Philadelphia Yearly Meeting of the Religious Society of Friends v. U.S. Department of Homeland Security

On August 18, 2026, the Fourth Circuit affirmed the preliminary injunction in a published opinion by Senior Judge Barbara Milano Keenan, joined by Judges Agee and Harris, with Judge Agee concurring. The court held that the plaintiffs have standing because the predicted decline in worship attendance is fairly traceable to the new policy and redressable by an injunction, that the district court did not abuse its discretion in finding the plaintiffs likely to succeed on their RFRA claim because the rescission substantially burdens their religious exercise, and that the government waived any strict-scrutiny defense by failing to present argument or evidence in the district court. The court did not reach the First Amendment claim. The preliminary injunction requiring DHS to follow its prior protected-areas guidance remains in effect.