A Biden-appointed federal judge has become the second jurist in Massachusetts to block the Trump administration's effort to end Temporary Protected Status for Ethiopian nationals, fueling a clash over whether lower courts are ignoring a recent Supreme Court ruling that narrowed their authority over such decisions.
U.S. District Judge Brian Murphy of the District of Massachusetts issued an administrative stay in African Communities Together v. Mullin, temporarily preserving TPS protections for Ethiopian nationals while the court considers whether plaintiffs may pursue constitutional claims following the Supreme Court's June ruling in Mullin v. Doe. In a 6-3 decision, the Supreme Court significantly narrowed lower courts' authority to block Department of Homeland Security decisions designating or terminating TPS.
The litigation began after then-DHS Secretary Kristi Noem determined in December 2025 that conditions in Ethiopia no longer justified Temporary Protected Status and announced the designation would terminate after a 60-day wind-down period. Under the department's notice, Ethiopia's TPS protections were set to expire on Feb. 13, 2026, before Judge Murphy intervened.
What the Right Is Saying
DHS General Counsel James Percival accused Judge Murphy of "mutiny" against the Supreme Court following his ruling. Percival pointed to a previous May 2025 order by Murphy halting a deportation flight to South Sudan, which DHS officials say left ICE officers stranded at a U.S. military base in Djibouti facing malaria exposure and rocket attack threats from terrorist groups in Yemen.
Conservative legal activists argue lower courts are overstepping their authority. Mike Davis, founder of the Article III Project, wrote on X that "these Democrat operatives in robes do not have the power to do this" and called for the administration to ignore what he described as "lawless orders."
Conservative commentator Ann Coulter echoed those calls, writing that district judges had been overruled by the Supreme Court repeatedly on immigration matters. "I think it's time for the president to take his constitutional oath seriously, and ignore them," she wrote.
The Trump administration argues it has the authority to terminate TPS designations when conditions in foreign countries no longer warrant such protections. The Justice Department contends that Judge Murphy's injunction was undermined by the Supreme Court's ruling limiting APA challenges to TPS decisions.
What the Left Is Saying
Democratic lawmakers and immigrant rights advocates argue that judges are appropriately exercising judicial review to protect vulnerable populations. Senator Dick Durbin, D-Ill., who serves as ranking member of the Senate Judiciary Committee, has previously stated that TPS holders have built lives in the United States and deserve due process protections.
African Communities Together, the advocacy group leading the legal challenge alongside individual TPS holders, argues that constitutional claims remain viable even after the Supreme Court's ruling. The plaintiffs revised their complaint to focus on constitutional arguments after the high court's decision limited APA-based challenges.
Progressive groups have praised Murphy's rulings as necessary checks on executive power. The National Immigration Law Center called the judge's approach "consistent with constitutional principles" and said TPS holders who have established roots in the United States deserve continued protection while courts assess the merits of their claims.
What the Numbers Show
The Supreme Court's June 2026 decision in Mullin v. Doe was a 6-3 ruling, with conservative justices in the majority and liberal justices dissenting.
Ethiopia's TPS designation affects approximately 15,700 Ethiopian nationals currently in the United States under protected status, according to DHS data from 2025.
Judge Murphy has faced Supreme Court reversals twice before on immigration-related orders restricting deportations of migrants to countries that are not their homelands. The high court sided with the administration in both instances.
Senior U.S. District Judge Patti Saris, also in the District of Massachusetts, issued a similar administrative stay halting termination of TPS for South Sudan within hours of Murphy's ruling. The parallel case involves 900 South Sudanese nationals under TPS protection.
The Bottom Line
The twin rulings from Massachusetts federal judges represent an escalating legal confrontation over immigration enforcement authority following the Supreme Court's narrowing of judicial review power over TPS decisions. Both cases now hinge on whether plaintiffs can successfully argue constitutional claims survive the high court's APA restrictions.
The Trump administration faces pressure from conservative allies to defy lower court orders, a strategy that would almost certainly trigger additional Supreme Court intervention. Legal experts say ignoring judicial orders would create a constitutional crisis with far-reaching implications for separation of powers.
What happens next: Courts in Massachusetts are expected to rule on whether constitutional claims can proceed after the Mullin v. Doe decision. The administration must decide whether to appeal Murphy's stay directly to the First Circuit or seek Supreme Court review again.