In a key DC judge ICE ruling, U.S. District Judge Dabney L. Friedrich declined on Friday to block immigration enforcement actions by ICE at places of worship, denying a preliminary injunction sought by a coalition of religious organizations challenging the Trump administration’s immigration policy shift.
The lawsuit, brought by 27 Christian and Jewish groups representing millions of congregants, argued that the administration’s rollback of protections for sensitive locations like churches and synagogues created a chilling effect on religious practice. The plaintiffs claimed violations of the First Amendment and the Religious Freedom Restoration Act (RFRA).
Judge Friedrich ruled that the religious groups had not demonstrated a credible and imminent threat of enforcement at their places of worship “at least at this juncture.” The judge also concluded that the plaintiffs lack standing, as the challenged directives do not specifically instruct ICE agents to target religious institutions or prioritize them for enforcement actions.
“Since the policy rescission took effect over 10 weeks ago, only one enforcement action has taken place at the hundreds of plaintiffs’ member congregations,” the ruling stated. The judge added that only three total enforcement actions have occurred near any place of worship nationwide since January 20, 2025, further weakening the plaintiffs’ claim of imminent harm.
The court also found insufficient evidence that ICE’s surveillance activities near some churches were directly linked to planned raids or arrests.
Judge Friedrich emphasized that DHS’s revised guidance amounts to a “modest change” and does not mandate enforcement during worship services. “Absent evidence of specific directives to immigration officers to target plaintiffs’ places of worship, or a pattern of enforcement actions, the court finds no credible threat of imminent enforcement,” she wrote.
While acknowledging the plaintiffs’ concerns about decreased attendance and fear among congregants, Judge Friedrich concluded that the evidence does not clearly connect these trends to the specific policy change, rather than to broader immigration enforcement efforts.
The plaintiffs, represented by the Institute for Constitutional Advocacy and Protection, had requested the court to reinstate protections that have been in place for decades, which restricted enforcement in so-called “sensitive locations” without a judicial warrant or exigent circumstances. The coalition argues that the administration failed to follow proper rulemaking procedures in implementing the new guidance.
The case is Mennonite Church USA et al. v. Department of Homeland Security et al., Case No. 1:25-cv-00403, pending in the U.S. District Court for the District of Columbia.
