Philadelphia Yearly Meeting v. DHS (Sensitive Locations)

[ARCHIVED-September 2025]  

Forward brought this case on behalf of Quaker meetings across 12 states and the District of Columbia to challenge DHS’s rescission of the so-called “sensitive locations” memo, which had codified long-standing government policy to refrain from conducting immigration enforcement actions in “sensitive locations,” including places of worship.

On January 20, 2025, the Department of Homeland Security (DHS) issued a memo that superseded and rescinded government policy, most recently reaffirmed in a 2021 DHS memo, not to conduct immigration enforcement in “sensitive locations.” The 2025 memo said that it was not necessary for DHS “to create bright line rules regarding where our immigration laws are permitted to be enforced.” Rather, noting that immigration officers “frequently apply enforcement discretion,” the memo instructed law enforcement officers to “continue to use that discretion along with a healthy dose of common sense.” The memo was publicized on January 21 in a Fox News report and a DHS press statement. It was subsequently leaked on January 23.

The Plaintiffs have since amended their complaint to add a Baptist fellowship and a Sikh temple as plaintiffs, and filed a motion for a Temporary Restraining Order and Preliminary Injunction on Feb. 4, 2025. The court granted the Plaintiffs’ motion on February 24, 2025, issuing an injunction that prevents the federal government from applying the “common sense” memo to Plaintiffs.  

The federal government filed a notice of appeal of the court’s preliminary injunction on April 24, 2025 - just a day within the deadline for it to appeal. On the same day, it also filed a partial motion to dismiss the Plaintiffs’ claims brought under the Administrative Procedure Act.