Even before the President’s executive actions on immigration have been implemented, there is a new development. On Monday, a federal district court in Texas issued a preliminary injunction blocking implementation of the new Deferred Action for Parental Accountability (DAPA) program and expansion of the Deferred Action for Childhood Arrivals (DACA) program. The original DACA program implemented in 2012 is unaffected. The injunction is temporary while the case State of Texas v. U.S.A. proceeds in federal court. The litigation was brought by 26 states objecting to the President’s executive action on immigration which was announced in late 2014 for implementation in 2015. The injunction affects only two of the areas addressed by the executive action (DACA expansion and DAPA). The Obama administration has announced that it will appeal the decision, and the immigration bar expects the decision will be overturned based the outcome of prior cases. But implementation of DAPA and the DACA expansion are postponed for now.