Mullin v. Doe (consol. w/ Trump v. Miot) — TPS
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The Facts
The Trump administration terminated Temporary Protected Status (TPS) designations for Syrians (September 2025) and Haitians (November 2025), citing alleged improvements in country conditions and national interest. A federal district court blocked both terminations, finding the Secretary of Homeland Security lacked statutory authority and the decisions may have been racially motivated. The Supreme Court accepted the cases on certiorari before judgment to resolve the administration's authority.
The Issue
Whether the Secretary of Homeland Security has statutory authority under INA § 244 to terminate TPS designations based on changed country conditions and national interest; and whether the Secretary complied with the consultation and procedural requirements of the statute.
The Rules
The Secretary may designate a foreign state for TPS if ongoing armed conflict, environmental disasters, or extraordinary conditions exist; designation may be terminated if conditions change.
A reviewing court shall hold unlawful and set aside agency action found to be arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.
No person shall be deprived of liberty without due process of law; equal protection principles prohibit racially motivated government action.
The Application
DHS argues it has authority to terminate immigration protections and enforce removal against individuals or classes protected by lower courts. The government's position is that executive enforcement discretion includes the power to rescind previously granted parole or protection, and that lower courts exceeded their authority in blocking these enforcement actions.
The anonymized respondents argue DHS cannot unilaterally revoke legally-granted immigration protections without proper procedures. Lower courts properly enjoined enforcement actions that would strip individual or class-based protections without adequate notice, hearing, or compliance with the Administrative Procedure Act.
Argued April 29, 2026 — the last case argued this term. Limited public briefing makes the specific legal question less clear than other pending cases. The Court's general deference to executive immigration enforcement in Trump-era cases suggests a lean toward DHS. As the latest-argued case, a decision is expected in the final week of June 2026.
The Conclusion
The Court ruled 6-3 that the TPS statute bars judicial review of non-constitutional challenges to the administration's termination of Temporary Protected Status for Haitian and Syrian nationals. The decision clears the way for DHS to end protections for roughly 350,000 Haitians and 6,000 Syrians, with Justice Alito writing for the majority and Justice Kagan dissenting.
No circuit court data for this case.
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