By Dara Kam ©2025 The News Service of Florida
TALLAHASSEE — Saying his original decision was too broad, a federal judge this week ruled that an injunction prohibiting the state from enforcing part of a 2023 law aimed at cracking down on illegal immigration should be limited to plaintiffs who challenged the measure.
The lawsuit, filed by the Farmworker Association of Florida and individual plaintiffs, focuses on part of the law that threatens felony charges for people who transport into Florida an immigrant who “entered the United States in violation of law and has not been inspected by the federal government since his or her unlawful entry.”
U.S. District Judge Roy Altman on May 22 sided with plaintiffs and granted a preliminary injunction blocking the part of the law, known as “Section 10,” from being enforced statewide. But the following day, the judge issued an order appearing to second-guess his decision and asked for “further briefing on the proper scope of the injunction.”
Altman on Tuesday curtailed his original order and specified that the preliminary injunction applies only to the individual plaintiffs, who are Andrea Mendoza Hinojosa, Carmenza Aragon and Maria Medrano Rios; the farmworker association; and the association’s members as of the date of the order. The association has about 12,000 members statewide, according to court documents.
Although statewide injunctions can be suitable in some instances, the judge wrote that such a broad injunction “isn’t appropriate in our case.”
Altman’s analysis relied, in part, on a concurring opinion by Justice Neil Gorsuch in a 2024 U.S. Supreme Court ruling in a case known as Labrador v. Poe. The Supreme Court decision scaled back a statewide injunction against an Idaho law that prohibited treatments such as puberty blockers and hormone therapy for transgender children and said the injunction should apply only to the two plaintiffs who challenged the law.
“It’s true that the alleged constitutional harm in our case is perhaps more expansive than the plaintiff-specific injuries at issue in Poe,” Altman wrote.
But the judge added that, when he issued his original ruling for a statewide injunction, he relied on a decision by the 11th U.S. Circuit Court of Appeals saying that “Congress has established an ‘overwhelmingly dominant federal interest in the field’ of unlawfully transporting aliens.”
Altman said he was guided in his revised ruling by Gorsuch’s more recent opinion in the Idaho case. Gorsuch relied on “the long-established maxim — a maxim we aren’t free to ignore — that ‘judicial power exists only to redress or otherwise to protect against injury to the complaining party,’” Altman wrote.
In a brief filed in June, lawyers for the plaintiffs urged Altman to keep his initial decision to block the law throughout Florida, saying there was “no way to fully protect” the association’s members from enforcement action while allowing enforcement against other people.
“Statewide relief is necessary to provide complete relief to the plaintiffs here, because there is no viable way to structure and enforce a more limited injunction that would fully protect the nearly 12,000 members of plaintiff Farmworker Association of Florida,” the plaintiffs’ lawyers argued.
The lawyers acknowledged the ongoing debate about the propriety of statewide injunctions but said that “every court to address the issue “has agreed that they are appropriate” when necessary.
But Altman disagreed this week.
“While we’re sympathetic to these concerns, we don’t think they justify a broader injunction in our case,” Tuesday’s order said.
The plaintiffs’ “fears that they might suffer accidental harm absent a statewide injunction and that a more tailored injunction might be non-administrable are highly speculative and would require us to ignore the bedrock principle ‘that the remedy issued (cannot be) ‘more burdensome to the defendant than necessary’” to provide relief to the plaintiffs, the judge said.
“So, while some of the plaintiffs have shown that they would suffer concrete harm if Section 10 were enforced against them … we disagree that expanding the scope of our injunction to include unidentified third-parties (many of whom may never have standing to sue and none of whom have elected to assert their claims here) would constitute a proper exercise of our jurisdiction,” Altman, who was appointed to the bench by President Donald Trump, said.
In a June brief, attorneys for the state argued that “no universal injunction is warranted here.”
“At best, only the individual plaintiffs have standing and a cause of action. The injunction therefore should not apply beyond them, whether nationwide, statewide, or even district-wide,” lawyers for the Florida attorney general’s office wrote.
But Altman’s ruling this week said the state’s arguments that the association should be cut out of the injunction were “unpersuasive” and put guardrails around who would be covered.
“To ensure that FWAF (Farmworker Association of Florida) is afforded complete relief — but mindful that an injunction shouldn’t be indefinite or harmful to the plaintiffs — our injunction will apply only to persons who can verify that they were active FWAF members as of the date of this order,” Altman said.
The 2023 law was part of a years-long effort by Gov. Ron DeSantis and the Republican-controlled Legislature to crack down on illegal immigration. Lawmakers met in a special session last month to pass a broad measure aimed at helping implement Trump’s deportation efforts.
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