On March 25, 2025, the U.S. Department of Homeland Security (DHS) announced via the Federal Register that it would terminate the humanitarian parole programs for nationals of Cuba, Haiti, Nicaragua, and Venezuela (CHNV) and their immediate family members, effective April 24, 2025. These programs, modeled after the United for Ukraine (U4U) initiative, allowed eligible individuals to enter the U.S. under humanitarian parole and receive two-year employment authorization.
This announcement sparked widespread concern among over 500,000 parolees who had already entered the U.S. under CHNV, leaving employers, families, and immigration advocates scrambling for clarity. However, a major legal development on April 14, 2025, has thrown a temporary lifeline to many.
Judge Halts DHS Mass Revocation Effort
In a significant turn of events, U.S. District Judge Indira Talwani issued two important orders:
- Class Certification: She certified a class of individuals who had already received CHNV parole but were at risk of mass revocation. The class excludes those who:
- Voluntarily left the U.S. before the March 25 notice,
- Or choose to opt out and pursue individual legal relief.
- Emergency Stay: The court blocked DHS’s en masse termination of CHNV parole grants and their associated work authorizations. The judge determined that DHS had failed to provide the required case-by-case review before revoking parole, violating the Immigration and Nationality Act (INA) and the Administrative Procedure Act (APA).
Judge Talwani emphasized that while DHS has broad discretion to grant parole, once a consistent policy is established, any sudden, unexplained departure from that policy can be deemed arbitrary and capricious.
What This Means for CHNV Parolees and Employers
For parolees:
- If you received notice via your myUSCIS account about parole or work authorization termination, that notice is stayed — you currently remain in valid status under the CHNV program.
- If you submitted evidence to USCIS to contest a revocation notice, that review should still proceed under normal guidelines.
- You are advised to upload any updates regarding your immigration status to your USCIS account.
For employers:
- DHS had warned that the March 25 notice constituted “constructive knowledge” of employee ineligibility, which could trigger I-9 compliance issues. However, due to the court’s stay, (c)(11) Employment Authorization Documents (EADs) remain valid until further notice.
- Employers should consult legal counsel before taking any adverse action based on perceived expiration or revocation of work authorization.
- Identifying CHNV parolees is not straightforward. Not all (c)(11) EADs stem from CHNV; employers should avoid discriminatory document requests.
- CBP used specific I-94 codes such as CHP, HHP, NHP, and VHP to classify CHNV entrants. Review of these codes may assist with clarification.
What’s Next?
The stay is temporary, and Judge Talwani made clear that she is not likely to block the administration from ending the CHNV programs in the future — but the process must follow the law. DHS will likely need to issue individualized revocation decisions rather than rely on sweeping, categorical actions.
DHS has also reiterated its intent to remove parolees who:
- Have not filed for another lawful immigration benefit by March 25, 2025,
- Do not have a pending case filed by a sponsor (such as a family-based petition),
- Or fail to depart the U.S. voluntarily.
Parolees were advised to use the CBP One mobile app to report voluntary departure, especially at land borders.
The end is not near for CHNV parolees or their employers, but for now, they can breathe a little easier. The court’s intervention shows that policy must follow process, even in urgent immigration matters. Attorney Estrada and his staff at the Immigration Law Center at BCC can assist parolees and employers in determining pathways forward.
Stay tuned for further updates as this case continues to evolve. Article current as of April 26, 2025.