A federal appeals court has sided with Quaker, Baptist, and Sikh congregations challenging the Trump administration's reversal of protections against immigration enforcement near churches, a ruling that sharpens the collision between border security and religious liberty.

The U.S. Circuit Court of Appeals for the Fourth Circuit on Tuesday upheld a lower court injunction barring Immigration and Customs Enforcement from conducting arrests outside certain houses of worship while the underlying lawsuit proceeds. The ruling, written by Senior Circuit Judge Barbara Milano Keenan, found that the religious groups challenging the policy were "likely to succeed" under the Religious Freedom Restoration Act, the federal law that requires the government to clear a high bar before burdening the free exercise of religion.

The case traces back to January 21, 2025, one day after President Trump took office, when the Department of Homeland Security issued a memo reversing a longstanding policy that had discouraged immigration officials from making arrests "in or near so-called 'sensitive' areas," including churches, schools, and hospitals. Religious groups sued, a district court blocked the new policy, and the administration appealed. Now the Fourth Circuit has told the administration, in effect: not so fast.

RFRA's strict standard proved too high for the administration to clear

The court's reasoning turned on RFRA, the Religious Freedom Restoration Act, which says the government must demonstrate a "compelling interest" and use "the least restrictive means" available before it can substantially burden someone's religious exercise. The Fourth Circuit held that the administration failed on both counts with respect to the 2025 policy.

Christianity Today reported that Judge Keenan's opinion framed the stakes in direct terms:

"Whether it's to sit in expectant waiting, to deliver or receive a weekly sermon... communal worship is fundamental to the religious exercise of many."

The ruling went further, describing ICE agents parking outside religious services or arresting congregants as "anathema" to the plaintiffs' religious exercise. And the court stated flatly that "'attending religious services' is 'at the very heart' of the 'guarantee of religious liberty'", and that "if the government is going to impede that guarantee, it must meet the strictest of justifications. With respect to the 2025 policy, it cannot."

That is strong language from a federal appeals court. But it is also, critically, a preliminary ruling. The Fourth Circuit did not decide the merits of the case. It upheld an injunction, a temporary hold, while the lawsuit continues in the lower court. And the injunction applies only to the named plaintiffs: six Quaker meetings, a Cooperative Baptist Fellowship in Georgia, and a Sikh temple in Sacramento, California.

Congregations report falling attendance and locked doors

The plaintiffs painted a picture of real harm. A concurrence in the ruling noted a "pocketbook injury", contributions dropped along with attendance at some houses of worship after the 2025 policy took effect. Some churches locked their doors entirely. The Cooperative Baptist Fellowship's original lawsuit filing argued that "in the faces of immigrants and refugees who are fleeing political or religious persecution... Baptists see nothing less than the face of Jesus."

Chris Mohr, general secretary of the Philadelphia Yearly Meeting of the Religious Society of Friends, one of the Quaker bodies in the case, told Christianity Today that the policy had a direct chilling effect on worship.

"If some of our members are dissuaded from coming to worship because they fear the presence of law enforcement in our house of worship, that hampers the fullness of our ability to worship."

Mohr belongs to an "unprogrammed" Quaker meeting tradition, a form of worship built around communal silence and expectant waiting rather than sermons, a practice the court's opinion specifically acknowledged. The broader question of how the federal government navigates religious liberty protections continues to create legal battles across multiple fronts.

Paul Baxley calls the decision a 'powerful affirmation' of Baptist principles

Paul Baxley, pastor and executive coordinator of the Cooperative Baptist Fellowship, framed the ruling in explicitly Baptist terms, calling it a "powerful affirmation" of Baptists' "steadfast commitment to religious liberty, local church autonomy, and the clear separation of church and state."

Skye Perryman, president and CEO of Democracy Forward, the litigation nonprofit that represented the plaintiffs, issued a sharper statement aimed at the administration:

"This decision reaffirms that the Trump-Vance administration cannot force people of faith to abandon their ministries or make people worship under the constant threat of indiscriminate enforcement activities."

Jeremy McKinney, an attorney and former president of the American Immigration Lawyers Association who identifies as Methodist, argued that "the constitutional right to exercise religious liberty applies to all people, regardless of citizenship status." McKinney expressed hope that Christians across the political spectrum would view these cases through a religious liberty lens rather than a strictly partisan one.

Multiple lawsuits are boxing in the administration's enforcement policy

This is not an isolated case. Earlier in 2026, another court blocked enforcement of the same 2025 DHS policy for a separate group of Lutheran, Quaker, and Baptist congregations that had filed their own lawsuit. The Fourth Circuit's latest ruling adds to a growing pattern of federal courts pushing back against the administration's approach.

A separate, similar lawsuit filed by 27 Christian and Jewish groups is moving through the U.S. District Court for the District of Columbia. In that case, however, the judge denied the plaintiffs' request for a preliminary injunction, a split outcome that suggests the legal landscape is far from settled.

The administration's lawyers have been quick to appeal lower court losses to the Supreme Court in other contexts, and whether this case follows that path remains an open question. The ruling's limited scope, applying only to the named plaintiffs, not to all houses of worship nationwide, may factor into that calculation. In other arenas where religious liberty and federal authority collide, the high court has increasingly become the final arbiter.

A genuine tension conservatives should not wave away

For readers who support strong border enforcement, and this publication is firmly among them, this case presents an uncomfortable but honest tension. The rule of law demands that illegal immigrants face consequences for violating immigration statutes. But it also demands that the government not trample religious liberty in the process. RFRA exists precisely because Congress recognized that federal power, even when exercised for legitimate purposes, can crush the free exercise of faith if left unchecked.

The Fourth Circuit did not say the government can never enforce immigration law. It said the government has to justify burdening worship under the strictest legal standard, and that, so far, it has not done so. That is not a radical proposition. It is the same principle conservatives invoke when the government tries to force religious organizations to fund abortions or compel churches to host events that violate their doctrine.

Around the world, believers face far graver threats. In China, authorities have raided house church services and detained pastors and children. Americans rightly condemn those actions. The principle that government agents should not be able to turn a Sunday service into an enforcement operation is not a liberal invention, it is a bedrock American commitment.

None of this means churches should become sanctuaries for lawbreaking. But the government has tools to enforce immigration law without stationing agents outside worship services. If the administration believes otherwise, it needs to make that case under the law Congress wrote, not simply assert its authority and expect the courts to salute.

Religious liberty is either a principle or a convenience. Conservatives who treat it as the former should be able to hold two truths at once: borders matter, and so do church doors.