Doe v. Noem (TPS stay appeal 2025)
Case Overview
Doe v. Noem, No. 25-1384 (1st Cir.), is the government's appeal of a district court order that stayed DHS's early termination of the CHNV humanitarian parole programs for nationals of Cuba, Haiti, Nicaragua, and Venezuela. The First Circuit vacated the stay and remanded, holding that although the parole statute requires DHS to grant parole only on a case-by-case basis, it does not impose the same case-by-case limitation on the termination of parole. The mandate issued November 26, 2025, returning the case to the District of Massachusetts.
Legal Issues
The Application
The district court found sufficient basis to stay DHS's pause on TPS and CHNV applications, suggesting probable success on the argument that the agency action violated statutory constraints or procedural requirements. The appellate court reviewed whether the lower court properly applied stay standards to this immigration benefits determination.
The Conclusion
On September 12, 2025, the First Circuit vacated and remanded, ruling for the government and allowing the mass termination of CHNV parole to proceed. A petition for panel rehearing was denied November 18, 2025, and the mandate issued November 26, 2025.
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