Application 26A305 for a stay of the September 4 injunction

… Government is likely to suffer irreparable harm without a stay” “[b]ecause reversal of the District Court’s judgment” against implementation of the final Rule “would come too late for the 2026 midterms.” California, 2026 WL, 2473573, at *4. North Carolina presumably has already begun mailing ballots on September  30 4, and Alabama will begin mailing ballots this week, on September 9.2 At least five more States will begin mailing ballots the following week, and more than a dozen others will begin by the end of this month.3 Because the district court’s injunction prohibits the government from verifying compliance with the Rule’s requirements, it will permanently bar the Rule’s operation with respect to any ballots mailed before a stay issues. In fact, because the injunction bars USPS from training its employees to conduct the verification process, see p. 12, supra, it will effectively continue to delay implementation of the Rule for a brief period even after a stay is issued, underscoring …

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… (“Postal Service” or “USPS”), et al.—respectfully requests that this Court stay the preliminary injunction issued by the United States District Court for the District of Massachusetts (App., infra, 1a-49a) pending appeal to the United States Court of Appeals for the First Circuit and, if the court of appeals affirms the order, pending the timely filing and disposition of a petition for a writ of certiorari and any further proceedings in this Court. The Solicitor General also respectfully requests an imme- diate administrative stay of the order to prevent ongoing irreparable injury while this application is pending. (1)  2 Less than two weeks ago, this Court issued a stay of a prior order entered by the same district court. See Trump v. California, No. 26A124, 2026 WL 2473573 (Aug. 24, 2026) (per curiam). That order had enjoined implementation of a potential final rule by the Postal Service before it had even issued. In granting a stay, this …

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… v. LEAGUE OF WOMEN VOTERS OF MASSACHUSETTS, ET AL. ─────────── APPLICATION FOR A STAY OF THE INJUNCTION ISSUED BY THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS AND REQUEST FOR AN IMMEDIATE ADMINISTRATIVE STAY ─────────── Pursuant to Rule 23 of the Rules of this Court and the All Writs Act, 28 U.S.C. 1651, the Solicitor General—on behalf of applicants the United States Postal Service (“Postal Service” or “USPS”), et al.—respectfully requests that this Court stay the preliminary injunction issued by the United States District Court for the District of Massachusetts (App., infra, 1a-49a) pending appeal to the United States Court of Appeals for the First Circuit and, if the court of appeals affirms the order, pending the timely filing and disposition of a petition for a writ of certiorari and any further proceedings in this Court. The Solicitor General also respectfully requests an imme- diate administrative stay of the order to prevent ongoing irreparable injury while this …

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… Service’s efforts to address the risk that the federal mails will be used to perpetrate voter fraud, 91 Fed. Reg. at 54,969—a particularly pernicious species of fraud that dilutes the votes of lawful voters, prevents election results from reflecting the will of the American people, and undermines “public confidence in the integrity of the elec- toral process,” Crawford v. Marion Cnty. Election Bd., 553 U.S. 181, 197 (2008). Ballots have already begun to be mailed in North Carolina, and more States will begin the mailing process as the injunction remains in place—including Alabama on September 9 and at least five States the week of September 13. Once those ballot envelopes enter the mailstream, there is no retrieving them. And while the injunction allows the Postal Service and the States to continue taking steps to ensure that their envelopes satisfy the Rule’s requirements, see App., infra, 47a-48a, each day the in- junction is in place risks sowing confusion and chaos because the injunction makes those preparatory steps voluntary, rather than mandatory. Thus, if the injunction is …

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… U.S.C. 705, which again precludes the California respondents from obtaining relief nationwide. See Starbucks Corp. v. McKinney, 602 U.S. 339, 346 (2024) (explaining that “absent a clear command” to the contrary, statutes adhere to “established prin- ciples” of equity); CASA, 606 U.S. at 844 (noting that “party-specific principles * * * permeate our understanding of equity”). CONCLUSION This Court should stay the preliminary injunction of the United States District Court for the District of Massachusetts, pending the resolution of the government’s appeal to the United States Court of Appeals for the First Circuit and any proceedings in this Court, and grant an immediate administrative stay. Respectfully submitted. D. JOHN SAUER Solicitor General SEPTEMBER 2026 

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