Judge Edward M. Chen, a U.S. District Judge for the Northern District of California, ruled on September 5, 2025, that the Trump administration's effort to terminate Temporary Protected Status (TPS) for Venezuelan and Haitian nationals violated federal law. However, the U.S.
Supreme Court ultimately overrode Chen's ruling in June 2026, giving the Trump administration the power to end the designations anyway—a reversal that exposed a gap between what lower courts found unlawful and what the highest court allowed. Chen's decision temporarily protected over one million people from deportation. It marked the first judicial challenge to block an attempt to reverse a TPS extension in the program's 35-year history. But his victory proved temporary, overturned by a Supreme Court decision that reset the legal landscape for how presidents can manage TPS in the future.
Table of Contents
- What Judge Chen Ruled
- The Numbers and Who Was Affected
- The Appeals Court Agreement
- The Supreme Court Reversal
- What This Means Going Forward
- Frequently Asked Questions
What Judge Chen Ruled
Judge Chen found that DHS Secretary Kristi Noem lacked statutory authority to vacate the Biden administration's 2025 TPS extension for Venezuela. In his 69-page decision, Chen determined that the terminations were "arbitrary and capricious" and that Noem's actions "do not follow proper procedures" required by administrative law.
The ruling covered not only Venezuela's termination but also the Trump administration's partial vacatur of Haiti's TPS designation. Chen ordered both vacaturs set aside and restored TPS extensions—Venezuela to October 2, 2026, and Haiti to February 3, 2026. He also raised concerns about the administration's reasoning, noting potential equal protection issues with the Venezuela decision.
The Numbers and Who Was Affected
Approximately 350,000 Venezuelan nationals and 500,000 Haitian nationals were protected by Chen's ruling, representing over one million people facing potential deportation. These individuals held jobs, paid taxes, and had built lives in the United States under TPS—a humanitarian program that allows foreign nationals to remain when their home countries experience armed conflict, natural disaster, or other emergency conditions.
For Venezuelan TPS holders, the designation had been extended multiple times since 2019. For Haitian TPS holders, it had been in place even longer, since 2010 following Haiti's earthquake. Losing TPS would have meant losing work authorization, risking deportation, and losing the ability to travel and return to the United States.
The Appeals Court Agreement
On January 28, 2026, the Ninth Circuit Court of Appeals affirmed Chen's judgment, with the appellate panel confirming that Secretary Noem lacked the statutory authority to vacate either Venezuela or Haiti's TPS designation. This was a significant validation of Chen's legal reasoning at the appellate level—a court typically more deferential to government power.
The Ninth Circuit's decision reinforced that the Trump administration had overstepped its authority under the statute governing TPS. At this point, the protection appeared likely to survive. But the case was heading to the supreme Court, where the legal landscape would shift.
The Supreme Court Reversal
The legal picture changed dramatically when the U.S. Supreme Court issued a favorable decision in Mullin v. Doe on June 25, 2026, permitting TPS terminations. Unlike Chen's and the Ninth Circuit's decisions, SCOTUS determined that the Trump administration did have the power to end TPS designations. Haiti's TPS was terminated effective July 27, 2026.
This reversal highlighted a critical distinction: a lower court finding that an action violates administrative law does not guarantee protection when the Supreme Court later rules that the underlying statutory power exists. Chen's district court victories were ultimately superseded by Supreme Court rulings that gave the Trump administration final authority to end the TPS designations.
What This Means Going Forward
Chen's battle with the Trump administration produced a significant but ultimately limited victory. His rulings established that the termination process violated proper legal procedures—a landmark decision that, for nine months, protected over one million people from deportation. Yet it also exposed a structural gap: even when courts find an agency action procedurally unlawful, a higher court can overturn that finding by reinterpreting the underlying statute.
For affected TPS holders, the Supreme Court's decision meant the loss of work authorization, travel permission, and legal status. Individuals who received deportation notices after July 27, 2026, had to either seek other forms of relief through immigration courts or face removal from the United States. The case underscored that TPS, despite its humanitarian purpose, remains vulnerable to changes in administration and subject to how courts interpret presidential power.
Frequently Asked Questions
Did Judge Chen's ruling actually stop the TPS terminations?
Only temporarily. Chen's ruling protected affected individuals from September 2025 through June 2026, when the Supreme Court reversed the decision and allowed terminations to proceed.
Could Venezuelan TPS holders appeal Chen's loss?
The Supreme Court's decision on the broader statutory question made further appeals unlikely to succeed. Individuals facing deportation could explore other immigration remedies, such as asylum or cancellation of removal, depending on their circumstances.
Does this ruling change TPS law permanently?
The Supreme Court's decision in Mullin v. Doe established that presidents have the authority to terminate TPS designations. Future challenges would need to rely on different legal arguments or require Congressional action to change TPS law itself.