National TPS Alliance v. Noem et al.

Last updated
National TPS Alliance v. Noem
Seal of the United States Courts, Ninth Judicial Circuit.svg
Court Northern District of California
Full case name National TPS Alliance et al. v. Noem et al.
DecidedOngoing
Docket nos.
Defendant Kristi Noem et al.
PlaintiffNational TPS Alliance et al.
Case history
Subsequent actionsSent under emergency application to Supreme Court, stay of previous order since enforced. Case sent to Ninth Circuit for further deliberation.
Holding
Pause on termination of temporary protected status for designates whose status was set to expire in April, pending verdict on litigation.
Court membership
Judge sitting Edward M. Chen
Keywords

National TPS Alliance v. Noem et al. is an ongoing US federal court case between the United States Department of Homeland Security (DHS) under Kristi Noem and 7 temporary protected status (TPS) recipients represented by the National TPS Alliance, an organization composed of TPS recipients from across the country. [1] [2] [3] The latter is represented in court by the National Day Laborer Organizing Network (NDLON), the California branches of the American Civil Liberties Union, and staff at the UCLA Law Center for Immigration Law and Policy. [1] [4] [5] [6] It is a continuation from Ramos v. Nielsen, a case deliberated during the first Trump administration over the repeal of TPS designation for status holders from several nations. [4] [7] The suit sought to block the repeal of TPS status for roughly 350,000 Venezuelan recipients by Noem's administration under the order of President Donald Trump. [8] In a short brief, the Supreme Court granted an emergency application to stay a lower court's pause on the repeal on May 19, 2025, sending the case to the Ninth Circuit Court of Appeals which "affirmed the district court’s order granting preliminary relief in the form of a postponement of the effective dates of actions by the Secretary of Homeland Security to terminate Temporary Protected Status ("TPS") for Venezuelan nationals". [9] [10] [11] [12]

Contents

Background

Temporary protected status (TPS)

First Trump administration (Jan 2021)

The first Trump administration was characterized by efforts to restrict additional and existing designations of temporary protected status to foreign nationals, despite those pursuits largely being blocked in the courts. [13] Nevertheless, the president issued directives at the end of his presidency to protect migrants originating in Venezuela.

On January 19, 2021, President Donald Trump issued a Deferred Enforced Departure (DED) directive to the Attorney General and Secretary of Homeland Security to defer the deportation of migrants originating from Venezuela on account of the extraordinary nature of the circumstances presented in the country by the actions of Nicolas Maduro's administration. [14] [15] [16] The directive began in stating that Maduro had "consistently violated the sovereign freedoms of the Venezuelan people.” [15] [17] The agencies were thus directed:

to take appropriate measures to defer for 18 months the removal of any national of Venezuela, or alien without nationality who last habitually resided in Venezuela, who is present in the United States as of January 20, 2021, except for aliens who:

  1. have voluntarily returned to Venezuela or their country of last habitual residence outside the United States;
  2. have not continuously resided in the United States since January 20, 2021;
  3. are inadmissible under section 212(a)(3) of the Immigration and Nationality Act (INA) (8 U.S.C. 1182(a)(3)) or removable under section 237(a)(4) of the INA (8 U.S.C. 1227(a)(4));
  4. who have been convicted of any felony or 2 or more misdemeanors committed in the United States, or who meet the criteria set forth in section 208(b)(2)(A) of the INA (8 U.S.C. 1158(b)(2)(A));
  5. who were deported, excluded, or removed, prior to January 20, 2021;
  6. who are subject to extradition;
  7. whose presence in the United States the Secretary of Homeland Security has determined is not in the interest of the United States or presents a danger to public safety; or
  8. whose presence in the United States the Secretary of State has reasonable grounds to believe would have potentially serious adverse foreign policy consequences for the United States. [15]

The administration further directed that the latter agency open up pathways to employment for any individual that met these requirements. [15] The following day, Joe Biden was inaugurated the 46th President of the United States.

Biden administration (Jan 2021 – Jan 2025)

On March 9, 2021, the Biden administration directed DHS and Immigration and Customs Enforcement (ICE) to grant temporary protected status for 18 months to registrants from the Republic of Venezuela, deferring to the earlier judgement made by Trump's office on the country's political situation. [16] [18] [19] It maintained the DED policy enacted by the previous administration, but offered a broader means of access to Venezuelan nationals by means of TPS. [16] On April 22, the administration further extended employment authorization to F-1 student visa recipients "experiencing severe economic hardship as a direct result of the...humanitarian crisis in Venezuela." [20]

In July 2022, the administration announced its plans to extend the TPS designation, leaving the DED order to lapse, effectively replacing it with the new policy. [16] In August 2021, the administration extended the deadline for registration by new applicants from Venezuela, Syria, and Myanmar from September of that year to November of 2022. [21] On September 8, the administration issued a continuation for the TPS designation for another 18-month period, ending March 10, 2024. [16] [22]

In September 2023, then-DHS Secretary Alejandro Mayorkas announced the extension of TPS and work authorization to an additional 472,000 Venezuelans, as well as additional work authorizations, citing "increased instability and lack of safety due to the enduring humanitarian, security, political, and environmental conditions." [23] [24] It additionally expanded the designation to encompass any Venezuelan that arrived before July 31 of that year, lasting until September 2025. [25] [26] ICE continued, though, to carry out deportations of new arrivals from the country at the southern border during the same period. [23] [24] [27] [28]

On January 10, 2025, DHS announced the final continuation of TPS under the Biden administration. [29] [30] [31] It would have maintained the order from April 2 on to October 2026 for roughly 600,000 Venezuelans, as well as 100,000 designates from Ukraine, more than 200,000 designates from El Salvador, and nearly 2,000 designates from Sudan. [13] [30] [32] [33] This order was rescinded almost immediately upon the beginning of the second Trump administration, with designation set to expire in April. [34] [35]

Second Trump administration (Jan 2025 – Pres.)

On January 28, Secretary Noem announced the vacatur of the previous designation, reverting to the initial deadline set by the October 2023 designation. [36] On February 1, 2025, the Department of Homeland Security announced its intention to seek the removal of Temporary protected status for roughly 350,000 Venezuelans who had been granted the charter under the Biden administration. On February 5, an order was published in the federal register. [37] A suit was filed against the order on February 19. [38] Termination was to go into effect in early April, but the order was blocked by Judge Edward M. Chen in the US Court for the Ninth District of California. [39]

Lower Court

On February 19, 2025, the National TPS Alliance and its partners filed suit in federal court to challenge the department's efforts to remove the temporary status of roughly 600,000 Venezuelans: 350,000 whose designation would expire on April 7, and an additional 250,000 whose designation is set to expire in September. [8] They filed preliminary motion the following day. [38] [40] In a press release, they claimed that the "explanation for her decision [was] irrational and riddled with legal errors." [40] The case was assigned to District Judge for the Northern District of California Edward M. Chen. [5] [41]

Arguments

Information on deliberations can be found here. [5] [41]

Plaintiffs (National TPS Alliance et al.)

In their preliminary filing, plaintiffs claimed that the DHS under Noem had violated the Administrative Procedure Act, as well as the guidelines of the TPS statute itself, which prohibits the premature vacatur of previous administrations' designations. [4] [8] [42] They further claimed that the administration's actions were driven by racial/ethnic animus. [5] [8] [38] [42]

Representatives have further argued that the actions thus far taken by the administration have caused irreparable harm to the claimants–notwithstanding others affected by the order and litigation process–through family separation, psychological trauma, and unwarranted social stigma. [5]

Defendants (Noem et al.)

Noem's office has held that Biden's office did not have the authority to renew the 2023 designation, and thus its vacatur is justified, given the fact that the current administration believes the designation is no longer warranted. [3] [37] They and the Trump administration at large have also advanced claims challenged both in and by the court surrounding the presence of dangerous elements within the Venezuelan migrant population at large in the United States. [3] [17] [37] This has included their allegation of the broadly-based membership of Venezuelan migrants in the Tren de Aragua gang, the subject of additional court proceedings. [43] [44] [45] The administration has further argued that TPS status designations are not subject to judicial review. [46]

Ruling

On March 31, Judge Chen granted the plaintiff's motion to allow time for status holders' designations to be reviewed and deliberated in court, finding that Noem did not have a legal right to vacate the 2023 designation prior to its expiration; even if she had, it was based in legal error, according to his argument siding with the plaintiffs' reasoning. [3] [47] [48] Judge Chen stated he felt Noem's actions appeared to be "predicated on negative stereotypes casting class-wide aspersions on their [Venezuelans'] character," and that the policy appeared in part to be driven by unconstitutional animus. [3] [42] The court found that the vacatur would do irreparable harm to the families designated under the provision; it did not feel that Noem's office had provided sufficient explanation of the harm inherent to redesignating Venezuelans under temporary status, and that Noem's office itself had conceded that its intention was principally to revisit then-Secretary Mayorkas' renewal of the 2023 designation. [3] [42]

Defendants almost immediately filed a motion to stay the order by no later than 3pm on April 4, given that the departments vacatur of TPS was set to take effect on the 7th. [39] [49] Though the motion to shorten the deadline was granted, the motion to stay was denied by the court. [50] An emergency application was then filed by DHS in the Supreme Court, claiming that multiple rulings by judges had encroached on the department's authority. [35] In the emergency filing, Solicitor General D. John Sauer argued that "The court’s order contravene[d] fundamental executive branch prerogatives," indefinitely delaying work in areas of policy that Congress had recognized to required "flexible, fast-paced, and discretionary" action. [9]

Precedent

Supreme Court

National TPS Alliance v. Noem et al.
Seal of the United States Supreme Court.svg
Supreme Court of the United States
Original jurisdiction
Full case nameKristi Noem, Secretary of Homeland Security, et al. v. National TPS Alliance et al.
Docket no. 24A1059
Opinion announcement Opinion announcement
Case history
PriorNational TPS Alliance v. Noem (3:25-cv-01766) (Northern District of California, Judge Edward M. Chen presiding)
Outcome
Initial court order stayed. Case ongoing. Sent back to the Ninth Circuit Court of Appeals following approval of the DHS order.
s
Dissent Ketanji Brown Jackson

In an unsigned order on May 19, the Supreme Court granted an emergency application filed by the administration to stay Judge Chen's earlier order. [9] [51] [52] [42] [53] The initial application for the stay was forwarded by Justice Kagan. [54] Individuals whose status was set to expire in April are now without substantial legal protection, and face the prospect of deportation. [6] [9] The decision did not affect the status of 250,000 Venezuelans whose status was set to expire in September; their status is not set for final determination by DHS until July 12, 2025. [34] [51] Nor does the decision affect Haitian status holders. [34] The court offered a pathway to later challenges, though observers have noted that the language is unspecific. [9] The case was sent down to the Ninth Circuit Court of Appeals for further deliberation. [55]

Dissent

Ketanji Brown Jackson was the only Justice noted in dissent. [10] [56] The initial ruling was left unsigned, as is typical in emergency filings. [6] Nevertheless, this ultimately leaves the question of concurrence with the ruling unknown.

Implications and Reactions

The case, along with several others, will set precedent in deciding the extent to which the Trump administration can manipulate or repeal existing executive policy on temporary status. Independent observers note that it is likely the Trump administration will take steps to deport previous status holders in the event that the case is ultimately decided in their favor. [57] This has partly been performed by means of the Alien Enemies Act, the subject of further litigation, most pertinently in J.G.G. v. Trump. [58] [59] [44]

Many outside actors have noted the critical role that Venezuelan asylum seekers and other TPS designates play in the US economy, and the dangers that lie therein for its functions in the event that large scale deportation efforts against recent or existing temporary status holders are greenlit by the courts. [60] They constitute a population of more than 1 million people, and fulfill functions that are otherwise shortly supplied in the US labor market. [60] [61] In 2021, status holders contributed more than $2 billion to the US economy, roughly a fifth of their total earnings. [62] 94% of working-age designees are employed, comparable with the national average, and they play a substantial role in the economic health and diversity of their communities. [62] [63]

Reactions

Plaintiffs

Representatives for the plaintiffs noted their surprise after an emergency verdict was reached. In a statement following the ruling, the co-director for the UCLA Immigration Law Center surmised:

[Noem's Feb. 5 order] is the largest single action stripping any group of non-citizens of immigration status in modern US history. That the Supreme Court authorized it in a two-paragraph order with no reasoning is truly shocking. [6]

Defendants

DHS reacted to the ruling in a tweet on X, in which they claimed that it represented "a win for the American people and the safety of our communities." [6] They further advanced unsupported claims of broad-based arrivals of gang members on US soil under the Biden administration. [6] A notice on the Temporary Protected Status page of the Immigration and Customs Enforcement website describes the court's ruling as "convincing" and showing the merits of the order; further, it claims Judge Chen's March ruling to have been an "erroneous error". [55]

Outside Observers

See also

Main Filings

Plaintiffs

  • Declaration in Support of Motion to Postpone Effective Date of Agency Action No. 37

Defendants

  • Court filings available here

Linked proceedings

References

  1. 1 2 "Certificate of Service: No. 24A1059: In the Supreme Court of the United States - Kristi Noem, Secretary of Homeland Security, et al., applicants v. National TPS Alliance, et al" (PDF). Supreme Court of the United States (supremecourt.gov). 2025-05-09. Retrieved 2025-05-23.
  2. ↑ "About Us – National TPS Alliance" . Retrieved 2025-05-23.
  3. 1 2 3 4 5 6 "Order on Motion for Miscellaneous Relief – #93 in National TPS Alliance v. Noem (N.D. Cal., 3:25-cv-01766) – CourtListener.com". CourtListener. Retrieved 2025-05-26.
  4. 1 2 3 "National TPS Alliance v. Noem | ACLU of Southern California". www.aclusocal.org. 2025-02-24. Retrieved 2025-05-23.
  5. 1 2 3 4 5 6 "National TPS Alliance v. Noem 3:25-cv-01766 (N.D. Cal.) | Civil Rights Litigation Clearinghouse". clearinghouse.net. Retrieved 2025-05-25.
  6. 1 2 3 4 5 6 Al Jazeera Staff. "US Supreme Court clears way to end TPS for Venezuelans: What it means". Al Jazeera. Retrieved 2025-05-24.
  7. ↑ "The Impact of Ramos V. Nielsen on Temporary Protection for Migrants | Black Pre-Law Society". blackprelaw.studentgroups.columbia.edu. Retrieved 2025-05-27.
  8. 1 2 3 4 Plaintiffs (2025-02-19). "Case No. 25-cv-1766: Complaint (Administrative Procedure Act Case)" (PDF). United States District Court - Northern District of California (San Francisco Division) (aclusocal.org). Retrieved 2025-05-24.
  9. 1 2 3 4 5 Hurley, Lawrence (2025-05-19). "Supreme Court allows Trump to revoke protected status for thousands of Venezuelans". NBC News. Retrieved 2025-05-24.
  10. 1 2 "Order in pending case 24A1059: Noem, Sec., DHS, et al. v. Nat. TPS Alliance, et al" (PDF). supremecourt.gov. 2025-05-19. Retrieved 2025-05-24.
  11. ↑ "OPINION" (PDF). thomsonreuters.com .
  12. ↑ Raymond, Nate (August 29, 2025). "Trump wrongly ended protections for Venezuelan migrants, US appeals court rules". Reuters .
  13. 1 2 Martínez-Beltrán, Sergio (2025-01-10). "Biden extends protections for immigrants from Venezuela, El Salvador and Ukraine". NPR. Retrieved 2025-05-24.
  14. ↑ Rodriguez, Sabrina (2021-01-19). "Trump grants Venezuelans temporary legal status on his way out". POLITICO. Retrieved 2025-05-23.
  15. 1 2 3 4 "Deferred Enforced Departure for Certain Venezuelans". Federal Register of Notices - United States Federal Archive (federalregister.gov). 2021-01-25. Retrieved 2025-05-23.
  16. 1 2 3 4 5 "POTUS issues 18-month Deferred Enforced Departure (DED) for certain Venezuelans". Immigration Policy Tracking Project. Retrieved 2025-05-23.
  17. 1 2 Sacchetti, Maria; Hunter, Tatum; LeVine, Marianne; Goodwin, Liz; Jouvenal, Justin; Marimow, Ann (2025-05-22). "Under Trump, some immigrants lose protections — others don't. Why?". The Washington Post. ISSN   0190-8286 . Retrieved 2025-05-24.
  18. ↑ "Notice: Designation of Venezuela for Temporary Protected Status and Implementation of Employment Authorization for Venezuelans Covered by Deferred Enforced Departure". Federal Register of Notices - United States Federal Archive (federalregister.gov). 2021-03-09. Retrieved 2025-05-23.
  19. ↑ Initial mailing addresses in (DOJ 3/21) incorrect, reprint listed here: https://www.justice.gov/eoir/page/file/1379196/dl?inline
  20. ↑ "Employment Authorization for Venezuelan F–1 Nonimmigrant Students Experiencing Severe Economic Hardship as a Direct Result of the Current Humanitarian Crisis in Venezuela". Federal Register of Notices - United States Federal Archive (federalregister.gov). 2021-04-22. Retrieved 2025-05-23.
  21. ↑ "Notice of initial registration period extensions: Extension of initial registration periods for new temporary protected status applicants under the designations for Venezuela, Syria, and Burma; Correction to the Notice on the Designation of Venezuela for Temporary Protected Status and Implementation of Employment Authorization for Venezuelans Covered by Deferred Enforced Departure". Federal Register of Notices - United States Federal Archive (federalregister.gov). 2021-08-04. Retrieved 2025-05-23.
  22. ↑ Federal Register of Notices (2021-09-08). "Extension of the Designation of Venezuela for Temporary Protected Status" . Retrieved 2025-05-23.
  23. 1 2 Santana, Rebecca; Spagat, Elliot (2023-09-21). "The US is allowing hundreds of thousands of Venezuelans in the country to work legally". AP News. Retrieved 2025-05-24.
  24. 1 2 Garcia, Regina; Spagat, Elliot (2023-09-23). "With temporary status for Venezuelans, the Biden administration turns to a familiar tool". AP News. Retrieved 2025-05-24.
  25. ↑ "Biden Administration Redesignates Temporary Protected Status (TPS) for Venezuela | New York City Central Labor Council, AFL-CIO". nycclc.org. 2023-09-22. Retrieved 2025-05-24.
  26. ↑ Moslimani, Mohamad (2024-03-29). "How Temporary Protected Status has expanded under the Biden administration". Pew Research Center. Retrieved 2025-05-24.
  27. ↑ Rose, Joel (2023-09-20). "U.S. will expand Temporary Protected Status to hundreds of thousands of Venezuelans". NPR. Retrieved 2025-05-24.
  28. ↑ Bush-Joseph, Kathleen; Muzaffar, Chishti (2022-10-26). "Amid Record Venezuelan Arrivals, Biden Administration Embraces Border Expulsions Policy". migrationpolicy.org. Retrieved 2025-05-27.
  29. ↑ Al Jazeera Staff. "Biden extends temporary status for immigrants from Ukraine, Venezuela". Al Jazeera. Retrieved 2025-05-23.
  30. 1 2 "Biden Administration announced the extension of Temporary Protected Status (TPS) for eligible nationals of El Salvador, Sudan, Ukraine, and Venezuela – CIRA". 15 January 2025. Retrieved 2025-05-24.
  31. ↑ "DHS to Extend Temporary Protected Status for Venezuela | Homeland Security". www.dhs.gov. Retrieved 2025-05-27.
  32. ↑ "Extension of the 2023 Designation of Venezuela for Temporary Protected Status". Federal Register of Notices - United States Federal Archive (federalregister.gov). 2025-01-17. Retrieved 2025-05-24.
  33. ↑ Salomon, Gisela (2025-01-10). "Biden extends time in US for 800,000 Venezuelans, Salvadorans as Trump readies immigration crackdown". AP News. Retrieved 2025-05-24.
  34. 1 2 3 USCRI (2025-05-21). "Administration Revokes Protections for Venezuelans". U.S. Committee for Refugees and Immigrants. Retrieved 2025-05-23.
  35. 1 2 Marcos, Coral Murphy (2025-05-20). "What is temporary protected status and who is affected by Trump's crackdown?". The Guardian. ISSN   0261-3077 . Retrieved 2025-05-26.
  36. ↑ "Curtailment of Humanitarian Immigration Benefits | NAFSA". National Association for Foreign Student Affairs (www.nafsa.org). 2025-03-11. Retrieved 2025-05-29.
  37. 1 2 3 "Termination of the October 3, 2023 Designation of Venezuela for Temporary Protected Status". Federal Register. 2025-02-05. Retrieved 2025-05-26.
  38. 1 2 3 Plaintiffs (2025-02-20). "Case No. 25-cv-1766: Plaintiff's notice of motion and motion to postpone effective date of agency action; Memorandum of points and authorities in support thereof" (PDF). United States District Court - Northern District of California (San Francisco Division) (aclusocal.org). Retrieved 2025-05-24.
  39. 1 2 Santana, Rebecca; Salomon, Gisela (2025-02-03). "Trump administration ends temporary deportation protection for 350,000 Venezuelans". AP News. Retrieved 2025-05-25.
  40. 1 2 "TPS Holders Sue the Trump Administration Over Unlawful Attempt to Strip Protection From Venezuelans – National TPS Alliance" . Retrieved 2025-05-24.
  41. 1 2 "National TPS Alliance v. Noem, 3:25-cv-01766 - CourtListener.com". CourtListener. Retrieved 2025-05-24.
  42. 1 2 3 4 5 VanSickle, Abbie; Liptak, Adam (2025-05-19). "Supreme Court Lets Trump Lift Deportation Protections for Venezuelans". The New York Times. ISSN   0362-4331 . Retrieved 2025-05-24.
  43. ↑ "Alien Enemies Act: The 1798 law Trump used to deport migrants". www.bbc.com. 2025-05-14. Retrieved 2025-05-27.
  44. 1 2 Totenberg, Nina (2025-04-07). "Supreme Court backs Trump in controversial deportations case". NPR. Retrieved 2025-05-26.
  45. ↑ "Invocation of the Alien Enemies Act Regarding the Invasion of The United States by Tren De Aragua". The White House. 2025-03-15. Retrieved 2025-05-27.
  46. ↑ "Compliance with Court Order Regarding 2023 Designation of TPS Venezuela | USCIS". www.uscis.gov. 2025-04-02. Retrieved 2025-05-27.
  47. ↑ Har, Janie (2025-03-31). "Judge pauses Trump administration plans to end temporary legal protections for Venezuelans". AP News. Retrieved 2025-05-24.
  48. ↑ Cohen, Luc (2025-03-31). "Judge blocks Trump administration from stripping deportation protections for Venezuelans". Reuters. Retrieved 2025-05-24.
  49. ↑ "Motion to Shorten Time – #96 in National TPS Alliance v. Noem (N.D. Cal., 3:25-cv-01766) – CourtListener.com". CourtListener. Retrieved 2025-05-27.
  50. ↑ "Order on Motion for Miscellaneous Relief AND Order on Motion to Shorten Time – #102 in National TPS Alliance v. Noem (N.D. Cal., 3:25-cv-01766) – CourtListener.com". CourtListener. Retrieved 2025-05-27.
  51. 1 2 "Tracking Trump and Latin America: Migration—Supreme Court Permits TPS End for Venezuelans | AS/COA". www.as-coa.org. 2025-05-20. Retrieved 2025-05-24.
  52. ↑ Chung, Andrew (2025-05-20). "US Supreme Court lets Trump end deportation protection for Venezuelans". Reuters. Retrieved 2025-05-23.
  53. ↑ "Supreme Court lets Trump end deportation protections for Venezuelans". www.bbc.com. 2025-05-20. Retrieved 2025-05-27.
  54. ↑ "Docket for 24A1059". www.supremecourt.gov. Retrieved 2025-05-26.
  55. 1 2 "Temporary Protected Status | USCIS". www.uscis.gov. 2025-05-21. Archived from the original on 2025-05-26. Retrieved 2025-05-25.
  56. ↑ Sherman, Mark (2025-05-19). "Supreme Court allows Trump to strip legal protections from 350,000 Venezuelans who risk deportation". AP News. Retrieved 2025-05-24.
  57. ↑ Long, Colleen; Merica, Dan (2024-11-10). "Trump on Day 1: Begin deportation push, pardon Jan. 6 rioters and make his criminal cases vanish". AP News. Retrieved 2025-05-24.
  58. ↑ "Invocation of the Alien Enemies Act Regarding the Invasion of the United States by Tren de Aragua". Federal Register. 2025-03-20. Retrieved 2025-05-26.
  59. ↑ "ACLU and Democracy Forward Sue Trump Administration Over Expected Invocation of Alien Enemies Act". American Civil Liberties Union. Retrieved 2025-05-26.
  60. 1 2 Gurley, Lauren Kaori; Kaur, Anumita (2025-05-22). "Venezuelan migrants lost legal status. Here's what that means for the economy". The Washington Post. ISSN   0190-8286 . Retrieved 2025-05-24.
  61. ↑ Snow, Anita; Attanasio, Cedar (2024-11-14). "1 million migrants in the US rely on temporary protections that Trump could target". AP News. Retrieved 2025-05-26.
  62. 1 2 "The contributions of temporary protected status holders to the U.S. economy" (PDF). American Immigration Council (americanimmigrationcouncil.org). September 2023. Retrieved 2025-05-26.
  63. ↑ "Labor Force Status of Women and Men". DOL. Archived from the original on 2025-05-26. Retrieved 2025-05-26.
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