Mullin v. Doe
Decision
The Supreme Court held that federal law prevents courts from reviewing most challenges to the government's decision to end Temporary Protected Status for foreign nationals.
The Supreme Court ruled that the Department of Homeland Security has the authority to end humanitarian protections for nationals of Syria and Haiti without judicial interference.
Plain-English summary generated by AI from the Court's published opinion on June 25, 2026. Always read the official opinion for the controlling text.
Key Takeaways
- 01Federal courts lack the power to review administrative challenges to the ending of Temporary Protected Status.
- 02The 1990 TPS law bars judicial review of both the final decision and the steps taken to get there.
- 03Policy-based opposition to an immigration program is considered a race-neutral justification for ending it.
Inside the Court
- Opinion by
- Justice Alito
- Dissent
- KaganSotomayorJackson
Why It Matters
This decision clarifies that most executive decisions regarding Temporary Protected Status are shielded from lawsuits, making it easier for the government to end long-standing humanitarian programs.
Who Is Affected?
TPS Recipients
Thousands of individuals from Syria and Haiti lose their legal authorization to work and may face removal from the United States.
Department of Homeland Security
The agency gains broader freedom to terminate humanitarian programs without facing lengthy administrative litigation in federal courts.
What Happened?
In late 2025, the Secretary of Homeland Security announced the termination of Temporary Protected Status (TPS) for nationals of Syria and Haiti, arguing that conditions in those countries had sufficiently improved. Syrian and Haitian nationals filed lawsuits in federal courts, claiming the government violated the Administrative Procedure Act and the constitutional right to equal protection. Lower courts initially blocked the terminations, allowing the individuals to stay while the cases proceeded. The government appealed, arguing that a 1990 federal law specifically prohibits judges from reviewing such immigration decisions.
Legal Question
Does federal law bar courts from reviewing executive branch decisions to terminate Temporary Protected Status, and did the termination of Haiti's status violate constitutional equal protection rights?
Why the Court Ruled This Way
The Court ruled that 8 U.S.C. §1254a(b)(5)(A) plainly bars judicial review of non-constitutional claims regarding TPS terminations. Writing for the Court, Justice Alito explained that the term "determination" in the statute covers both the final decision and the process used to reach it, leaving courts with no authority to hear administrative complaints. Regarding the constitutional claim, the Court held that the plaintiffs were unlikely to prove that the termination of Haiti’s status was motivated by racial discrimination. The Court noted that the administration's general policy shift against the TPS program provided a race-neutral explanation for the decision. Consequently, the Court reversed the lower courts' orders that had postponed the program's end.
Arguments in Favor
The law clearly states that no judicial review is allowed for the Secretary's determinations regarding the designation or termination of a foreign state's status. Allowing courts to second-guess these decisions interferes with the executive branch's inherent authority to manage foreign affairs and immigration policy.
Arguments Against
The term "determination" should only apply to the final substantive decision, not to the underlying procedural errors or illegal motivations that led to it. Stripping courts of the power to review these actions allows the government to ignore mandatory legal procedures and constitutional protections without accountability.
Timeline
1990
Congress created the Temporary Protected Status program.
The law was designed to provide short-term relief to foreign nationals who could not safely return home due to disasters or war.
2010
Haiti designated for TPS.
The designation followed a devastating earthquake that disrupted living conditions.
2012
Syria designated for TPS.
The country was designated due to extraordinary conditions caused by the Assad regime.
2025
President Trump issued Executive Order 14159.
The order directed officials to ensure TPS designations were limited in scope and duration.
September 2025
Secretary announced termination of Syria's TPS.
The government argued that the fall of the Assad regime constituted an improvement in conditions.
November 2025
Secretary announced termination of Haiti's TPS.
The government moved to end the years-long designation despite claims of racial bias.
June 25, 2026
Supreme Court issued its decision.
The Court ruled that it lacked the authority to review the administrative challenges to these terminations.
What This Means for Everyday Americans
For most Americans, this case highlights how much power the President and the Department of Homeland Security have over immigration rules. If you are an employer or coworker of someone with Temporary Protected Status, you may see those individuals lose their right to work as these programs end. The ruling means that even if a government agency makes a mistake in its process, judges often cannot step in if Congress has passed a law saying the courts should stay out of it. It emphasizes that humanitarian stays in the U.S. are truly "temporary" and can be ended at the government's discretion.
What Happens Next?
The cases will return to the lower courts, but those courts must now dismiss the administrative claims based on the lack of jurisdiction. The government can proceed with ending the TPS designations for Syria and Haiti, requiring affected individuals to find other legal status or depart the country.
Explain It Like I'm 12
The government has a program called Temporary Protected Status (TPS) that lets people from dangerous countries stay in the U.S. for a while. When the government tried to end this program for people from Syria and Haiti, those people went to court to stop it. They said the government didn't follow the right rules or was being unfair. However, the Supreme Court looked at a law passed by Congress that says judges are not allowed to look at these specific decisions. Because of that law, the Court said the judges must step aside, and the government can go ahead and end the program for those countries.
Broader Context
This ruling reinforces the principle that when Congress uses broad "jurisdiction-stripping" language in immigration law, federal courts cannot create exceptions for procedural or administrative complaints. It signals a high bar for using constitutional arguments to overcome statutory limits on judicial power.
Key Players
Dahlia Doe
A Syrian national who sued to prevent the termination of her protected status.
Donald J. Trump
The President whose executive order directed the stricter review of TPS designations.