Fourth Circuit Upholds Injunction Blocking DHS Enforcement Near Houses of Worship
The Fourth Circuit upheld an injunction blocking DHS immigration enforcement near 1,400+ worship sites.
Why it matters: This ruling protects religious sanctuaries from immigration enforcement, reflecting tensions between federal policy changes and religious freedom protections under the Religious Freedom Restoration Act (RFRA). It signals limits on DHS enforcement near places of worship across multiple states.
- Injunction covers over 1,400 houses of worship across 33 states and D.C., including Quaker meetings, Sikh Temple Sacramento, and Cooperative Baptist Fellowship.
- The 2025 DHS policy replaced a hard prohibition on enforcement near sensitive sites with discretionary guidance, prompting attendance drops at affected congregations.
- The Fourth Circuit found the DHS policy likely burdens religious exercise under RFRA, upholding a preliminary injunction from February 2025.
- Plaintiffs argue the ruling protects sacred spaces from enforcement disruption; DHS states criminals should not evade arrest in schools or churches.
On August 18, 2026, the U.S. Court of Appeals for the Fourth Circuit upheld a preliminary injunction blocking DHS immigration enforcement at or near specific houses of worship affiliated with Quaker, Sikh, and Cooperative Baptist groups. The injunction was originally issued by a district court in February 2025.
The plaintiffs represent six Quaker meetings, the Sikh Temple Sacramento—which serves roughly 30,000 members—and the Cooperative Baptist Fellowship, comprising nearly 750,000 Baptists nationwide. Collectively, their faith communities include over 1,400 worship sites across 33 states and the District of Columbia.
Central to the dispute is a 2025 Department of Homeland Security policy that removed previous strict limits on immigration enforcement near "sensitive locations" such as places of worship and schools. Instead of a flat ban, the policy advises officers to exercise discretion and "a healthy dose of common sense" when conducting enforcement activities.
The court concluded this policy likely imposes a substantial burden on religious exercise, violating the Religious Freedom Restoration Act (RFRA), which bars the government from substantially burdening religious practice without a compelling interest pursued in the least restrictive way. Plaintiffs argued enforcement actions deter immigrant congregants from attending services and force worship groups into conflicts with their beliefs.
Representing the plaintiffs' coalition, one statement said, "This decision reaffirms a fundamental promise of religious liberty: every person should be able to gather, worship, pray, and serve their community without fear that immigration enforcement will unlawfully disrupt sacred spaces."
A DHS spokesperson responded, saying, "Criminals will no longer be able to hide in America's schools and churches to avoid arrest," emphasizing the need for effective enforcement despite sensitivities.
This ruling illustrates ongoing legal tensions between immigration enforcement authority and protections for religious sanctuaries. It remains unclear whether DHS will seek further appeals or adjust its enforcement policies to comply with the injunction.
By the numbers:
- 1,400+ houses of worship — covered by the injunction across 33 states and D.C.
- February 2025 — district court first issued the injunction blocking DHS enforcement
- August 18, 2026 — Fourth Circuit upheld the injunction
- 30,000 members — Sikh Temple Sacramento congregation size
Yes, but: While the court found the DHS policy likely violates RFRA, the injunction is preliminary and the government could appeal or modify the policy to address the court's concerns.
What's next: DHS could appeal the Fourth Circuit ruling to the Supreme Court or issue revised enforcement guidelines balancing immigration objectives and religious freedoms.