U.S. District Judge Andrew Hanen had issued a court order to halt the immigration actions, which would grant temporary relief from deportation for 4.7 million people.
His ruling means the Homeland Security department may not shut down—for a while.
The move adds a new wrinkle to a debate already raging in the new, Republican-led U.S. Congress.
Arturo Hernandez Garcia faces deportation.
Obama's executive order on illegal migrants is being challenged in Texas.
The ruling has no immediate impact, with the government saying there was no reason for Judge Arthur Schwab to address the issue in the case.
Conservative Republicans on Wednesday resisted a plan to avert a budget fight over President Barack Obama's immigration order.
"This is an act of justice which recognizes the great contribution of millions of Mexicans to the development of our neighbor," Pena Nieto told a conference in Mexico.
After years of waiting for immigration reform, reactions to the president's speech are all over the map.
Watch a video of President Obama's immigration reform speech and read the full text of his comments.
President Barack Obama imposed the most sweeping immigration reform in a generation on Thursday, easing the threat of deportation for about 4.7 million undocumented immigrants and setting up a clash with Republicans.
Obama, in a speech to be broadcast at 8 p.m. ET, is set to lay out plans for allowing as many as 5 million undocumented people to stay in the U.S.
Advocates hope the president goes big to protect millions from deportation
Obama is expected to announce details of his executive action on immigration in a Thursday night speech
Republicans, who will take control the new Congress in January, have warned Obama not to take unilateral action on immigration.
Facing increased pressure from advocacy groups, Obama still does not have a set timeline for action
With expected gains in the midterms, another government shutdown is the last thing rank and file Republicans want
A vast majority believe the children arriving on the border should be allowed to stay if it is unsafe for them to return to their home countries
A top White House adviser said on Friday Republicans might try to impeach President Barack Obama over his go-it-alone immigration strategy