Legend (scope-of-relief shorthand):

• 🔴 Plaintiffs-only relief (guaranteed = named plaintiffs)
• 🟠 Class-limited relief (guaranteed = certified class)
• 🟡 Policy-wide remedy requested (guaranteed = plaintiffs; non-plaintiffs only if class/broader order)
• 🟢 Reserved: truly “everyone affected” coverage (e.g., certified class of all affected or an order explicitly written to cover all)
• Court level: District Court (N.D. Illinois, Eastern Division)
• Case: John Doe v. USCIS, et al., 1:26-cv-02389
• Judge: U.S. District Judge Sara L. Ellis
• Source: TRO Order, Doc. 33 (Filed 03/26/2026)

TL;DR

• Judge Sara L. Ellis granted a TRO for one plaintiff in an individual employment-based case challenging PM-602-0192 / PM-602-0194.
• The Court enjoined USCIS from applying the adjudication hold to this plaintiff’s pending:
  • I-485
  • I-765
  • I-131
  • I-485 Supplement J
• The Court also ordered defendants to adjudicate the pending forms, inform the plaintiff of the decision, and if denied, explain the reasons.
• Important: this is 🔴 plaintiffs-only relief, not a class action and not a system-wide order lifting the pause for everyone.

What happened

1) The case

This is an individual lawsuit filed by an Iranian plaintiff in lawful status who had pending employment-based immigration filings, including adjustment of status and related forms.

The plaintiff argued that the USCIS hold under PM-602-0192 and PM-602-0194 was unlawfully blocking adjudication of his pending applications.

2) The judge granted a TRO

Judge Ellis granted the plaintiff’s motion for a temporary restraining order and specifically ordered that defendants are:

• enjoined from applying the adjudication hold of PM-602-0192 and PM-602-0194 to this plaintiff’s pending:
  • Form I-485
  • Form I-765
  • Form I-131
  • Form I-485 Supplement J

The Court further ordered defendants to:

• adjudicate the pending forms
• inform the plaintiff of the decision
• and, if denied, provide the reasons for denial

3) Why the judge said the plaintiff had a sufficient chance of success

The Court’s reasoning was important.

Judge Ellis said the challenge was not to the ultimate discretionary grant or denial of adjustment itself, but to the categorical adjudicatory hold. The Court concluded there was at least some likelihood of success on the APA claim because:

• the Policy Memoranda looked like final agency action
• the adjudication hold appeared likely arbitrary and capricious
• the government had not adequately explained why such a broad hold was necessary for someone like this plaintiff, who had already been lawfully present in the U.S. for years
• and the hold created serious practical harms

The Court also rejected the idea that this was just an unreviewable timing dispute. It said the court could review the legality of the categorical hold, even if it could not generally micromanage ordinary agency timing decisions.

4) Why the Court found irreparable harm

The judge found that without relief, the plaintiff was facing immediate and serious consequences:

• loss of employment
• possible inability to remain lawfully in the U.S.
• inability to make life decisions
• emotional strain
• inability to travel

That was enough for the Court to conclude TRO relief was warranted.

What does this mean for people affected by PM-602-0192 / PM-602-0194?

This is a good result for the plaintiff, but it is not a general unfreeze.

What it means:

• another federal judge has now granted individual relief against the PM-602-0192 / 0194 adjudication hold
• the order shows at least one court is willing to say the hold likely functions as a reviewable final agency action
• and that the hold may be vulnerable under the APA arbitrary-and-capricious standard

What it does not mean:

• it does not automatically lift the hold for everyone
• it does not create class-wide relief
• it does not mean all employment-based applicants now move automatically
• it does not mean USCIS lost the entire policy nationwide

So the practical reading is:

• important precedent / persuasive reasoning
• but direct relief only for this plaintiff

Scope-of-relief reminder (CASA-safe)

• This case is 🔴 plaintiffs-only
• The TRO protects John Doe, not everyone affected by PM-602-0192 / PM-602-0194
• Post-CASA, do not assume that because one plaintiff wins a TRO, non-plaintiffs are covered too

Why this case is especially notable

A few things stand out here:

• this is an employment-based case, not just a parole / humanitarian-benefits context
• the judge explicitly treated the adjudication hold as something courts can review as a categorical policy
• the judge found that USCIS had not sufficiently justified using such a broad hold against someone who had already been lawfully present in the U.S. for a long time
• the Court gave real operational relief: stop applying the hold to him and adjudicate the forms

That makes this a significant case to watch, even though the relief is still individual.

Next checkpoints

• Watch for whether the government:
  • seeks reconsideration,
  • appeals,
  • or complies and adjudicates the plaintiff’s forms
• Watch whether this reasoning gets cited in:
  • other individual pause lawsuits
  • broader PM-602-0192 / 0194 litigation
  • any later PI or merits rulings