Yesterday the Court stayed most of the district court's injunction in Labrador v. Poe, narrowing the injunction so that it protected only the plaintiffs from the enforcement of Idaho's statute restricting surgeries and other kinds of medical interventions for minors related to gender identity. Accompanying the Court's stay were three opinions about universal injunctions. Labrador v. Poe is an important development and it starts to clarify the Court's direction.
Note that in this post I will refer to "universal injunctions," meaning injunctions that prohibit the government's application of a law or regulation to anyone, not just to the parties and those represented by parties. In other words, the category "universal injunctions" includes national injunctions and also their state equivalents (i.e., it includes nationwide and statewide injunctions), but it excludes the distinct question of vacatur as a remedy under the Administrative Procedure Act. Using the term "universal injunctions" is helpful because it is what is squarely at issue between the justices in Labrador v. Poe: the case is about an injunction prohibiting enforcement of a state law against anyone, and the justices discuss the power to do this as a matter of equitable principles, leaving to one side the question of whether those principles are altered by the APA.
Here is where the justices fell:
