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D issued a notice of proposed rulemaking that signaled its intent to adopt a new definition of 'public charge' for purposes of admissibility determinations. The Rule replaced the 1999 Field Guidance's definition of 'public charge,' which asked whether an alien was likely to become 'primarily dependent' on government assistance, with a durational threshold. Under the Rule, a 'public charge' is defined as 'an alien who receives one or more public benefits . . . for more than 12 months in the aggregate within any 36-month period.' The Rule jettisoned the 1999 Field Guidance's exclusive focus on cash benefits, instead providing that both cash and certain in-kind benefits count as 'public benefits' and can be considered in making public charge determinations. An alien's receipt of noncash benefits such as Section 8 housing, SNAP (i.e., food stamps), and certain Medicaid benefits would each count towards the 12-month threshold. the Rule enumerated a host of factors that DHS officials are to consider, in addition to those set forth in the INA, before determining whether a given alien is likely to become a 'public charge.' D received 266,077 public comments in just sixty days. D then spent the next ten months refining the Rule and responding to those comments. Many of the changes implemented during this period addressed specific comments received, and its detailed responses spanned nearly 200 pages of the Federal Register. In formulating the Rule's durationally specific definition of 'public charge,' D relied on several empirical analyses regarding patterns of welfare use in the United States, including studies conducted by the Census Bureau, the Department of Health and Human Services, and D itself. Studies indicated that a substantial portion of individuals who receive public benefits do so for fewer than 12 months, and that those who receive such benefits over a longer period are more likely to become 'long-term recipients' of welfare. D concluded that the 12-of-36-month threshold would best effectuate its three objectives in replacing the 'primarily dependent' standard, namely '(1) provid[ing] meaningful guidance to aliens and adjudicators, (2) accomodat[ing] meaningful short-term and intermittent access to public benefits, and (3) . . . not excus[ing] continuous or consistent public benefit receipt that denotes a lack of self-sufficiency.' The Rule retained the prevailing test that 'the determination of an alien's likelihood of becoming a public charge at any time in the future must be based on the totality of the alien's circumstances.' The Rule governs only public charge determinations made in the context of admissibility; deportations, by contrast, would still be decided under the 1999 Field Guidance and the three-part Matter of B- test. The Rule applied only to public charge inadmissibility determinations made by D, not the other two executive agencies (the Department of State and the Department of Justice) that are tasked with making public charge decisions in related contexts. Litigation followed immediately with most claiming the Rule violated both the Administrative Procedure Act (APA) and the Fifth Amendment to the United States Constitution. Two district courts issued preliminary injunctions barring enforcement of the Rule, one of which applied nationwide and the other of which applied only to persons residing in certain California counties as well as a number of states and the District of Columbia. A district judge in the Southern District of New York also issued two preliminary nationwide injunctions against the Rule, while another judge in the Northern District of Illinois enjoined enforcement of the Rule only within Illinois. The Ninth Circuit stayed the injunctions within its jurisdiction, concluding that 'D has shown a strong likelihood of success on the merits, that it will suffer irreparable harm, and that the balance of the equities and public interest favors a stay' pending appeal. The Second and Seventh Circuits declined to follow suit, and the Supreme Court eventually granted the government's emergency requests to stay the preliminary injunctions issued by both the Southern District of New York and the Northern District of Illinois. Five Justices of that Court necessarily concluded that the government had made 'a strong showing that [it was] likely to succeed on the merits.' Ps filed this lawsuit in Maryland. P is a non-profit organization that 'offers a wide variety of social, health, job training, employment, and legal services to the immigrant communities in Maryland, Washington, D.C., Virginia, and Pennsylvania.' The individuals, Aguiluz and Perez, are both P members who immigrated to the United States as children. Ds are federal officials charged with enforcing the Rule. Ps claim that the Rule violates both the APA and the Fifth Amendment. Ps claims that 'D lacks the statutory authority to reinterpret public-charge admissibility.' They claim the Rule is arbitrary and capricious, and violates the Due Process Clause and the Equal Protection Component of the Fifth Amendment. Ps moved for a preliminary injunction to block the Rule from going into effect. Ds claimed that Ps lacked standing and their case was not ripe for adjudication. The district court granted Ps' motion and enjoined Ds from enforcing the Rule nationwide. The district court concluded that P was an appropriate party to challenge the Rule who had Article III standing because the Rule could potentially harm its members, and P was thus forced 'to divert resources that otherwise would have been expended to improve the lives of its members' to combat the Rule's assertedly deleterious effects. The court held that P was likely to succeed on its APA claim that the Rule was 'not in accordance with law.' The court applied the two-step Chevron framework for analyzing agency interpretations of statutory provisions. The district court entered a preliminary injunction that applied nationwide, preventing Ds from enforcing the Rule against anyone. It provided three justifications for issuing such a broad remedy: (1) a nationwide injunction was necessary to provide complete relief to P because its members could be subject to public charge determinations outside of the district's geographic boundaries, (2) there is a particular need for uniformity in immigration law, and (3) that 'the ordinary remedy in APA challenges to a rulemaking is to set aside the entire rule if defective.' The district court also granted P's request to stay the effective date of the Rule during the pendency of this litigation. On motion by Ds, we stayed the district court's preliminary injunction by order dated December 9, 2019. Ds appealed.

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