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Warner Norcross + Judd LLP is a corporate law firm with over 230 attorneys serving clients in nine offices throughout Michigan. Among the largest law firms in Michigan, Warner works in virtually all areas of business law.

Michigan Law Firm - Warner Norcross + Judd LLP

On April 14, 2025, the U.S. District Court for the District of Massachusetts issued a significant ruling temporarily blocking the Trump administration’s plan to terminate the parole and employment authorization of over 500,000 individuals from Cuba, Haiti, Nicaragua and Venezuela (“CHNV parolees”). These individuals were granted humanitarian parole and work authorization under the CHNV parole programs introduced during the prior administration.

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The Trump administration’s order, originally set to take effect on April 24, 2025, would have revoked parole and associated Employment Authorization Documents (EADs) issued under the CHNV programs without individualized review. The court’s decision temporarily halts that action, preserving work authorization and legal status for affected individuals pending further judicial review.

Implications for Employers

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Employers with CHNV parolee employees should take note of the following:

No Immediate Reverification Required: The stay order prevents the Department of Homeland Security (DHS) from enforcing early revocations of CHNV-based EADs. These documents remain valid until their original expiration dates. Employers should not conduct reverification or take adverse employment actions related to this program at this time.

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Follow Existing I-9 Compliance Procedures: Employers should continue to rely on the expiration date printed on the EAD when assessing employment authorization and conducting reverification, consistent with current Form I-9 rules.

Prepare for Future Updates: This stay is temporary, and the legal challenge remains ongoing. Employers should be prepared for future guidance depending on the outcome of the case or any appellate review.

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Background on the Court’s Ruling

In Doe et al. v. Noem et al., Judge Indira Talwani found that DHS’ blanket termination of parole and work authorization — without case-by-case review — raises serious legal questions and could result in irreparable harm to those affected. While the administration argued that DHS’ authority over parole is broad, the court held that such actions remain subject to judicial review, especially when they would result in abrupt loss of lawful presence and work authorization.

Judge Talwani’s order stays both the rule terminating the CHNV program and the individualized electronic notices issued to parolees informing them of revocation, pending further court proceedings.

Recommendations for Employers

Monitor Legal and Agency Updates: Stay informed about developments in the case and any agency implementation guidance.

Reinforce Internal Compliance: Ensure HR and compliance teams are aware that the revocation is currently on hold and that no changes in employment status should be made based solely on the April 24 date.

Consult Legal Counsel as Needed: Legal teams can provide tailored guidance as the litigation evolves and help employers assess risk and readiness for future reverification or other compliance changes.

We will continue to monitor developments and provide updates as the case progresses. If you have employees working under CHNV-based parole or related questions, please contact a member of our immigration team.

Senior Counsel

Sarah R. Bileti

Associate

Christopher M. LeClair

Daniel C. “Dan” Persinger

Immigration

Update: Federal Court Temporarily Blocks Trump Administration’s Termination of CHNV Parole Program — Work Authorization Remains Valid

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Update: Federal Court Temporarily Blocks Trump Administration’s Termination of CHNV Parole Program — Work Authorization Remains Valid

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