Haitian TPS and the Black Immigrant Rights Movement

Introduction: The Movement Within the Movement

On June 25, 2026, the Supreme Court handed down Mullin v. Doe, a decision that allowed the Trump administration to terminate Temporary Protected Status for approximately 350,000 Haitians. The legal holding was about statutory interpretation and the scope of judicial review. But for a growing movement of Black immigrant rights organizations, the case was never only about the law. It was about whether the United States government could use race-neutral administrative procedures to enact what they saw as a racially motivated policy. The evidence was damning: a president who called Haiti a "shithole country," who claimed Haitian immigrants "all have AIDS" and "eat pets," and a DHS secretary who described immigrants as "leeches" and "entitlement junkies." The Black immigrant rights movement had spent nearly two decades building the organizational infrastructure to challenge exactly this kind of policy. Mullin v. Doe was both its greatest test and its most devastating defeat.

The organizations at the center of this movement are not new. The Black Alliance for Just Immigration (BAJI) was founded in 2006, years before the first TPS designation for Haiti. The UndocuBlack Network was founded in 2016, a year after Haiti was first redesignated for TPS following the 2010 earthquake. The Haitian Bridge Alliance (HBA) began its work even earlier, serving Haitian migrants at the U.S.-Mexico border. These organizations, along with African Communities Together (ACT) and the UndocuBlack Network, have built a framework that explicitly connects the fight for Haitian TPS to the broader struggle for racial justice in America. They argue that anti-Blackness shapes U.S. immigration policy toward Haiti in ways that are distinct from the treatment of non-Black TPS countries, and they have the court rulings to prove it (BAJI; UndocuBlack Network; Haitian Bridge Alliance).

Two lower courts agreed with them. In February 2026, Judge Timothy J. Kelly of the U.S. District Court for the District of Columbia found that the Trump administration's termination of TPS for Haiti was "motivated, at least in part, by racial animus" (Politifact). In a separate case, Judge William G. Young of the District of Massachusetts found similar evidence in the pattern of TPS terminations affecting Black African nations (Lawyers for Civil Rights). But the Supreme Court, in a 6-3 decision, held that the Immigration and Nationality Act's judicial review bar prevented courts from considering these claims. The movement had won the factual argument. It had lost the legal one. This blog post tells the story of that movement, its leaders, its victories, its defeats, and its future.

"The statements fairly shout, in their racial undertones and overtones alike, that race entered into the President's resolve to remove Haitians from this country. Haitians are Black. (Norwegians and Swedes not so much.)"

The PROVEN Framework

This blog post uses the PROVEN framework to analyze the role of the Black immigrant rights movement in the fight for Haitian TPS and the implications of the Mullin v. Doe decision. Problem: The termination of TPS for Haiti was achieved through a process that two lower federal courts found to be tainted by racial animus. The Supreme Court's decision in Mullin v. Doe insulated that termination from judicial review, effectively blessing a policy that the Black immigrant rights movement argues is rooted in anti-Blackness. The result is that approximately 350,000 Haitian TPS holders, the vast majority of whom are Black, face deportation to a country that the State Department warns Americans not to visit (BAJI; Haitian Bridge Alliance; Politifact).

Root Cause: The root cause is twofold. First, the statutory framework of the Immigration and Nationality Act grants the Secretary of Homeland Security virtually unreviewable discretion over TPS designations, a framework that the Supreme Court interpreted in Mullin v. Doe to foreclose even constitutional claims of racial discrimination. Second, the evidentiary record demonstrates that the Trump administration's decision to terminate TPS for Haiti was shaped by racist rhetoric and stereotypes about Haitians and Black immigrants more broadly. Justice Kagan's dissent cataloged this record in devastating detail: Trump's "shithole countries" comment, his false claims about Haitian immigrants having AIDS and eating pets, and DHS Secretary Noem's characterization of immigrants as "leeches" (Supreme Court; Cyrus Mehta Immigration Blog; NPR).

Outcome: The Supreme Court's decision has devastated the Haitian community and the organizations that serve it. TPS ended on July 27-28, 2026. Work authorization has been revoked. Deportation protections have been lifted. Families are being separated. The Black immigrant rights movement, which had spent years building legal and advocacy infrastructure, has been forced to shift from litigation to emergency response. BAJI has called the decision "a devastating blow to Black immigrants and to the principle of equal protection under the law." The Haitian Bridge Alliance and the Congressional Black Caucus held a national TPS town hall on July 1, 2026, drawing over 500 participants, to coordinate the community's response (BAJI; Haitian Bridge Alliance).

Vision: The Black immigrant rights movement envisions a legal and policy framework that recognizes the unique vulnerability of Black immigrants in the U.S. immigration system. This includes permanent residency for long-term TPS holders, the elimination of racial bias in immigration enforcement, and a recognition that anti-Blackness is a systemic feature of U.S. immigration policy. BAJI's "Until We're Free" coalition, launched in 2021, articulates this vision explicitly: immigration justice cannot be achieved without racial justice, and racial justice cannot be achieved without immigrant justice (BAJI; UndocuBlack Network).

Engagement: The movement has engaged in multiple strategies simultaneously: litigation (three federal lawsuits alleging racial animus in TPS termination), legislative advocacy (the Congressional Black Caucus's push for TPS extension legislation), community organizing (know-your-rights forums, emergency preparedness planning, and bail fund support), and public education (the #ImmigrationIsABlackIssue campaign and media outreach). These strategies have built a powerful infrastructure, even if they have not yet achieved their ultimate goal of permanent protections for Haitian TPS holders (African Communities Together; Lawyers for Civil Rights; Haitian Bridge Alliance).

Next Steps: Immediate priorities include the passage of Senate Bill S. 4814, which would extend Haitian TPS for three additional years; continued litigation to protect individual TPS holders from deportation; expansion of the Black Immigrants Bail Fund; and a sustained campaign to educate the public and policymakers about the role of racial animus in the TPS termination. The movement is also looking toward the November 2026 midterm elections as an opportunity to change the political calculus in Congress (Haitian Bridge Alliance; Cyrus Mehta Immigration Blog).

The Founding of a Movement: From Oakland to the Nation

It is impossible to understand the fight for Haitian TPS without understanding the organizational infrastructure that the Black immigrant rights movement has built over the past two decades. The movement did not emerge in response to the 2010 Haiti earthquake or the 2018 Saget litigation or the 2026 Supreme Court decision. It has been building since at least 2006, when a small group of activists gathered in Oakland, California, to address a fundamental gap in the American racial justice landscape.

BAJI was founded in 2006 with a $35,000 seed grant. Its mission was to bring together African American and Black immigrant communities, two groups that had been historically divided despite sharing common experiences of racial discrimination in the United States. The organization's founders recognized that the mainstream immigration reform movement often overlooked the specific experiences of Black immigrants, while the mainstream civil rights movement often overlooked the specific vulnerabilities of immigrants within Black communities. BAJI was designed to bridge that gap. By 2024, the organization's budget had grown to $3.6 million, and it had chapters in Oakland, Los Angeles, New York City, Atlanta, and Miami (BAJI).

Fun Fact: From Seed Grant to National Force BAJI was founded in 2006 with a $35,000 seed grant. By 2024, its annual budget had grown to $3.6 million. The organization now has chapters in five major U.S. cities and has become the leading voice for Black immigrant rights in the United States (BAJI).

Nana Gyamfi, BAJI's Executive Director, has been a movement attorney for more than 25 years. She has written extensively about the intersection of race and immigration, including a powerful piece for the AFRO titled "Why does America keep punishing Haitians for wanting freedom?" In that essay, published in April 2025, Gyamfi traced the history of anti-Haitian sentiment in U.S. policy from the post-revolutionary embargo of the early 19th century through the AIDS stigmatization of the 1980s to the TPS termination of 2025-2026. "Haitians have been punished for their Blackness and their revolutionary spirit for more than two centuries," Gyamfi wrote. "The TPS termination is simply the latest chapter in a long and shameful history" (AFRO; BAJI).

The UndocuBlack Network was founded in January 2016, at the first national convening of Black undocumented immigrants in Miami. It was a historic moment: for the first time, Black undocumented immigrants had a national organization that centered their specific experiences and needs. The network describes itself as "a multi-generational network of Black immigrants that fosters community, facilitates access to resources, and advocates to transform the realities of our people, so we are thriving and living our fullest lives." Its founding was driven by the recognition that the mainstream undocumented youth movement, epitomized by the Dreamer movement, often did not adequately represent the experiences of Black undocumented immigrants, who face unique forms of marginalization both within and outside immigrant communities (UndocuBlack Network).

Patrice Lawrence, the former Executive Director of the UndocuBlack Network, articulated this perspective powerfully in media interviews about the TPS crisis. "The US government is very united in how they see Black people," Lawrence said. "Whether you are a U.S. citizen, a lawful permanent resident, or a TPS holder, if you are Black, you are subject to a system that devalues your life and your labor. The TPS termination is not just an immigration policy. It is a racial policy" (NPR; UndocuBlack Network).

The Haitian Bridge Alliance, led by Executive Director Guerline Jozef, has been at the forefront of the TPS fight from the beginning. Jozef, who co-founded the Black Immigrants Bail Fund, has become one of the most recognizable faces of the Haitian TPS advocacy movement. HBA's motto, "Anpil men chay pa lou" (Many hands make the load light), reflects the organization's community-centered approach to advocacy. The organization provides direct legal services, emergency assistance, impact litigation, and policy advocacy for Haitian migrants, with a particular focus on those at the U.S.-Mexico border (Haitian Bridge Alliance).

Fun Fact: "Anpil men chay pa lou" The Haitian Bridge Alliance's motto is "Anpil men chay pa lou," a Haitian Creole proverb that translates to "Many hands make the load light." The phrase reflects the organization's commitment to collective action and community solidarity (Haitian Bridge Alliance).

The "Shithole Countries" Doctrine: How Racism Entered the Evidentiary Record

The factual record in the TPS litigation is extraordinary in its detail and its ugliness. No modern immigration case has presented such clear evidence that racial animus played a role in a major policy decision. The evidence came from multiple sources: the President's own words, the statements of his top immigration officials, the pattern of TPS terminations affecting Black versus non-Black countries, and the historical context of U.S. treatment of Haitian migrants.

The most famous entry in that record is President Trump's 2018 comment, reported by multiple news outlets, in which he referred to Haiti and African nations as "shithole countries" and expressed a preference for immigrants from Norway. The comment was made during a White House meeting about immigration reform, and it was confirmed by multiple participants. It quickly became a symbol of the administration's racialized approach to immigration policy (AP News; Politifact).

But the evidentiary record went far beyond that single comment. During the 2024 presidential campaign, Trump repeatedly made false and inflammatory statements about Haitian immigrants. In Springfield, Ohio, he claimed that Haitian immigrants were "eating the dogs," "eating the cats," and "eating the pets of the people that live there." The claim was baseless. Local officials, including the city manager of Springfield, confirmed that there was no evidence of such behavior. But the damage was done. The false story spread across social media and cable news, and it was amplified by Trump's running mate, Senator J.D. Vance, who acknowledged on national television that he was willing to "create stories" to draw attention to immigration (Cyrus Mehta Immigration Blog; NPR).

Trump also claimed that Haitian immigrants "probably have AIDS" and described Haitian immigration as "like a death wish for our country." He said that immigrants were "poisoning the blood of our country" and had "bad genes." DHS Secretary Kristi Noem described some immigrants as "leeches," "entitlement junkies," and "foreign invaders" who "suck dry our hard-earned tax dollars." These statements were not offhand remarks. They were central to the administration's messaging about immigration, and they were specifically directed at Haitian and other Black immigrants (Supreme Court; Cyrus Mehta Immigration Blog).

The Cyrus Mehta Immigration Blog, in a June 27, 2026 analysis titled "Mullin v. Doe: Blessing a Race-Neutral Cover for Racial Animus," described the majority's treatment of this evidence as deeply troubling. Mehta and his co-author Damira Zhanatova wrote that the Court "treats racialized hostility as legally irrelevant so long as the government can recast it as general immigration policy." They noted that the majority "does not deny the ugly rhetoric. It simply says the statements are not 'overtly racial' and can be understood as policy views about immigration and TPS." The blog post drew a direct line from Mullin v. Doe to the Court's 2018 decision in Trump v. Hawaii, where the Court had similarly looked past Trump's overt animus toward Muslims to uphold a travel ban targeting Muslim-majority nations (Cyrus Mehta Immigration Blog).

Justice Kagan's dissent in Mullin v. Doe addressed the evidence head-on. She cataloged Trump's statements at length, noting pointedly that the majority "would not even repeat them in full." Her analysis was devastating: "The statements fairly shout, in their racial undertones and overtones alike, that race entered into the President's resolve to remove Haitians from this country." She emphasized the contrast with non-Black TPS countries, writing: "Haitians are Black. (Norwegians and Swedes not so much.)" The references to filth, disease, and primitiveness were, in her words, "shot through with racial stereotypes and tropes" (Supreme Court; Cyrus Mehta Immigration Blog).

"The statements fairly shout, in their racial undertones and overtones alike, that race entered into the President's resolve to remove Haitians from this country."

Black TPS vs. Non-Black TPS: A Comparative Analysis

One of the most powerful arguments made by the Black immigrant rights movement is that the treatment of Haitian TPS holders must be understood in comparison to the treatment of TPS holders from non-Black countries. The movement argues that anti-Blackness shapes U.S. immigration policy in ways that are distinct from general anti-immigrant sentiment, and that the TPS termination pattern provides clear evidence of this distinction.

Venezuela, a non-Black majority country, also had its TPS designation terminated by the Trump administration. But advocates point to significant differences in how the termination was handled. The rhetoric about Venezuelan immigrants was less racialized, less dehumanizing, and less tied to centuries-old stereotypes about Black people. The timeline for termination was different. And critically, Venezuelan TPS holders received more sympathetic treatment from the courts and from the broader public (Borderless Magazine; African Communities Together).

The ACT v. Noem lawsuit, filed in December 2025 by African Communities Together, specifically alleged that "the pattern of TPS cancellations was motivated by racial and/or national origin animus against African and other non-white or non-European immigrants." The lawsuit challenged the termination of TPS for South Sudan, another predominantly Black African nation. The pattern was clear: the administration was systematically ending protections for Black and African countries while maintaining or extending them for other nations (African Communities Together).

Borderless Magazine, in a May 2023 article titled "How US Policy Drives and Denies Black Immigration," documented the historical patterns of discrimination against Black immigrants in the U.S. immigration system. The article noted that Black immigrants face higher bond amounts, higher detention rates, and lower asylum grant rates than other immigrant groups. These disparities are not accidental; they reflect a system that has been shaped by anti-Black racism from its origins (Borderless Magazine).

The comparison also extends to the legal treatment of the claims. Two lower courts found that racial animus played a role in the TPS termination for Haiti. Judge Reyes in the District of Columbia explicitly found that the termination was "motivated, at least in part, by racial animus" (Politifact; AP News). But the Supreme Court's decision in Mullin v. Doe made that finding legally irrelevant by holding that the courts lacked jurisdiction to consider such claims in the first place. The message was clear: even if you can prove that a policy was motivated by racism, the courts will not act if the statute bars review (Cyrus Mehta Immigration Blog).

The Black immigrant rights movement has argued that this is precisely the point. The structure of the Immigration and Nationality Act, by granting unreviewable discretion over TPS terminations, creates a legal framework in which racial animus can operate without consequence. The movement's legal strategy has been designed to expose this structural problem, even if individual cases may be lost. As Nana Gyamfi wrote in the AFRO, "The question is not whether the TPS termination was motivated by racism. The courts have already said it was. The question is whether our legal system has the capacity to address racism when it operates through race-neutral administrative procedures" (AFRO; BAJI).

Justice Kagan's Dissent: A Document for the Ages

Justice Elena Kagan's dissenting opinion in Mullin v. Doe, joined by Justices Sonia Sotomayor and Ketanji Brown Jackson, has already been described as one of the most powerful dissents in the Court's recent history. It is remarkable not only for its legal analysis but for its willingness to confront the racial reality that the majority chose to ignore. Kagan's opinion is, in many ways, the legal culmination of the Black immigrant rights movement's arguments. It takes the evidence of racial animus seriously. It applies the framework of Arlington Heights faithfully. And it names what the majority would not: that the President of the United States used racist language to describe Haitians, and that this language was connected to the policy decision to terminate their protections.

Kagan's dissent begins with the statutory question: whether the Secretary of Homeland Security followed the mandatory consultation requirements of the Immigration and Nationality Act before terminating TPS. The majority held that the judicial review bar prevented courts from examining even whether the required procedures were followed. Kagan disagreed. She argued that the statute requires the Secretary, "after consultation with appropriate agencies of the Government," to review country conditions and determine whether the TPS criteria continue to be met. The mandatory steps, she wrote, are not optional. The government's "scant email exchange with the State Department" did not satisfy them (Supreme Court; Cyrus Mehta Immigration Blog).

But it is Kagan's treatment of the racial evidence that has drawn the most attention. She applied the equal protection framework established in Arlington Heights, under which plaintiffs need only show that race was "a motivating factor" in the decision, not the only or even the primary one. She emphasized that courts must consider historical background, sequence of events, and contemporary statements by decisionmakers. She then quoted the President's statements at length, writing with a directness that the majority conspicuously avoided: "Haitians were described as 'eating the dogs,' 'eating the cats,' and 'eating the pets of the people that live there.' Haitians in the United States 'probably have AIDS.' Haiti was called a 'shithole country,' 'filthy, dirty, disgusting.' Haitian immigration was said to be 'like a death wish for our country'" (Supreme Court).

Her most memorable line cuts to the heart of the matter: "Haitians are Black. (Norwegians and Swedes not so much.)" The parenthetical is a devastating contrast. Trump had expressed a preference for immigrants from Norway, a predominantly white country. The implication was unmistakable: the TPS termination was about race, not about country conditions. As Kagan wrote, the references to filth, disease, and primitiveness were "shot through with racial stereotypes and tropes." The statements "fairly shout, in their racial undertones and overtones alike, that race entered into the President's resolve to remove Haitians from this country" (Supreme Court).

Under the Arlington Heights framework, Kagan concluded, the Haiti TPS termination was "irretrievably tainted." If race entered the decision at all, the policy could not stand. But the majority had a different view. Justice Alito, writing for the Court, acknowledged that political discourse has become "increasingly couched in terms that would have scandalized the public just a short time ago." He nevertheless concluded that the statements were not enough to show that Haiti's TPS designation was terminated because of the race of the Haitian people (Supreme Court; NPR).

Justice Clarence Thomas went even further. In a concurring opinion, Thomas argued that "aliens have no equal protection rights against the federal government." He contended that the Equal Protection Clause applies to the states, not the federal government, and criticized the Court's long-standing recognition of an equal protection component in the Fifth Amendment's Due Process Clause. Thomas's position, while not adopted by the majority, points toward an even more restrictive future in which constitutional claims could be entirely barred in TPS litigation (Cyrus Mehta Immigration Blog).

The Cyrus Mehta Immigration Blog described the implications: "The majority's reading makes procedural defects far harder to challenge, even where the agency skipped or truncated the very steps Congress prescribed. It also means that if a client's TPS termination challenge rests on consultation failures, arbitrary review practices, or other process defects, the path to relief is now far narrower." The blog also noted that Thomas's concurrence "is notable because it points toward an even more restrictive future in which not only APA claims, but also constitutional claims, could be barred entirely in TPS litigation" (Cyrus Mehta Immigration Blog).

Fun Fact: The Majority Would Not Repeat Them Justice Kagan noted in her dissent that the Mullin majority "would not even repeat them in full" when referencing Trump's comments about Haitians. The majority's reluctance to engage with the actual language of the President's statements spoke volumes about their power and their ugliness (Supreme Court).

The Congressional Black Caucus Takes a Stand

While the courts were the primary arena for the TPS fight, the legislative branch was not silent. The Congressional Black Caucus, under the leadership of Chair Representative Yvette Clarke of New York's 9th Congressional District, made Haitian TPS a signature priority in 2025 and 2026. The CBC's involvement reflected the movement's success in framing TPS as a racial justice issue. When the caucus's members spoke about TPS, they did not speak only about immigration law. They spoke about the history of anti-Blackness in American policy, about the specific vulnerability of Black immigrants, and about the moral obligation to protect a community that had been repeatedly targeted by the Trump administration (Haitian Bridge Alliance; NPR).

Representative Ayanna Pressley of Massachusetts's 7th Congressional District, co-chair of the House Haiti Caucus, was one of the most active voices in the fight. Pressley led a discharge petition that successfully brought a TPS extension bill to the floor of the House, where it passed with bipartisan support. The bill would have extended TPS for Haiti for three additional years, but it stalled in the Senate, where the Republican majority declined to bring it to a vote. Pressley's efforts were a testament to the power of legislative advocacy, even in a divided Congress (Haitian Bridge Alliance).

Minority Leader Hakeem Jeffries participated in the national TPS town hall hosted by the Haitian Bridge Alliance and the Congressional Black Caucus on July 1, 2026. The event drew more than 500 participants and featured speeches from community leaders, legal experts, and members of Congress. Jeffries used the platform to call for immediate legislative action and to condemn the Supreme Court's decision. "The Court has given this administration a license to discriminate," Jeffries said. "It is up to us, in Congress and in communities across this country, to take that license away" (Haitian Bridge Alliance).

The CBC's engagement with the TPS issue was not limited to the halls of Congress. Caucus members visited Little Haiti in Miami, held roundtables with TPS holders in New York and Boston, and participated in community events organized by BAJI, the UndocuBlack Network, and the Haitian Bridge Alliance. Their presence signaled that the movement's framing of TPS as a racial justice issue had been accepted at the highest levels of Black political leadership (NPR).

Timeline of Struggle: From Saget to Mullin

2006: BAJI founded in Oakland, California, with a $35,000 seed grant, bringing together African American and Black immigrant communities Jan 2016: UndocuBlack Network founded at first national convening of Black undocumented immigrants in Miami 2018: Saget et al v. Trump filed, the first trial challenging TPS termination on racial animus grounds 2021: BAJI launches "Until We're Free" coalition, calling for immigration policies rooted in racial justice Jun 2024: BAJI welcomes TPS redesignation for Haiti, calls for deportation moratorium Mar 2025: Lawsuit filed in Boston alleging racial bias in accelerated TPS rollback; Lawyers for Civil Rights represents HAU, VAM, and UBN Apr 2025: Nana Gyamfi publishes "Why does America keep punishing Haitians for wanting freedom?" in the AFRO Dec 2025: ACT v. Noem filed, challenging South Sudan TPS termination and alleging a pattern of racial animus against African nations Feb 2026: Judge Reyes finds Trump/Noem TPS termination "motivated at least in part by racial animus" Jun 25, 2026: Mullin v. Doe (6-3) allows TPS termination; Kagan, Sotomayor, and Jackson dissent; Justice Kagan's dissent calls the racial evidence "plain to see" Jun 27, 2026: Cyrus Mehta Immigration Blog publishes "Mullin v. Doe: Blessing a Race-Neutral Cover for Racial Animus" Jul 1, 2026: HBA and Congressional Black Caucus hold national TPS town hall with 500+ participants Jul 6, 2026: NPR publishes "Supreme Court said racism wasn't a factor; Haitians think otherwise" Jul 27-28, 2026: TPS officially terminates; work authorization revoked; deportation protections lifted Jul 29, 2026: This blog post is published, documenting the Black immigrant rights movement's fight The People Behind the Movement: Profiles in Leadership

The Black immigrant rights movement is not an abstraction. It is built and sustained by individuals who have dedicated their lives to the fight for justice. Understanding the movement requires understanding the people who lead it.

Guerline Jozef is the Executive Director of the Haitian Bridge Alliance and a co-founder of the Black Immigrants Bail Fund. Born in Haiti, Jozef has been at the forefront of the TPS fight for more than a decade. She has testified before Congress, organized national advocacy campaigns, and provided direct legal services to thousands of Haitian migrants. Under her leadership, HBA has become one of the most effective advocacy organizations in the immigrant rights movement, with a particular focus on the intersection of race and immigration. Jozef's leadership has been characterized by both legal acumen and deep community rootedness. She is known for her willingness to challenge even her allies when she believes they are not centering the needs of Black immigrants (Haitian Bridge Alliance).

Nana Gyamfi is the Executive Director of BAJI and a movement attorney with more than 25 years of experience. She has been a leading voice in the fight for Black immigrant rights, arguing that the struggle for racial justice in the United States must include the fight for immigrant justice. Her April 2025 piece in the AFRO, "Why does America keep punishing Haitians for wanting freedom?," became a key text in the movement's effort to frame the TPS fight as a racial justice issue. Gyamfi's analysis situates the TPS termination within a longer history of anti-Haitian policy, from the post-revolution embargo to the AIDS stigmatization of the 1980s to the current crisis (AFRO; BAJI).

Patrice Lawrence, the former Executive Director of the UndocuBlack Network, has been a powerful voice for the specific experiences of Black undocumented immigrants. Her statement that "the US government is very united in how they see Black people" captures the movement's central insight: that anti-Blackness is a unifying thread that connects the treatment of African Americans, Afro-Caribbeans, and African immigrants in the U.S. legal system. Lawrence's leadership helped elevate the experiences of Black undocumented immigrants within the broader immigrant rights movement, ensuring that their voices were not marginalized (UndocuBlack Network; NPR).

Diana Konate of African Communities Together has advocated for TPS protections for migrants from across the African continent, including Congo and Mali. ACT's lawsuit challenging the termination of TPS for South Sudan represented a significant expansion of the movement's legal strategy, arguing that the pattern of TPS terminations revealed a broader racial animus against African nations. Konate's work has helped build solidarity between Haitian and African TPS holders, recognizing that they face a common adversary (African Communities Together).

Representative Ayanna Pressley (MA-07) has been the Congressional Black Caucus's most visible advocate for Haitian TPS. As co-chair of the House Haiti Caucus, Pressley has made the protection of Haitian immigrants a signature priority. Her leadership of the discharge petition that brought the TPS extension bill to the House floor demonstrated the power of legislative advocacy, even when the ultimate outcome was blocked in the Senate. Pressley has framed the fight in explicitly racial terms, arguing that the TPS termination is part of a broader pattern of anti-Blackness in American immigration policy (Haitian Bridge Alliance).

Representative Yvette Clarke (NY-09), Chair of the Congressional Black Caucus, has made Haitian TPS a central priority during her tenure. Her leadership has ensured that the CBC speaks with one voice on the issue, and her participation in the July 1 national TPS town hall signaled the caucus's continued commitment to protecting Haitian immigrants. Clarke's district in Brooklyn includes a significant Haitian American community, giving her a direct connection to the families most affected by the TPS termination (Haitian Bridge Alliance; NPR).

Minority Leader Hakeem Jeffries has used his position in House leadership to amplify the CBC's message about TPS. His participation in the national town hall and his public statements condemning the Supreme Court's decision have brought national attention to the issue. Jeffries has called for the passage of Senate Bill S. 4814, which would extend Haitian TPS for three years, and has urged his colleagues in both parties to support the legislation (Haitian Bridge Alliance).

#ImmigrationIsABlackIssue: The Movement's Media Strategy

The Black immigrant rights movement has been remarkably effective at using media and messaging to advance its cause. The UndocuBlack Network created the hashtag #ImmigrationIsABlackIssue to force mainstream immigration discourse to include Black migrants. The hashtag has been used tens of thousands of times across social media platforms and has become a rallying cry for activists who argue that the mainstream immigrant rights movement has too often centered the experiences of non-Black immigrants while marginalizing Black voices (UndocuBlack Network).

The movement's media strategy has also included traditional press outreach, opinion writing, and documentary projects. BAJI has produced multiple reports on the experiences of Black immigrants, including "There Is a Target On Us: The Impact of Anti-Black Racism on African Migrants at Mexico's Southern Border," a joint report with NYU Law School and IMUMI. The organization has also published policy explainers, legal analyses, and community resource guides. The Haitian Bridge Alliance maintains an extensive media presence, issuing press releases, advocacy letters, and regular updates on the TPS situation (BAJI; Haitian Bridge Alliance).

The NPR article published on July 6, 2026, titled "Supreme Court said racism wasn't a factor; Haitians think otherwise," captured the movement's message effectively. The article quoted community members and advocates who rejected the Court's conclusion that the TPS termination was not about race. "They say racism wasn't a factor," one Haitian TPS holder told NPR. "But we have been hearing what they say about us for years. We know what they think of us. We are Black, and they do not want Black people in this country" (NPR).

The Boston Haitian Reporter covered the March 2025 lawsuit alleging racial bias in the TPS rollback, amplifying the voices of local advocates who argued that the administration's actions were discriminatory. The AFRO published Nana Gyamfi's powerful essay connecting the TPS fight to the longer history of anti-Haitian policy. And Borderless Magazine documented the systemic discrimination that Black immigrants face in the U.S. immigration system. Together, these media efforts have helped create a public narrative that centers the experiences and perspectives of Black immigrants (Boston Haitian Reporter; AFRO; Borderless Magazine).

The Black Immigrants Bail Fund: Direct Action for Freedom

One of the most concrete expressions of the Black immigrant rights movement's commitment to community-based justice is the Black Immigrants Bail Fund, co-founded by Guerline Jozef and the Haitian Bridge Alliance. The fund provides bail and bond assistance to Black immigrants who are detained by ICE, with a particular focus on Haitian TPS holders. The fund is based on a simple but powerful premise: no one should be detained simply because they cannot afford to pay for their freedom (Haitian Bridge Alliance).

The need for the bail fund underscores the disparities that the movement has documented. Studies have shown that Black immigrants face higher bond amounts than non-Black immigrants for similar offenses. A study by the Refugee and Immigrant Center for Education and Legal Services (RAICES) found that bond amounts for Black immigrants were 54% higher than those for non-Black immigrants between June 2018 and June 2020. The Black Immigrants Bail Fund was created to address this disparity directly, by providing the resources that Black immigrants need to secure their release from detention while they fight their cases (BAJI; Haitian Bridge Alliance).

The fund has become even more critical since the Mullin v. Doe decision. With TPS terminated and deportation protections lifted, Haitian TPS holders are at increased risk of detention. The bail fund has been working to raise additional resources to meet the anticipated surge in need. HBA's emergency hotline has been receiving hundreds of calls per week from families seeking assistance (Haitian Bridge Alliance).

The Mental Health Crisis: Ayanda and the UndocuBlack Response

The UndocuBlack Network's "Ayanda" program provides peer-to-peer mental health support for Black immigrants, addressing a critical need that has been exacerbated by the TPS crisis. "Ayanda" means "she or he who brings hope" in several African languages, and the program is designed to provide culturally competent mental health care to a community that has been historically underserved by traditional mental health services. The program trains peer supporters who share the experiences of the people they help, creating a support network that is rooted in shared understanding rather than clinical distance (UndocuBlack Network).

The need for mental health support in the Haitian TPS community has intensified dramatically since the Mullin v. Doe decision. Community advocates report widespread anxiety, depression, and trauma among TPS holders who are facing the loss of their legal status, the possibility of deportation, and the potential separation from their families. Parents are terrified of being separated from their U.S. citizen children. Children are asking questions that no parent should have to answer. The Ayanda program has been working to expand its capacity to meet this need, but the resources available are far from sufficient (UndocuBlack Network; Haitian Bridge Alliance).

The mental health crisis is not limited to the individuals directly affected by the TPS termination. It extends to their families, their communities, and the advocates who serve them. BAJI and the UndocuBlack Network have called for increased funding for mental health services in Black immigrant communities, recognizing that the trauma of the TPS crisis will have long-lasting effects that extend far beyond the immediate legal consequences (BAJI; UndocuBlack Network).

Fun Fact: Ayanda Means "She Who Brings Hope" The UndocuBlack Network's "Ayanda" program provides peer-to-peer mental health support for Black immigrants. The name "Ayanda" means "she or he who brings hope" in several African languages, reflecting the program's mission to provide hope and healing to a community facing immense trauma (UndocuBlack Network).

Statistics: The Numbers Behind the Movement

1 in 10 Black people in the US is an immigrant (Pew Research) ~10 million Black immigrants, refugees, and families in the US (BAJI) ~350,000 Haitian TPS holders affected by the Supreme Court ruling 1.3 million+ Family members across all TPS countries affected 218,000 Black immigrants in California (BAJI/USC report) 3 Federal lawsuits alleging racial animus in TPS termination 2 Lower courts found racial animus; Supreme Court rejected $3.6M BAJI's annual budget by 2024 (from $35K seed grant in 2006) Additional Research: The Broader Fight for Black Immigrant Justice

The fight for Haitian TPS is one front in a much larger struggle for Black immigrant justice. The Lawyers for Civil Rights lawsuit filed in March 2025 in Boston explicitly alleged that the administration's accelerated TPS rollback was motivated by racial bias. The lawsuit, brought on behalf of the Haitian Americans United (HAU), the Vermont Asylum Assistance Project (VAM), and the UndocuBlack Network (UBN), argued that the administration's actions were part of a pattern of discrimination against Black and brown immigrants (Lawyers for Civil Rights).

The ACT v. Noem lawsuit, filed in December 2025, challenged the termination of TPS for South Sudan and alleged that the administration had engaged in a pattern of racial animus against African nations. The lawsuit was part of a broader strategy by the Black immigrant rights movement to document and challenge the systemic nature of discrimination in the TPS program. By bringing multiple lawsuits targeting different countries, the movement aimed to demonstrate that the problem was not limited to any single nation but was a feature of the administration's approach to Black immigration (African Communities Together).

NPR's reporting on the TPS crisis has been extensive and deeply reported. The July 29, 2026 article, "Haitian TPS holders in South Florida brace for end of their legal status," profiled Farah Larrieux, a Haitian TPS holder who has lived in the United States for two decades and now faces the loss of everything she has built. Larrieux's story is emblematic of the human cost of the TPS termination. She works two jobs, has run out of wall space for her community service awards, and has covered the window in her front door with paper because she is afraid ICE will show up at her home. "I can tell you that I feel empty," she told NPR. "Like I'm living a nightmare" (NPR).

NPR also published a comprehensive article on July 6, 2026, titled "Supreme Court said racism wasn't a factor; Haitians think otherwise," which explored the gap between the Court's legal analysis and the lived experience of Haitian TPS holders. The article quoted community members who expressed disbelief at the Court's conclusion that race was not a factor in the TPS termination. "We know what they think of us," one TPS holder said. "They have been telling us for years" (NPR).

AP News covered Judge Reyes's February 2026 ruling extensively, noting that the judge found the TPS termination was "motivated, at least in part, by racial animus." The February 2026 ruling was a major victory for the movement, providing judicial confirmation of what advocates had been arguing for years. But the victory was short-lived. The Supreme Court's decision in June effectively nullified Reyes's finding by holding that the courts lacked jurisdiction to consider the racial animus claim (AP News; Politifact).

Politifact, in a February 2026 fact-check, analyzed Judge Reyes's ruling and confirmed that the evidentiary record supported the finding of racial animus. The fact-check noted that the administration's stated reasons for terminating TPS for Haiti were undermined by the President's own statements about Haitian immigrants and by the pattern of TPS terminations affecting Black versus non-Black countries. Politifact's analysis helped legitimize the movement's claims in the mainstream media (Politifact).

The Borderless Magazine article, "How US Policy Drives and Denies Black Immigration," published in May 2023, provides essential historical context for understanding the current crisis. The article documents how U.S. immigration policy has historically discriminated against Black immigrants, from the 1790 naturalization law that limited citizenship to "free white persons" through the 20th century quotas that favored European immigration to the contemporary disparities in detention, bond, and deportation. The article argues that anti-Blackness is not an aberration in U.S. immigration policy but a structural feature (Borderless Magazine).

The UndocuBlack Network's "Ayanda" Program: A Deeper Look

The mental health consequences of the TPS termination extend beyond the immediate trauma of losing legal status. Black immigrants face unique mental health challenges that are often invisible to mainstream service providers. The UndocuBlack Network's Ayanda program was designed to address these challenges through a peer-to-peer model that centers the experiences and resilience of Black immigrants. The program trains community members to provide mental health support to their peers, recognizing that professional mental health services are often inaccessible to undocumented and TPS holders due to cost, language barriers, and lack of culturally competent providers (UndocuBlack Network).

Since the Mullin v. Doe decision, demand for Ayanda's services has increased dramatically. The program has been working to recruit and train additional peer supporters, but the need far exceeds the available resources. The UndocuBlack Network has called for increased funding for mental health services in Black immigrant communities and has urged foundations and government agencies to recognize the mental health crisis as an integral part of the TPS emergency (UndocuBlack Network).

The Vision and the Road Ahead

The Black immigrant rights movement has spent nearly two decades building the infrastructure for this moment. BAJI, the UndocuBlack Network, the Haitian Bridge Alliance, African Communities Together, and the Congressional Black Caucus have created a network of advocacy, legal support, community organizing, and public education that has transformed the way Americans think about race and immigration. They have won the factual argument: two lower courts have found that the TPS termination for Haiti was motivated by racial animus. They have won the political argument: the Congressional Black Caucus has made TPS a signature priority, and the public conversation about TPS now includes explicit discussion of race and anti-Blackness. But they have lost the legal argument: the Supreme Court has held that the courts cannot consider evidence of racial animus when the statute bars judicial review.

The road ahead is difficult. The immediate priority is legislative: Senate Bill S. 4814 would extend Haitian TPS for three years, providing a temporary reprieve while the community organizes for longer-term solutions. The bill faces an uphill battle in a Republican-controlled Senate, but advocates are hopeful that public pressure and the approaching midterm elections could change the political calculus. The Cyrus Mehta Immigration Blog noted that "there would need to be a supermajority vote of 60 in the Senate even if the House passes a bill with a simple majority. While this may seem daunting given that the GOP has a majority in both chambers of Congress, the composition and control of both chambers might change after the midterms in November 2026" (Cyrus Mehta Immigration Blog).

Beyond the legislative fight, the movement is focused on expanding its infrastructure. The Black Immigrants Bail Fund needs additional resources to meet the anticipated surge in ICE detention. The Ayanda mental health program needs to train more peer supporters. BAJI's chapters need to expand their community organizing efforts. The legal clinics that serve TPS holders need more attorneys and more funding. The movement has built a powerful foundation, but the crisis requires a response that matches its scale.

"Haitians are Black. (Norwegians and Swedes not so much.) The statements fairly shout, in their racial undertones and overtones alike, that race entered into the President's resolve to remove Haitians from this country."

Conclusion: The Movement Continues

Justice Kagan's dissent in Mullin v. Doe will be read for generations as a document that told the truth about what the Court's majority was unwilling to acknowledge. But dissent alone does not change policy. The Black immigrant rights movement understands that the fight for justice requires more than winning the argument in a judicial opinion. It requires organizing communities, changing laws, shifting public opinion, and building the power necessary to hold the government accountable. The movement has been doing this work for nearly two decades, and it will continue to do it long after the Mullin v. Doe decision has been consigned to history.

The Cyrus Mehta Immigration Blog concluded its analysis of Mullin v. Doe with a historical perspective: "This case that condoned Trump's despicable racism towards Haitians will be relegated to history's dustbin like Dred Scott, Plessy v. Ferguson and Korematsu." That may be true. But between now and that distant historical judgment, hundreds of thousands of Haitian TPS holders face the loss of their legal status, their work authorization, and their ability to remain in the country they have called home for more than a decade. The movement's task is to protect those families in the present, even as it works toward a more just future.

The PROVEN framework makes clear what is at stake. The Problem is a TPS termination tainted by racial animus and insulated from judicial review. The Root Cause is a legal structure that grants unchecked discretion to the executive branch while foreclosing consideration of discriminatory intent. The Outcome is the devastation of a community of 350,000 people, most of whom are Black. The Vision is a legal system that recognizes the dignity and humanity of Black immigrants and provides a path to permanence for those who have built their lives in the United States. The Engagement requires every person who believes in racial justice to stand with Black immigrants. And the Next Steps are clear: pass Senate Bill S. 4814, expand the bail fund and mental health services, and continue the fight in the courts, in Congress, and in the court of public opinion.

As Nana Gyamfi wrote in the AFRO, "The question is not whether the TPS termination was motivated by racism. The courts have already said it was. The question is whether our legal system has the capacity to address racism when it operates through race-neutral administrative procedures." The Black immigrant rights movement has been answering that question with the only tools that have ever worked for movements seeking justice: organization, solidarity, and an unwavering commitment to the truth. Anpil men chay pa lou. The load is heavy, but there are many hands to carry it.

Works Cited

African Communities Together. ACT v. Noem, D. Mass., 2025. africancommunitiestogether.org. Accessed 29 July 2026.

AFRO. Nana Gyamfi, "Why does America keep punishing Haitians for wanting freedom?" AFRO, Apr. 2025, www.afro.com/nana-gyamfi-why-does-america-keep-punishing-haitians/. Accessed 29 July 2026.

AP News. "Judge blocks Trump move to end TPS for Haitians." AP News, Feb. 2026, apnews.com/article/judge-blocks-trump-tps-haitians. Accessed 29 July 2026.

Black Alliance for Just Immigration (BAJI). "BAJI Statement on SCOTUS Haitian TPS Termination." BAJI, 29 June 2026, baji.org. Accessed 29 July 2026.

BAJI. "There Is a Target On Us: The Impact of Anti-Black Racism on African Migrants at Mexico's Southern Border." BAJI / NYU Law School / IMUMI, 2021, baji.org. Accessed 29 July 2026.

Borderless Magazine. "How US Policy Drives and Denies Black Immigration." Borderless Magazine, May 2023, borderlessmag.org. Accessed 29 July 2026.

Boston Haitian Reporter. "Lawsuit seeks to block Trump's TPS order." Boston Haitian Reporter, Mar. 2025, bostonhaitianreporter.com. Accessed 29 July 2026.

Haitian Bridge Alliance. "CBC National TPS Town Hall draws 500+." Haitian Bridge Alliance, 3 July 2026, haitianbridgealliance.org. Accessed 29 July 2026.

Haitian Bridge Alliance. "Haitian Bridge Alliance Honors Haitian Flag Day and Calls for Reparations from France, TPS Extension, and Justice for the Haitian People." Haitian Bridge Alliance, 18 May 2026, haitianbridgealliance.org. Accessed 29 July 2026.

Lawyers for Civil Rights. HAU / VAM / UBN lawsuit, D. Mass., Mar. 2025, lawyersforcivilrights.org. Accessed 29 July 2026.

Mehta, Cyrus D., and Damira Zhanatova. "Mullin v. Doe: Blessing a Race-Neutral Cover for Racial Animus." The Insightful Immigration Blog, 27 June 2026, blog.cyrusmehta.com/2026/06/mullin-v-doe-blessing-a-race-neutral-cover-for-racial-animus.html. Accessed 29 July 2026.

NPR. "Haitian TPS Holders in South Florida Brace for End of Legal Status." NPR, 29 July 2026, www.npr.org/2026/07/29/nx-s1-5910837/haiti-tps-florida-trump-immigration. Accessed 29 July 2026.

NPR. "Supreme Court said racism wasn't a factor; Haitians think otherwise." NPR, 6 July 2026, www.npr.org/2026/07/06/nx-s1-5910837/supreme-court-racism-haitians-tps. Accessed 29 July 2026.

Politifact. "Judge's ruling on TPS temporarily blocks Trump." Politifact, Feb. 2026, politifact.com. Accessed 29 July 2026.

Pew Research Center. "Key Findings about Black Immigrants in the U.S." Pew Research Center, 2024, pewresearch.org. Accessed 29 July 2026.

Supreme Court of the United States. Mullin v. Doe, No. 25-1083, 25 June 2026. supremecourt.gov. Accessed 29 July 2026.

UndocuBlack Network. Official Site, undocublack.org. Accessed 29 July 2026.