pending final adjudication.
The agency record and the Sessions letter framed the rescission primarily as necessary because DACA was unlawful/unconstitutional and because of litigation risk after Texas v. United States (challenging DAPA/DACA expansion).
The court reviewed whether the rescission was arbitrary and capricious under APA §706(2)(A), focusing on whether DHS provided a reasoned explanation and considered reliance interests.
The court concludes DHS likely acted arbitrarily and capriciously (erroneous legal premise, factual mistakes about prior court holdings, internal contradictions) and grants a nationwide preliminary injunction preserving DACA processing and renewals under pre-rescission terms (with limited exceptions).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether rescission is reviewable under APA	Rescission is reviewable and must meet arbitrary-and-capricious standard	Rescission is committed to executive discretion / non-justiciable	Court previously found and proceeds on APA review; here treats merits under APA standard
Whether rescission was arbitrary and capricious	Rescission rested on legally erroneous view that DACA was unconstitutional, relied on incorrect facts about Texas/DAPA, and ignored reliance interests	Rescission was reasonable due to litigation risk and policy judgment to leave major immigration changes to Congress	Court: Plaintiffs likely to succeed; rescission arbitrary and capricious for stated reasons
Whether DHS adequately considered reliance interests	Plaintiffs: DHS failed to consider serious reliance (employment, education, state services, economic harms)	Defendants: Reliance interests were limited/contingent and Secretary mitigated harms via phased wind-down	Court: DHS failed to consider reliance; reliance interests are serious and must be addressed
Scope of preliminary relief (nationwide injunction)	Nationwide injunction necessary to preserve plaintiffs' and states' interests and ensure uniform immigration policy	Nationwide relief is overbroad; injunction should be limited to plaintiffs	Court: Grants nationwide preliminary injunction to maintain status quo ante (with limited exceptions)

Motor Vehicle Mfrs. Ass'n v. State Farm, 463 U.S. 29 (agency action must be the product of reasoned decisionmaking)
FCC v. Fox Television Stations, 556 U.S. 502 (agency must provide reasoned explanation when changing policy)
Chaney v. Heckler, 470 U.S. 821 (agency enforcement discretion and limits on judicial review)
Overton Park v. Volpe, 401 U.S. 402 (review limited to administrative record; courts cannot supply post hoc rationalizations)
SEC v. Chenery Corp., 318 U.S. 80 (agency cannot rely on reasons not given in the record)
Arizona v. United States, 567 U.S. 387 (broad federal authority over immigration and enforcement discretion)
Youngstown Sheet & Tube Co. v. Sawyer, 343 U.S. 579 (Jackson concurrence on limits of executive power; cited re: congressional inaction)
Winter v. Natural Resources Defense Council, 555 U.S. 7 (standard for preliminary injunction)
Nken v. Holder, 556 U.S. 418 (balancing equities in stays/remedies involving government)
Texas v. United States, 809 F.3d 134 (5th Cir.) (vacated by an equally divided Supreme Court; discussed for DAPA and related holdings)