Supreme Court Shuts the Courthouse Door on TPS: What Mullin v. Doe Means for Haitian and Syrian Immigrants

Today, the Supreme Court of the United States issued one of the most consequential immigration rulings in recent memory. In a 6–3 decision in Mullin v. Doe (Nos. 25-1083 and 25-1084), the Court ruled that federal courts have no power to review the Trump administration's decision to end Temporary Protected Status for the people of Haiti and Syria. For the approximately 350,000 Haitian TPS holders and 6,000 Syrian TPS holders currently living and working legally in the United States, the path forward is suddenly and dramatically narrower.

At Vartanian & Vartanian, we are monitoring this decision closely and want our clients, community members, and anyone affected to understand exactly what the Court held, what it means in practice, and what options may still remain.

What Is Temporary Protected Status?

Congress created the Temporary Protected Status program in 1990 to allow foreign nationals to remain in the United States when conditions in their home country make return unsafe. A country may be designated for TPS due to natural disasters, armed conflict, or other extraordinary and temporary circumstances.

Haiti was first designated for TPS in January 2010, days after a catastrophic 7.0 magnitude earthquake killed more than 300,000 people. Syria received a TPS designation in 2012 following the Assad government's brutal crackdown on protesters and the spiral into civil war. Both designations were renewed multiple times across administrations of both parties — until 2025, when Homeland Security Secretary Kristi Noem announced the terminations.

TPS gives holders the right to live, work, and remain in the United States without fear of deportation. It is not a green card, and it does not create a path to permanent residence — but for many families, it has provided critical legal stability for over a decade.

What the Court Decided Today

Justice Samuel Alito wrote the majority opinion, joined by five colleagues. The key holding: the TPS statute, at 8 U.S.C. § 1254a(b)(5)(A), strips federal courts of jurisdiction to review "any determination" the Secretary of Homeland Security makes "with respect to the" termination of a TPS designation.

Alito wrote that the language of the judicial review bar is "clear, and its plain meaning is very broad," concluding that it covers both individual decisions and the entire process leading up to a final termination — including challenges brought under the Administrative Procedure Act.

The Haitian plaintiffs had also raised a constitutional equal protection claim, arguing that President Trump's statements about Haiti during his 2024 campaign reflected racial animosity. The Court held that this constitutional claim is reviewable — but also ruled it is "likely to fail" because a race-neutral explanation exists: the Trump administration has terminated every TPS designation that has come up for renewal, regardless of the country involved.

Three liberal justices dissented. Justice Elena Kagan, joined by Justices Sonia Sotomayor and Ketanji Brown Jackson, argued that TPS holders "ask for only one thing: that they may stay in this country while they continue to litigate their claims" — and that they are entitled to that relief given the life-threatening consequences of deportation.

The practical result: the nationwide injunctions that had been blocking the terminations are now lifted. The terminations of Haiti and Syria TPS can proceed.

Who Is Affected and What Is the Timeline?

This ruling directly affects:

• Approximately 350,000 Haitian nationals currently holding TPS in the United States

• Approximately 6,000 Syrian nationals currently holding TPS in the United States

These individuals will lose both their employment authorization documents (EADs) and their protection from deportation once DHS implements the terminations. Exact wind-down dates have not yet been published — watch for announcements from USCIS regarding grace periods and transition timelines. It is also worth noting that this ruling makes it far harder to challenge TPS terminations for any other country going forward.

What Options Remain for Affected TPS Holders?

Losing TPS does not necessarily mean losing all options. Depending on your individual circumstances, the following paths may be available:

Family-Based Adjustment of Status

If you have an immediate relative who is a U.S. citizen or lawful permanent resident — a spouse, parent, or child — you may be eligible to apply for a green card. The end of TPS does not automatically cancel any pending or approvable family petition.

Employer-Sponsored Immigration

If your employer has been or is willing to sponsor you for an H-1B, O-1, or employment-based green card, now is the time to explore that path seriously. TPS has never been a permanent solution; for many clients, it has been a bridge to more lasting status.

Asylum and Other Protection-Based Claims

If you have been a victim of persecution or face a well-founded fear of persecution based on race, religion, nationality, political opinion, or membership in a particular social group, you may have an independent asylum claim. Note that asylum applications generally must be filed within one year of arrival, but exceptions exist.

Withholding of Removal and Convention Against Torture

Even if you are not eligible for asylum, you may qualify for Withholding of Removal or protection under the Convention Against Torture (CAT) if returning to your home country poses a clear risk of serious harm. These forms of protection do not carry a one-year filing deadline.

Constitutional Litigation

Today's ruling leaves the door slightly open for the equal protection claim brought by Haitian TPS holders. While the Court said it is "likely to fail," it did not dismiss the claim outright. Litigation may continue on that limited basis.

Congressional Relief

Advocates are calling on Congress to act. Bills providing a path to permanent residence for long-term TPS holders have been introduced in recent years. While the political environment is challenging, legislative advocacy remains meaningful — particularly for those with deep community and economic ties to the United States.

What Should You Do Right Now?

If you or a family member currently holds TPS for Haiti or Syria, we urge you to take the following steps immediately:

• Do not wait. Begin exploring alternative immigration options now, before your current TPS and work authorization expire.

• Do not miss filing deadlines. If you have a pending I-130, I-485, or employer petition, monitor it actively.

• Gather your documents. Have your passport, TPS approval notices, EAD card, and other immigration documents organized and accessible.

• Consult an immigration attorney. Every situation is different. A qualified attorney can assess your specific circumstances and identify pathways that may not be immediately obvious.

• Stay informed. DHS will likely publish guidance about transition timelines. Follow official USCIS announcements and reliable immigration news sources.

How Vartanian & Vartanian Can Help

Our firm has worked with TPS holders from Haiti and many other countries for years. We understand the anxiety this decision creates, and we are here to help you evaluate your options with honest, practical guidance.

If you have questions about how today's ruling affects your case, please reach out to us. The sooner we can assess your situation, the more options may be available to you.

Vartanian & Vartanian Immigration Law — 100 State Street, Floor 9, Boston MA 02109

Disclaimer: This blog post is for general informational purposes only and does not constitute legal advice. Reading this post does not create an attorney-client relationship. Immigration law is highly fact-specific; please consult a qualified attorney about your individual circumstances.