Fritz Emmanuel Lesly Miot v. Donald Trump
Legal Issues
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Overview
The government appealed Judge Reyes' order staying Secretary Noem's termination of TPS for Haiti.
The Facts
The Department of Homeland Security, under then-Secretary Kristi Noem, moved to terminate Temporary Protected Status for Haitian nationals as part of a broader rollback of TPS designations. Haitian TPS holders sued in the U.S. District Court for the District of Columbia, where Judge Ana C. Reyes stayed the termination and blocked the government from ending Haiti's TPS while the case proceeded. The government appealed to the D.C. Circuit and asked it to stay Judge Reyes's order pending appeal, which the D.C. Circuit denied on July 22, 2026. While the appeal was pending, the Supreme Court took up the consolidated TPS cases.
The Application
Analysis
Applying the stay standard, Judge Reyes found that Miot likely succeeds on the merits of his RIF challenge by demonstrating civil service procedural violations in his termination, that loss of employment constitutes irreparable harm that cannot be adequately remedied by back pay alone, and that the balance of equities favors protecting an incumbent's continued employment over the administration's efficiency interest in rapid reductions. The court thus granted the stay, effectively determining that judicial enforcement of statutory employment protections outweighs the government's public interest claim absent clear legal authority to bypass those procedural safeguards.
The Conclusion
The Supreme Court cleared the way for the government to terminate Temporary Protected Status for Haiti, holding 6 to 3 in the consolidated Mullin v. Doe decision (June 25, 2026) that the TPS statute bars judicial review of statutory and Administrative Procedure Act challenges to a termination. The plaintiffs' constitutional equal protection claim survives on remand, but the Court signaled it is unlikely to prevail. With the D.C. Circuit's August 4, 2026 remand, the case returns to Judge Ana C. Reyes in the district court, where that narrow constitutional question is what remains of the challenge.
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