Hyperventilating ran heavy in June after the Supreme Court issued its ruling that courts had been too profligate in using nationwide injunctions to stop the president, and ordered lower judges to cool it.

Justice Sonia Sotomayor called the decision an “invitation … to bypass the Constitution.” A law professor called it a “major blow” to the judicial branch’s ability to stop a president. One media outlet called the ruling a “blockbuster” victory for President Trump.

Three months later, though, the ruling has largely fizzled, with judges still finding plenty of room to shut down Mr. Trump without resorting to the kind of nationwide, or universal, injunctions the high court criticized.

Some judges shifted to using class action lawsuits to stop presidential action. Others turned to what’s known as “vacatur,” where a government policy can be erased root and branch. And still others said the cases in front of them were special enough that they demanded nationwide injunctions, notwithstanding the Supreme Court’s scolding in the June ruling in CASA v. Trump.

“CASA decisively rejected the universal injunction. But it didn’t eliminate all forms of broad relief in federal court, especially class actions and vacatur of federal rules. That’s where the energy has now shifted,” said Samuel Bray, a law professor at the University of Chicago whose work was cited in the high court’s June ruling.

Howard Wasserman, a professor at Florida International University College of Law, said legal experts who studied universal injunctions haven’t been surprised by how things have played out.

“The court left open four ways in which broad injunctions are still possible. But you have to do a little bit more work to get it, and that’s what’s happening,” he said.

But he said that doesn’t make the high court’s ruling go for naught.

“We end up in the same place, but we got here by the right mechanism, and that matters,” he said. “We got here by doing the correct analysis.”

Mr. Bray, for his part, said it’s too soon to say where lower courts will find ways to substitute other blockades in cases where they used to issue universal injunctions.

There are some early indications, however.

The Washington Times reviewed 23 decisions issued since July 1 where judges grappled with the scope of relief they were asked to give.

While most gave some nod to the CASA decision, in 18 of the cases, the judges delivered a broad relief.

In just two of the cases reviewed by The Times, the judges did say they were acting to limit their rulings in the wake of the high court’s CASA admonition.

One was Judge Julie Rubin, a Biden appointee to the court in Maryland. Faced with a case challenging the Trump administration trims to the Education Department, she said the plaintiffs were asking the court to become a referee over presidential actions, crossing lines the Supreme Court laid out in CASA.

“The relief requested here raises a serious risk of doing precisely what the [Supreme] Court has cautioned the court to avoid. Ultimately, this court may not overreach its authority to order the Executive to act within the confines of its own,” Judge Rubin wrote.

Injunctions are court rulings that halt a president’s action. In a normal case, an injunction is supposed to be limited to the parties that sued.

But as presidents have increasingly flexed unilateral executive powers in recent years, courts have responded with ever larger injunctions, blocking a president’s action for everyone, not just the plaintiffs.

In the cases decided by the high court in June, a series of plaintiffs had challenged Mr. Trump’s attempt to curtail government recognition of automatic citizenship for children born to illegal immigrant or temporary visitor parents.

Lower judges moved quickly to slap nationwide injunctions, reasoning that it made no sense to have a child’s citizenship depend on whether they were born in a Democrat-led state that sued, or a GOP-led state that didn’t or if their parents were part of one of the activist groups that sued.

The justices delivered a scolding in Casa v. Trump, telling lower judges they’d gone off the rails. They said the power to issue nationwide injunctions “lacks a historical pedigree” and fell “outside the bounds” of a judge’s power.

They said judges still had class action lawsuits, which require plaintiffs to prove members of the class were all in a similar situation. And the high court left open other questions, such as when states were plaintiffs, or when an agency’s action was being challenged under the Administrative Procedure Act, which requires the government to follow careful procedures when making policy decisions.

Judges moved quickly to exploit each of those.

Within weeks, four different lower courts re-examined birthright citizenship and in each case decided that a universal blockade was still warranted.

In New Hampshire and Maryland, federal district judges certified class actions.

In two other cases where states were plaintiffs, a federal district court in Massachusetts and the 9th U.S. Circuit Court of Appeals on the West Coast ruled that universal injunctions were still warranted.

“No workable, narrower alternative to the injunction issued originally would provide complete relief to the plaintiffs in this case,” wrote Judge Leo Sorokin, who oversaw the case out of Massachusetts.

Elsewhere, judges have been quick to use the Administrative Procedure Act to shut down Trump actions wholesale.

“The recent Supreme Court case, Trump v. CASA, does not change the outcome,” ruled U.S. District Judge Brendan Hurson in a case in Maryland challenging Trump administration restrictions on Obamacare.

In Seattle, U.S. District Judge Ricardo Martinez earlier this month shut down a Trump policy to block some temporary immigrants from signing up for welfare benefits. He said it would be “impractical” to only apply his ruling to the plaintiffs.

And U.S. Judge Trina Thompson, in San Francisco, postponed Homeland Security’s attempt to end a deportation amnesty program for migrants from Nepal, Honduras and Nicaragua. She said the APA allows judges to “vacate” an entire policy — and that’s what she said the case called for.

“Setting aside an agency action is the standard remedy for APA cases,” she said.

During oral argument in the Supreme Court case in May, Justice Brett M. Kavanaugh hinted that the upcoming ruling might not be the seismic shift some were figuring. He said people would still get the answers they deserved from courts, but the judges would have to work through more steps.

“This may all be a technicality,” he said.

But he suggested it was still worth it.

“It complies with the rules,” he said. “I mean, the law — we care about technicalities.”

Josh Blackman, a professor at South Texas College of Law who had been critical of the flood of universal injunctions, said the new rush to certify class actions is worrying.

He said some judges approved them so quickly that he was “skeptical whether they went through all of the required factors.”

“I think the Supreme Court will be frustrated that lower courts have resurrected national injunctions as class actions. The Supreme Court is being resisted,” he said.

Other legal experts suggested the high court may revisit the issue and attempt to rein in the states’ ability to sue, which could erase one of the remaining avenues for universal injunctions.

But that still leaves the Administrative Procedure Act, which has become the chief hurdle for the president in many of his executive action legal losses, according to data compiled by Adam Feldman, who runs Legalytics.

Mr. Wasserman said that’s a tricky issue for this Supreme Court.

He said Justice Kavanaugh and Chief Justice John G. Roberts Jr., who emerged from the circuit court in Washington that handles a lot of APA cases, have signaled that vacating entire rules is valid.

But it’s not clear where others like Justice Neil M. Gorsuch and Justice Amy Coney Barrett stand. Justice Barrett, who wrote the chief opinion in the CASA case, relegated the APA to a single footnote making clear the case didn’t affect that situation.

• Stephen Dinan can be reached at sdinan@washingtontimes.com.

• Alex Swoyer can be reached at aswoyer@washingtontimes.com.