H.R. 1526, NORRA of 2025

H.R. 1526 would limit the ability of U.S. district courts to issue broad injunctive relief that applies to nonparties. (Nonparties are individuals or entities not directly involved in a legal case.) Under current law, parties often seek injunctive and other forms of relief in federal courts to challenge federal laws, executive actions, and regulations. Injunctions and certain other forms of relief issued by judges in those cases can sometimes apply to nonparties.

Under the bill, district courts could only issue injunctions that provide relief to parties participating in the case (and to nonparties that are represented by parties in the case, such as in a class action). In a case brought by two or more state governments located in different circuits, H.R. 1526 would allow for a three-judge panel to provide injunctive relief that would otherwise be prohibited by the bill.

H.R. 1526 would not block district courts from issuing other forms of relief that can affect nonparties. For example, a district court could still vacate an agency action, such as by setting aside a new regulation, which could have similar effects on nonparties as injunctive relief.

Because many federal actions, such as executive orders and regulations promulgated by agencies, affect direct spending, revenues, and spending subject to appropriation, CBO expects that enacting the bill could have significant budgetary effects, depending on the extent to which judges choose to rely instead on other types of relief like vacatur. CBO cannot predict what actions will be litigated or the decisions that judges will make. Accordingly, CBO has no basis for estimating the budgetary effects of H.R. 1526.

The CBO staff contact for this estimate is Jon Sperl. The estimate was reviewed by H. Samuel Papenfuss, Deputy Director of Budget Analysis.