Haitian Evangelical Clergy Association v. Trump (2025 TPS Cancellation, D)
Legal Issues
Overview
Overview
The Haitian Evangelical Clergy Association sued the Trump administration over its decision to cancel temporary protected status for Haitians.
Overview
The government appealed Judge Cogan's order granting partial summary judgement for Haitian Evangelical Clergy Association and staying Secretary Noem's partial vacatur of temporary status protections for Haitians.
The Issue
Issue
Whether the Trump administration lawfully terminated Temporary Protected Status (TPS) for Haitian nationals under the Immigration and Nationality Act.
The Rules
Rule
The Secretary of Homeland Security may terminate TPS designations when country conditions no longer warrant protection; such determinations are reviewed under the Administrative Procedure Act for arbitrariness and capriciousness, requiring the agency to examine relevant data and demonstrate a rational connection between facts and the decision.
The Application
Analysis
The plaintiffs challenged the TPS cancellation as arbitrary and capricious, arguing the agency failed to adequately justify the termination and did not sufficiently consider factors supporting continued protection for Haitian nationals.
The Conclusion
The district court ruled for the plaintiffs and its judgment staying the TPS termination remains in effect pending appeal. The government's appeal to the Second Circuit is fully briefed as of mid-2026, and the government's motion to vacate the judgment and remand as moot has been referred to the merits panel, which has not granted it. The case is live on appeal, not concluded.
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