On June 8, 2026, the U.S. District Court for the District of Massachusetts granted summary judgment in favor of the coalition of states that challenged the Trump Administration’s $100,000 H-1B visa payment requirement. The court in California v. Mullin held that the $100,000 fee – implemented through a presidential proclamation and agency guidance – was unlawful and vacated it.
The court concluded that the $100,000 fee functioned as a tax, not a permissible user fee, and that Congress had not delegated taxing authority to the President or the Executive Branch under the Immigration and Nationality Act. As a result, the policy violated separation-of-powers principles.
The court also found multiple Administrative Procedure Act violations, including failure to follow notice-and-comment rulemaking, exceeding statutory authority, and acting arbitrarily and capriciously. The decision emphasizes limits on executive authority to reshape the H-1B program through large financial conditions.