Casa De Maryland, Inc. v. Biden, 414 F.Supp.3d 760

DHS issued a final "Public Charge Rule" (84 Fed. Reg. 41292) defining a "public charge" as any noncitizen "more likely than not" to receive one or more public benefits for >12 months in any 36-month period, and expanding covered benefits to include many non‑cash programs (Medicaid, SNAP, housing assistance); effective date: Oct. 15, 2019.
Plaintiffs: CASA de Maryland (immigrant‑rights nonprofit) and two individuals challenged the Rule under the Administrative Procedure Act (APA) and the Fifth Amendment; they moved for a preliminary injunction and for postponement of the Rule’s effective date.
CASA alleges organizational injury: its mission frustrated and resources diverted to advise and assist members, reducing other time‑sensitive advocacy work.
The Court addressed justiciability (standing, ripeness, zone of interests), applied the Winter preliminary‑injunction factors and APA §705 stay authority, and applied Chevron deference to assess statutory validity.
The Court concluded CASA has organizational standing and is within the zone of interests, the case is ripe, and CASA is likely to succeed on the APA claim because DHS’s expansive definition of "public charge" is contrary to the statute and historical/administrative precedent.
Remedy: the Court enjoined DHS, Acting Secretary McAleenan, and USCIS Acting Director Cuccinelli from enforcing or implementing the Rule (and from using related forms) and postponed the Rule’s effective date nationwide pending litigation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing (organizational)	CASA’s mission frustrated and resources diverted to respond to the Rule → concrete injury	Government: resource diversion was voluntary/budgetary and within CASA’s normal activities	CASA has organizational standing (diversion/frustration sufficient)
Ripeness	Rule is final and imminent harms (resource diversion, chilled benefits) make review ripe	Government: harms depend on third‑party choices and are not strictly legal	Case is ripe for review
Zone of interests under APA	CASA’s advocacy and services for immigrant health/economic welfare fall within INA §212(a)(4)’s concerns	Government: zone protects only aliens directly affected by inadmissibility determinations	CASA is "arguably within" the statute’s zone of interests
APA challenge (definition of "public charge")	Rule’s 12/36 months + inclusion of short‑term noncash benefits contradicts statutory meaning, history, precedent, 1999 Field Guidance, and congressional action/rejections → rule is not in accordance with law	Government: statute ambiguous; DHS permissibly interpreted statutory gap and relied on policy statements like the Welfare Reform Act	Court finds Plaintiffs likely to succeed: DHS’s definition is foreclosed by statutory history/interpretation (fails Chevron Step One and is impermissible at Step Two)

Chevron U.S.A., Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837 (U.S. 1984) (framework for judicial review of agency statutory interpretations)
FDA v. Brown & Williamson Tobacco Corp., 529 U.S. 120 (U.S. 2000) (agency interpretation invalid where Congress has effectively precluded it)
Gegiow v. Uhl, 239 U.S. 3 (U.S. 1915) (interpreting "likely to become a public charge" to align with permanent personal conditions)
Havens Realty Corp. v. Coleman, 455 U.S. 363 (U.S. 1982) (organizational standing via diversion of resources and mission frustration)
Patchak v. Zinke, 567 U.S. 209 (U.S. 2012) (APA zone‑of‑interests test is not especially demanding)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (U.S. 1992) (constitutional standing requirements)
Winter v. Natural Res. Def. Council, Inc., 555 U.S. 7 (U.S. 2008) (standard for preliminary injunctions)
Whitman v. American Trucking Associations, 531 U.S. 457 (U.S. 2001) (agency interpretations cannot exceed clear statutory limits)