S 1206119th CongressIn Committee

Judicial Relief Clarification Act of 2025

Introduced: Mar 31, 2025

Standard Summary

Comprehensive overview in 1-2 paragraphs

Judicial Relief Clarification Act of 2025 (S. 1206) would limit when and how courts can grant certain forms of relief, especially if the relief would affect people or entities that are not parties to a case. The bill adds a new provision prohibiting “non-party relief,” meaning courts could not issue orders such as injunctions, stays, vacatur, or declaratory or equitable relief that bind or compel action against someone who is not a party in the case unless the non-party is represented by a party acting in a representative capacity under the Federal Rules of Civil Procedure. It also tightens rules around temporary restraining orders (TROs), clarifies the handling of declaratory judgments, and narrows the scope of judicial review under the Administrative Procedure Act (APA) by limiting it to a “person” and by removing a court’s authority to set aside certain agency actions. The overarching aim appears to be restricting nationwide or broad, non-party relief and tightening who can seek or receive review of agency or administrative actions. In short, the bill seeks to curb nationwide injunctions and other relief that affect non-parties, require representative standing for non-party relief, curb certain TROs, and narrow court review of federal agency actions.

Key Points

1Non-party relief. Creates a new Sec. 2285 in Chapter 155 of Title 28 (non-party relief): no federal court (including territorial courts in the Virgin Islands, Guam, and the Northern Mariana Islands) may issue orders that bind or compel action for or against a non-party unless the non-party is represented by a party acting in a representative capacity under the Federal Rules of Civil Procedure.
2Territorial limits. The non-party relief rule explicitly covers the U.S. district courts in the Virgin Islands, Guam, and the Northern Mariana Islands, in addition to other courts.
3Temporary restraining orders. Amends 28 U.S.C. 1292(a) to add a new subsection limiting TROs: TROs cannot purport to restrain the enforcement of, or compel action with respect to, any statute, regulation, order, or executive action by the United States or by a state (and agencies/officers acting in official capacity). This aims to prevent TROs from halting broad federal or state actions.
4Declaratory judgments. Amends 28 U.S.C. 2201(a) so that the phrase “before the court” is inserted after “party,” potentially signaling a requirement that declaratory judgments be pursued through the court process in a specified manner.
5Judicial review (APA). Addresses Section 705 and Section 706 of the Administrative Procedure Act (5 U.S.C. 704-706):
6- Section 705: Qualification of standing/process limited to a “person,” as defined in 5 U.S.C. 551, before the court.
7- Section 706: Similar limiting language that a person may seek relief before the court, and striking the phrase “and set aside” from the standard to vacate or invalidate agency actions, potentially narrowing the remedies available to challenge agency decisions.
8General construction. Includes a rule that nothing in the Act should be construed to grant authority for relief that is prohibited by the Act, preserving the scope of the new prohibitions.

Impact Areas

Primary group/area affected- Individuals and organizations seeking nationwide or broad injunctive relief or other relief affecting non-parties (e.g., broad challenges to federal or state actions). Public interest groups, advocacy organizations, and industries that rely on nationwide injunctions would likely see the most direct impact.- Federal agencies and state governments who might face more constrained enforcement actions if TROs or injunctions cannot be used to halt actions affecting non-parties.Secondary group/area affected- Class actions or other representative litigation: the non-party relief provision relies on a “representative capacity” under FRCP; non-party relief could be blocked unless there is proper representation, potentially affecting how class actions are brought or defended.- Attorneys and litigants involved in administrative law and regulatory challenges, since APA-based judicial review would be narrowed and standing requirements tightened.Additional impacts- Ongoing or planned lawsuits seeking broad, nationwide injunctions or non-party relief could be affected; plaintiffs may need to adjust strategies to ensure relief is tied to represented parties.- The rule of construction could influence how courts interpret the reach of relief against agencies and officials, possibly affecting future decisions in administrative and regulatory cases.- The changes may raise questions about standing, due process, and the balance of powers between courts and the executive branch, as well as interactions with existing doctrines on national injunctions and standing.The bill was introduced in the Senate on March 31, 2025, by Senator Grassley and several co-sponsors. It is labeled as an introduction and would need committee action and passage in both chambers to become law.The terms “non-party relief,” “representative capacity,” and the narrowing of APA relief are technical; broadly, the bill aims to prevent courts from issuing orders that affect people or entities not properly represented in the case, and to curb broader or nationwide court interventions in administrative actions.

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