On Friday, October 3, 2025, the U.S. Court of Appeals for the First Circuit delivered a resounding blow to President Donald Trump’s efforts to revoke birthright citizenship, ruling that his administration’s attempt to fundamentally alter one of the nation’s core constitutional principles is likely unconstitutional. The sweeping, 100-page opinion not only upheld a Boston district court’s injunction that blocked enforcement of Trump’s executive order, but also reaffirmed the nation’s longstanding tradition of granting citizenship to nearly all individuals born on American soil, regardless of their parents’ immigration status.
The case has been closely watched across the country, as legal challenges to the Trump administration’s executive order—one of the first he signed upon beginning his second term—have worked their way through the federal courts. According to CBS News, the executive order sought to deny birthright citizenship to children born in the United States to parents who are either undocumented immigrants or temporary visa holders, directly challenging the prevailing interpretation of the 14th Amendment to the Constitution. This amendment, ratified in 1868 in the wake of the Civil War, has long been understood to guarantee citizenship to virtually everyone born within U.S. borders.
Chief Judge David J. Barron, writing for the three-judge First Circuit panel, did not mince words in his assessment of the Trump administration’s arguments. As reported by Mediaite, Barron opened the opinion by invoking America’s “longstanding guarantees of birthright citizenship,” quoting the very first clause of the 14th Amendment: “All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside.” He further noted that Congress reinforced this principle nearly a century later with the passage of the Immigration and Nationality Act, which states that “a person born in the United States, and subject to the jurisdiction thereof” is a national and citizen of the United States.
“We see no reason to do so,” Barron wrote, rejecting the administration’s request to reverse the preliminary injunctions blocking the executive order. “The government was therefore wrong to argue that the plaintiffs are not likely to succeed in showing that the children that the [executive order] covers are citizens of this country at birth.” The opinion was joined by Judge Julie Rikelman and Judge Seth R. Aframe, both appointed by President Joe Biden, while Barron himself was appointed by President Barack Obama. The composition of the panel underscored the current political and judicial landscape, but the opinion itself was rooted in a deep reading of constitutional history and precedent.
In its analysis, the court drew direct lines between Trump’s executive order and previous attempts to restrict birthright citizenship—efforts now widely regarded as shameful chapters in American history. Chief among these were the infamous Dred Scott decision before the Civil War and the enforcement of the Chinese Exclusion Act, which the Supreme Court later repudiated in United States v. Wong Kim Ark. “Our nation’s history of efforts to restrict birthright citizenship... has not been a proud one,” Barron wrote. “Indeed, those efforts each have been rejected, once by the people through constitutional amendment in 1868 and once by the Court relying on that same amendment three decades later, and at a time when tensions over immigration also were high.”
The ruling’s historical perspective was not merely academic. The court made it clear that the “lessons of history” should make judges wary of “blessing this most recent effort to break with our established tradition of recognizing birthright citizenship and to make citizenship depend on the actions of one’s parents rather than—in all but the rarest of circumstances—the simple fact of being born in the United States.” According to Mediaite, Barron also emphasized that the legal question before the court was “not a difficult one,” despite the length and complexity of the opinion needed to address the government’s numerous arguments. “It is not, which may explain why it has been more than a century since a branch of our government has made as concerted an effort as the Executive Branch now makes to deny Americans their birthright,” he wrote.
Legal experts and commentators have noted that the court’s decision is not just a technical legal ruling, but a forceful rejection of a policy that, if implemented, would have fundamentally changed the meaning of citizenship in the United States. The decision also highlighted the role of the judiciary as a backstop against executive overreach, especially on issues touching the core of constitutional rights. As CBS News reported, federal judges in several states had previously blocked the Trump administration’s order from taking effect, and the Supreme Court had declined to rule on the merits earlier in the year, instead issuing nationwide injunctions to prevent the order’s enforcement.
The path to Friday’s ruling was anything but straightforward. In June 2025, the Supreme Court limited the ability of lower courts to issue nationwide injunctions, a move that briefly opened the door for the Trump administration to attempt enforcement of the executive order. However, subsequent rulings—including a July decision from the Ninth Circuit Court of Appeals—reinstated blocks on the policy, ensuring that children born in the United States to undocumented or temporary visa-holding parents would continue to be recognized as citizens.
The Trump administration had sought Supreme Court review in two separate cases: one brought by four states and another by parents whose children would be directly affected by the executive order. But the high court, as noted by CBS News, declined to address the core constitutional question, instead allowing lower court injunctions to stand and leaving the fate of birthright citizenship in the hands of the appellate courts.
The First Circuit’s opinion, however, leaves little doubt about the judiciary’s view on the matter. The ruling not only upholds the injunction but also unequivocally states that the Trump administration’s interpretation of the 14th Amendment is inconsistent with both constitutional text and more than a century of legal precedent. The court’s insistence on the simplicity of the legal question—despite the government’s attempts to complicate it—serves as a powerful reminder of the enduring strength of constitutional protections, even in the face of political pressure and shifting public sentiment.
As of now, the nationwide injunction blocking the Trump executive order remains firmly in place. The practical effect is that birthright citizenship, as enshrined in the 14th Amendment and reinforced by decades of statutory law, continues to be the law of the land. For the millions of families and children who would have been affected by the administration’s attempt to narrow citizenship rights, the First Circuit’s decision is a moment of relief and affirmation.
With the Supreme Court yet to weigh in on the merits, the legal battle over birthright citizenship may not be entirely over. But for now, the courts have spoken clearly: the simple fact of being born on American soil, not the immigration status of one’s parents, remains the foundation of American citizenship.
