Coalition for Humane Immigrant Rights v. DHS, 25-5152

Plaintiffs, a group of nonprofit organizations serving immigrant communities, challenged an Interim Final Rule by DHS requiring certain aliens to register and provide biometric data.
The Rule, created pursuant to a 2025 executive order, instituted Form G-325R, allowing previously unregistered aliens to comply with statutory registration requirements.
Plaintiffs sought a stay or preliminary injunction to delay the Rule’s effective date, alleging violations of the Administrative Procedure Act (APA) and constitutional harms (including Fifth Amendment self-incrimination and First Amendment chill).
The district court evaluated the request under the standards for a preliminary injunction, focusing on standing as a threshold issue.
Ultimately, the court found plaintiffs lacked standing—both organizational and associational—because the alleged harms were speculative, not concrete, and mostly consisted of increased workload or self-imposed chilling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing	Plaintiffs said they suffered (or their members would suffer) concrete injuries from the Rule.	DHS argued plaintiffs’ harms were speculative and failed to show injury-in-fact.	Plaintiffs lacked both organizational and associational standing.
APA Notice & Comment	Plaintiffs contended the Rule is legislative and thus needed notice/comment under the APA.	DHS said the Rule is procedural and exemption applies; plaintiffs had no standing.	Didn’t reach merits due to lack of standing.
Substantive APA (Arbitrary)	Plaintiffs asserted the Rule was arbitrary/capricious due to its scope and effect.	DHS defended the Rule as reasoned government policy.	Didn’t reach merits due to lack of standing.
Constitutional Harms	Plaintiffs raised Fifth Amendment (self-incrimination) and First Amendment chill claims.	DHS argued any such risks were speculative or inapplicable by statute.	Claims were speculative; no credible threat established.

Munaf v. Geren, 553 U.S. 674 (preliminary injunction standards)
Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (elements for preliminary injunction)
Food & Water Watch, Inc. v. Vilsack, 808 F.3d 905 (organizational standing requirements in D.C. Circuit)
PETA v. USDA, 797 F.3d 1087 (example of organizational standing where government action impedes core activities)
TransUnion LLC v. Ramirez, 594 U.S. 413 (injury must have historical or common-law analogue to be concrete)
Susan B. Anthony List v. Driehaus, 573 U.S. 149 (pre-enforcement standing requires credible threat of prosecution)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (plaintiff bears burden of establishing standing)