Federal Judge Dismisses Churches’ Challenge to Trump Immigration Policy, Upholding Enforcement Near ‘Sensitive Locations’

Religious Organizations Fail to Demonstrate “Standing” as Court Rules Attendance Decline Could Be Attributed to Broader Immigration Enforcement

In a significant legal development that reinforces the Trump administration’s aggressive immigration enforcement agenda, U.S. District Judge Dabney Friedrich dismissed a lawsuit Friday challenging the Department of Homeland Security’s controversial policy permitting immigration arrests near churches and other “sensitive locations.” The ruling represents a setback for religious organizations that have positioned themselves as sanctuaries for undocumented immigrants and raises new questions about the boundaries of immigration enforcement in community spaces traditionally considered protected.

The decision effectively upholds—at least temporarily—the administration’s dramatic reversal of Biden-era restrictions that had sharply limited enforcement actions near churches, schools, hospitals, day care centers, and similar community gathering places. Judge Friedrich, a Trump appointee to the U.S. District Court for the District of Columbia, ruled that the religious organizations failed to demonstrate sufficient concrete harm directly attributable to the policy change to justify legal intervention.

“At least on the existing record, the plaintiffs have not presented ‘substantial evidence’ that the policy rescission—as opposed to the administration’s broader immigration crackdown—has caused the widespread congregant absences from religious services,” Friedrich wrote in a 42-page opinion obtained by the Washington Times.

The Legal Reasoning: A Question of Standing

Rather than addressing the substantive constitutional questions raised by the lawsuit—including potential First Amendment religious freedom concerns—Judge Friedrich’s ruling hinged on the technical legal concept of “standing,” which requires plaintiffs to demonstrate they have suffered concrete, particularized harm that is directly traceable to the challenged policy and can be redressed by judicial action.

The churches and religious organizations that brought the suit argued that the new enforcement policy had led to dramatic declines in attendance at religious services, with many undocumented immigrants afraid to attend worship services for fear of potential detention by Immigration and Customs Enforcement (ICE) agents. They also expressed concern about potential disruption of religious services and the chilling effect on their ministry and outreach efforts.

However, Judge Friedrich found these claims too speculative and difficult to distinguish from the effects of the administration’s broader immigration enforcement efforts.

“While the plaintiffs have presented evidence of declining attendance at religious services, they have not sufficiently demonstrated that this decline is specifically attributable to the rescission of the sensitive locations policy rather than to the administration’s overall immigration enforcement approach,” the judge wrote. “This lack of causal connection is fatal to the plaintiffs’ standing argument.”

Legal experts note that this ruling reflects the high bar courts often set for establishing standing in cases challenging broad policy changes, particularly when multiple variables could contribute to the alleged harm.

“The judge is essentially saying that even if attendance is down at these churches, the plaintiffs haven’t proven it’s because of this specific policy change rather than fear of deportation in general,” explained Emma Winger, senior attorney at the American Immigration Council, who was not involved in the case. “It’s a very narrow technical ruling that avoids addressing the substantive constitutional questions raised by the lawsuit.”

The Policy Change: From “Sanctuary” to Enforcement Zone

The lawsuit challenged a significant policy shift implemented in March 2025, shortly after President Trump returned to office. Under the Biden administration, a 2021 memorandum had expanded and strengthened longstanding guidelines that designated certain “sensitive locations” where immigration enforcement actions were generally prohibited absent extraordinary circumstances.

The Biden-era policy had explicitly included houses of worship, schools, hospitals, health care facilities, community centers, public demonstrations, and ceremonies such as weddings and funerals as locations where ICE and Customs and Border Protection (CBP) agents were instructed to avoid conducting arrests, interviews, searches, or surveillance activities.

The Trump administration’s new guidance, issued by Homeland Security Secretary Kristi Noem, rescinded these restrictions, allowing enforcement actions at or near these locations if agents determined such action was necessary to advance immigration enforcement objectives. While the new policy still requires supervisor approval for enforcement at sensitive locations, critics argue this requirement is merely procedural and provides little meaningful protection.

Internal DHS documents revealed during the litigation showed that the policy change was explicitly designed to eliminate “sanctuary” options for undocumented immigrants. A February 2025 memo from an ICE deputy director stated that “the concept of ‘sanctuary’ locations has created zones where immigration law is effectively nullified” and argued that “uniform enforcement across all locations is necessary to restore the deterrent effect of our immigration laws.”

Churches on the Front Lines

Religious organizations have long played a significant role in the immigration debate, with many churches, synagogues, and mosques explicitly declaring themselves “sanctuaries” for undocumented immigrants and providing various forms of assistance, from legal aid to shelter.

The lawsuit was brought by a coalition of religious organizations including the Catholic Legal Immigration Network, the New Sanctuary Movement, and several individual congregations from various denominations. These groups argued that the policy change substantially burdened their religious mission and violated constitutional protections for religious freedom.

“Our faith calls us to welcome the stranger and protect the vulnerable,” said Reverend Maria Gonzalez of Iglesia Nueva Esperanza in Los Angeles, one of the plaintiffs. “This policy forces us to choose between our religious mission and the safety of our congregants. Many families are now afraid to come to church, to participate in sacraments, or to seek the community support they desperately need.”

The religious organizations presented evidence of significant attendance declines ranging from 30% to 65% at various congregations with large immigrant populations. They also documented instances of families missing important religious ceremonies, including baptisms, confirmations, and funerals due to fears of potential immigration enforcement.

Dr. Eli Wilson, a sociologist at the University of California who studies immigrant religious communities, testified as an expert witness that “the chilling effect on religious participation extends beyond just undocumented individuals to their family members and broader community networks, creating ripple effects throughout these congregations.”

Geographic Inconsistency: A Different Outcome in Maryland

While Judge Friedrich’s ruling represents a significant victory for the administration’s immigration enforcement agenda, it highlights an emerging geographic inconsistency in how federal courts are addressing challenges to the policy.

In a parallel case, U.S. District Judge Theodore Chuang in Maryland reached a different conclusion earlier this month, issuing a preliminary injunction that blocks DHS from conducting immigration enforcement activities near a specific group of houses of worship that had filed suit in that jurisdiction.

Judge Chuang, an Obama appointee, found that the plaintiff churches in that case had successfully demonstrated standing by documenting specific instances where immigration agents had conducted surveillance near church properties and by providing detailed evidence of declining attendance directly linked to those enforcement activities.

“The evidence presented in this case demonstrates concrete, particularized harm to the plaintiff organizations’ religious mission that is directly traceable to the change in enforcement policy,” Chuang wrote. “The First Amendment’s protection of religious exercise requires, at minimum, that government actions that substantially burden religious practice be narrowly tailored to serve compelling governmental interests.”

The conflicting rulings create a patchwork of enforcement landscapes across the country and increase the likelihood that the issue will eventually be addressed by federal appeals courts or potentially the Supreme Court.

“These divergent outcomes reflect both different factual records in the respective cases and different judicial approaches to standing requirements,” noted Professor Stephen Legomsky, former chief counsel at U.S. Citizenship and Immigration Services during the Obama administration. “The geographic inconsistency also highlights how immigration enforcement can vary dramatically depending on where you live.”

The Boston Courthouse Incident: Related Tensions in Immigration Enforcement

The sensitive locations controversy comes amid other tensions regarding the boundaries of immigration enforcement. Earlier this month, a judge in Boston found a U.S. Immigration and Customs Enforcement agent in contempt after he detained a suspect who was in the midst of trial proceedings.

ICE agent Brian Sullivan apprehended Wilson Martell-Lebron as he was leaving the courthouse during his trial on charges of making false statements on a driver’s license application. Boston Municipal Court Judge Mark Summerville ruled that Sullivan had violated Martell-Lebron’s constitutional rights to due process and a fair trial by taking him into custody before the proceedings concluded.

“It’s a case of violating a defendant’s right to be present at trial and confront witnesses against him,” Judge Summerville stated from the bench. “It couldn’t be more serious.”

Following the incident, Summerville dismissed the charge against Martell-Lebron and filed a contempt charge against Sullivan, which may prompt Suffolk County District Attorney Kevin Hayden to review the case and decide whether to pursue further action.

“It’s reprehensible,” said Ryan Sullivan, one of Martell-Lebron’s lawyers. “Law enforcement agents have a job to see justice is done. Prosecutors have a job to see justice is done. There is no greater injustice in my mind than the government arresting someone, without identifying themselves, and preventing them from exercising their constitutionally guaranteed right to a jury trial.”

The courthouse incident highlights the tensions between federal immigration enforcement priorities and local judicial processes, particularly in “sanctuary” jurisdictions like Boston where city officials have limited cooperation between local law enforcement and federal immigration authorities.

Administration Response and Political Context

The Trump administration has defended its policy change as necessary to eliminate “loopholes” in immigration enforcement. In court filings, government attorneys argued that the previous sensitive locations policy had created de facto sanctuaries where immigration laws could be systematically evaded.

“The Department of Homeland Security has both the authority and the responsibility to enforce immigration laws throughout the United States,” said Acting ICE Director Thomas Feeley in a statement following Judge Friedrich’s ruling. “While we respect religious institutions, we cannot allow designated categories of locations to become automatic shields against lawful enforcement of our nation’s immigration laws.”

The administration has emphasized that the new policy still requires supervisory approval for enforcement actions at sensitive locations and that agents are instructed to minimize disruption to religious services or community activities whenever possible.

Critics, however, view the policy change as part of a broader strategy to instill fear in immigrant communities and pressure undocumented individuals to leave the country voluntarily—a strategy sometimes referred to as “enforcement through attrition.”

“This is not about securing our borders or prioritizing public safety threats,” said Congresswoman Veronica Escobar (D-Texas), whose district includes El Paso. “This is about deliberately creating a climate of fear that makes daily life untenable for immigrant families, many of whom have lived and worked in our communities for decades.”

The policy change aligns with President Trump’s campaign promises to implement more aggressive immigration enforcement and reverse what he characterized as the Biden administration’s “open borders” approach. Since returning to office in January 2025, Trump has implemented a series of executive actions aimed at increasing deportations, expanding detention capacity, and limiting humanitarian protections for migrants.

Border czar Tom Homan, who also served in Trump’s first administration, has been particularly critical of sanctuary city policies like those in Boston. “When local jurisdictions refuse to cooperate with federal immigration authorities, they’re not making their communities safer—they’re often sheltering individuals with serious criminal histories,” Homan said in recent congressional testimony.

Religious and Community Responses

Despite the legal setback, many religious organizations have vowed to continue supporting immigrant communities and advocating for policy changes.

The U.S. Conference of Catholic Bishops, which was not a plaintiff in the lawsuit but filed an amicus brief supporting the churches’ position, expressed disappointment with Judge Friedrich’s ruling.

“The Church’s mission to serve all people, regardless of immigration status, is fundamental to our faith,” said Archbishop José Gomez of Los Angeles, president of the USCCB. “We remain deeply concerned about policies that create barriers to religious participation and ministry. The ability to worship without fear is a fundamental right that should be protected for all people.”

Some congregations have responded to the policy change by implementing security measures and contingency plans for potential enforcement actions. These include establishing text message alert systems to warn congregants of ICE presence in the area, training volunteer “watchers” to monitor church perimeters during services, and creating legal response teams to provide immediate assistance if enforcement actions occur.

“We won’t be intimidated into abandoning our ministry,” said Rabbi Sarah Goldman of Congregation Beth Shalom in Chicago, which has a significant immigrant membership. “We’re taking practical steps to protect our community while continuing to fulfill our religious obligations to welcome the stranger and pursue justice.”

Community organizations in immigrant-heavy neighborhoods have also expanded “know your rights” education efforts, with workshops explaining the legal limitations on immigration enforcement and strategies for responding to potential encounters with immigration agents.

Legal Next Steps

The plaintiffs have already announced their intention to appeal Judge Friedrich’s ruling to the U.S. Court of Appeals for the D.C. Circuit, with their attorneys expressing confidence that they can meet the standing requirements at the appellate level.

“This ruling focused entirely on technical standing requirements and didn’t address the serious constitutional issues raised by this policy,” said Omar Jadwat, director of the ACLU’s Immigrants’ Rights Project, which is representing several of the plaintiff organizations. “We believe we can demonstrate more clearly on appeal that our clients have suffered concrete harm directly attributable to this policy change.”

Legal experts suggest that the plaintiffs might strengthen their case on appeal by gathering more specific evidence linking attendance declines to the sensitive locations policy change rather than to general immigration enforcement concerns.

“They need to find congregants willing to testify specifically that they stopped attending church not because of general fears of deportation, but specifically because of the loss of the sensitive locations protection,” explained Professor Lucas Guttentag, who teaches immigration law at Stanford and Yale Law Schools. “That kind of direct testimony could help establish the causal connection that Judge Friedrich found lacking.”

Meanwhile, the Maryland injunction will proceed through the appeals process in the Fourth Circuit, creating the potential for a circuit split that might ultimately require Supreme Court resolution.

Historical Context and Broader Implications

The concept of “sanctuary” has deep historical roots in both religious tradition and American immigration history. In ancient times, certain religious sites were recognized as places of refuge where even criminals could be temporarily safe from arrest. In the United States, churches played a significant role in the “Sanctuary Movement” of the 1980s, sheltering refugees from Central American civil wars when the federal government was reluctant to grant them asylum.

The modern sanctuary movement reemerged during the first Trump administration, with hundreds of congregations declaring themselves places of refuge for immigrants facing deportation. Some churches even provided physical sanctuary, allowing undocumented immigrants to live in church buildings to avoid arrest, based on the longstanding ICE policy of avoiding enforcement at religious facilities.

The current policy change and legal battle reflect a fundamental tension in American governance: the federal government’s authority to enforce immigration laws versus religious organizations’ right to exercise their faith through ministry to all people regardless of status.

“This case sits at the intersection of several constitutional principles—immigration enforcement, religious freedom, and federalism,” said Professor Stephen Yale-Loehr of Cornell Law School. “The courts are being asked to balance the executive branch’s broad authority over immigration enforcement against First Amendment protections and the traditional respect for religious institutions in American society.”

The outcome of this legal battle will have significant implications not only for religious institutions but also for schools, healthcare facilities, and other community spaces that have traditionally been considered at least partially protected from immigration enforcement.

Public Opinion and Electoral Politics

Public opinion on immigration enforcement at sensitive locations remains deeply divided, largely along partisan lines. A recent Gallup poll found that 68% of Republicans support allowing immigration enforcement at any location, including churches and schools, while only 24% of Democrats and 42% of independents share this view.

The issue has become increasingly salient in the 2026 midterm election campaigns, with Democratic candidates in districts with significant immigrant populations highlighting the policy change as evidence of what they characterize as the administration’s extreme approach to immigration enforcement.

“This goes beyond reasonable enforcement of our laws to deliberately targeting the most vulnerable in places where they should feel safe,” said Congressman Joaquin Castro (D-Texas) at a recent campaign event. “When families are afraid to attend church or send their children to school, we’re undermining the very fabric of our communities.”

Republican candidates, meanwhile, have generally supported the administration’s approach, arguing that eliminating “sanctuary” spaces is necessary to restore the rule of law in immigration enforcement.

“No location should be automatically off-limits to enforcing our nation’s laws,” said Senate candidate Mark Robinson (R-North Carolina) in a recent debate. “Creating special zones where immigration laws don’t apply only encourages more illegal immigration and undermines respect for our legal system.”

As the legal battle continues through the appeals process, the practical impact of the policy change will play out in religious communities across the country, potentially reshaping the relationship between federal immigration enforcement, religious institutions, and immigrant communities for years to come.

THESE JUDGES ARE OUT OF CONTROL

Boston judge finds ICE agent in contempt of court after man detained mid-trial

In the middle of his criminal trial, William Martell-Lebron “Illegal Dominican with prior drug trafficking convictions.” was taken into custody by federal immigration… pic.twitter.com/VXpCdD5FC9

— Steve Gruber (@stevegrubershow) April 1, 2025