Mullin v. Dahlia Doe

Mullin v. Dahlia Doe challenged the Trump administration’s decision to terminate Temporary Protected Status (TPS) for thousands of Syrian immigrants living and working legally in the United States while it is unsafe for them to return to their home country. The case was consolidated with Trump v. Miot, a case concerning Haitian TPS holders. The Supreme Court expedited the case for judicial review, granting certiorari before judgment based on a preliminary ruling from the district court.

In its Supreme Court’s June 25, 2026 6-3 ruling, the Court allowed the TPS terminations of Syria and Haiti to proceed, resulting in the loss of legal status and the right to work for over 350,000 people. The Supreme Court held that there was no judicial review for the plaintiffs’ statutory claims; and that the constitutional equal protection claim was unlikely to succeed on the merits.

TPS is a program established by Congress in 1990 to protect individuals who cannot safely return to their home country due to war, natural disaster, or other emergencies. TPS holders are mothers, fathers, workers, and contributing members of their communities. They rely on this humanitarian protection regime for safety.

The Supreme Court’s ruling impacts not only Syrian and Haitian TPS holders but all 1.3 million individuals from 17 countries designated for TPS. At the time the Supreme Court heard this case on April 29, 2026, the Trump administration had terminated TPS for 13 countries—despite ongoing wars and undisputed humanitarian crises.

Alongside our co-counsel the International Refugee Assistance Project (IRAP), Muslim Advocates, Van Der Hout LLP, and the National ACLU, the ACLU of Northern California represents seven Syrian nationals with TPS or pending applications in Mullin v. Dahlia Doe, a class action lawsuit originally filed in October 2025. Cancelling TPS designation for Syria subjects nearly 6,100 Syrian TPS holders, along with 800 Syrians with pending applications, to immigrant detention and possible deportation to an unsafe country. The Miot case, consolidated with Doe, affects 350,000 Haitian TPS holders.

The plaintiffs argued that the DHS Secretary does not have the legal authority to unilaterally override the TPS statute enacted by Congress, and that it is the role of the judiciary to review the government’s legally dubious actions. The Supreme Court adopted the government’s extreme position that even lawless decisions that violated clear statutory mandates were not reviewable.

On September 22, 2025, former Secretary of Homeland Security Kristi Noem terminated TPS for approximately 7,000 Syrians. She did so despite the State Department and the Department of Homeland Security recognizing that the armed conflict and humanitarian crisis in Syria make it unsafe. Syrian TPS holders challenged this termination decision and a district court put it on hold while the case proceeds. However, the Supreme Court took the extraordinary decision to review this case on the merits without basic fact gathering or a final decision from a lower court or court of appeal.

In March 2026, the Supreme Court chose not to rule on the Trump administration’s request to immediately end legal status and work authorization for Haitian and Syrian TPS holders, allowing the ruling of the lower court to remain in effect. Instead, they chose to fast-track Mullin v. Dahlia Doe and combine it with a separate lawsuit, Trump v. Miot, that similarly challenges the termination of TPS for Haiti. Both cases will be heard at the Supreme Court on April 29, 2026.

The ACLU of Northern California also represents TPS holders in two other cases: NTPSA I v. Noem, challenging the TPS terminations of Venezuela and Haiti, and NTPSA II v. Noem, challenging the TPS terminations of Honduras, Nepal and Nicaragua.