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CASA, Inc. v. Noem (TPS Afghanistan Appeal)

No. 25-1792 Circuit · Decided
Court
4th Cir.
ca4
Decided
Jul 23, 2025
Filed
Jul 14, 2025
Filed (CL)
Jul 14, 2025
CL Status
terminated
90-day re-liquidation window Casa universal injunction doctrine Deemed liquidation Entry liquidation Geographic scope of preliminary injunctions Party-specificity of preliminary injunctions Separation of powers birthright citizenship class action class certification equitable injunction equitable relief institutional standing judicial independence nationwide injunction scope nationwide injunction scope limitation nationwide injunctions preliminary injunction preliminary injunction scope Temporary Protected Status (TPS)

Legal Issues

90-day re-liquidation windowCasa universal injunction doctrineDeemed liquidationEntry liquidationGeographic scope of preliminary injunctionsParty-specificity of preliminary injunctionsSeparation of powersbirthright citizenshipclass actionclass certificationequitable injunctionequitable reliefinstitutional standingjudicial independencenationwide injunction scopenationwide injunction scope limitationnationwide injunctionspreliminary injunctionpreliminary injunction scopeTemporary Protected Status (TPS)
The Law · How the Case Works

Overview

Overview

CASA, Inc. appealed Judge Chuang's decision denying CASA's motion for a partial summary Judgment or a stay of agency action to prevent the cancellation of temporary protected status for Afghanistan and Cameroon.

The Issue

Issue

Whether CASA, Inc. is entitled to a preliminary injunction or stay preventing the cancellation of Temporary Protected Status (TPS) for nationals of Afghanistan and Cameroon pending appellate review of the agency action.

The Rules

Rule

Courts review agency TPS cancellation decisions under the Administrative Procedure Act standard, examining whether the agency action is arbitrary and capricious. Preliminary relief requires demonstration of likelihood of success on the merits, irreparable harm, and that the balance of equities favors the moving party.

The Application

Analysis

CASA challenged the TPS cancellation for Afghanistan and Cameroon as arbitrary and capricious, seeking summary judgment or a stay of agency action. Judge Chuang denied both forms of relief, finding CASA's arguments insufficient to warrant intervention before the status termination took effect.

The Conclusion

Conclusion

The Fourth Circuit has decided the appeal, affirming the district court's denial of CASA's motion for partial summary judgment and stay of agency action regarding TPS cancellation.

Court -
FiledJul 14, 2025
CL Statusterminated
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Court -
FiledJul 14, 2025
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Docket

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Outcome History (2)

  1. Jul 21, 2025 Circuit
    Preliminary injunction denied Relief denied

    Motion for injunctive relief pending appeal denied

  2. Jul 23, 2025 Circuit
    Voluntarily dismissed Resolved Final

    Motion to dismiss appeal granted, appeal dismissed pursuant to FRAP 42(b)

Federal Court TMR-2a8fe2b6 TPS Cancellation <br> Appeal of 8:25-cv-01484 Jul 26, 2026
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