Judge blocks Trump's early termination of temporary protections for Haitian immigrants
Cogan, an appointee of President George W. Bush, held that Noem's termination was unlawful because the government ignored provisions in the TPS statute that seek to provide early notice to recipients, including barring termination until a previous extension expires.
The judge noted that Haitian TPS recipients have enrolled in schools, taken jobs and began medical treatment in reliance on the U.S. government's previous representations about the duration of the protections.
'When the Government confers a benefit over a fixed period of time, a beneficiary can reasonably expect to receive that benefit at least until the end of that fixed period,' Cogan wrote.
'Secretary Noem cannot reconsider Haiti's TPS designation in a way that takes effect before February 3, 2026,' the judge added.
TPS designations are based on conditions in a particular country, including whether there is armed conflict, civil strife or widespread human rights violations. Noem said the 'environmental situation in Haiti has improved enough that it is safe for Haitian citizens to return home.' The State Department, meanwhile, advises Americans to 'not travel to Haiti due to kidnapping, crime, civil unrest, and limited health care.'
The Trump administration has sought to revoke immigration parole programs and protected status for more than a million people from countries including Haiti, Cuba, Nicaragua, Venezuela, Cameroon and Afghanistan.
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In mid-August 2025, a rumor spread on social media that Department of Homeland Security (DHS) Secretary Kristi Noem was having an affair with Corey Lewandowski, a former campaign manager for U.S. President Donald Trump. Speculation about a romantic relationship between the pair had circulated online since at least September 2021, when the conservative website American Greatness reported allegations that Noem and Lewandowski were involved in an extramarital affair. The allegation resurfaced two years later when U.K. tabloid newspaper Daily Mail published an article about the alleged affair. Both have publicly denied the claim on multiple occasions and reports of an alleged romantic relationship have primarily relied on anonymous sources. Snopes was unable to independently verify allegations that Noem and Lewandowski had an affair. In mid-August 2025, a rumor spread online that Department of Homeland Security (DHS) Secretary Kristi Noem was having an affair with Corey Lewandowski, a former campaign manager for U.S. President Donald Trump. Social media posts making the claim included an image of Noem, who previously served as South Dakota's governor, standing next to Lewandowski. The posts also featured the logo of left-leaning media outlet MeidasTouch. Multiple Snopes readers contacted us with questions about their alleged romantic relationship, with one asking: "Did Kristi Noem have an affair with Lewandowski?" However, the rumor has circulated online since at least September 2021, when the conservative website American Greatness reported (archived) that the two were allegedly involved in an extramarital affair, citing multiple anonymous sources. The allegation resurfaced two years later when British tabloid newspaper Daily Mail published an article (archived) claiming the pair had engaged in a yearslong "clandestine affair." On the same day, MeidasTouch also published an article (archived) and Facebook post about the alleged romantic relationship, citing the Daily Mail's reporting. In September 2022, Lewandowski accepted a plea deal to resolve allegations that he made unwanted sexual advances toward a Republican Party donor at a Las Vegas event, as The Associated Press reported. The AP added that he did "not admit to any wrongdoing." More recently, he has faced scrutiny in his role as a special government employee with DHS. Axios reported on Aug. 14, 2025, that Lewandowski acts as Noem's "de facto chief of staff." Snopes was unable to independently verify whether Noem and Lewandowski were having or were ever engaged in an affair. Reports making the claim have primarily relied on anonymous sources — therefore, we were unable to scrutinize their allegations — and both of them have publicly denied the rumor on multiple occasions. The White House and DHS did not respond to a request for comment by the time of publication. Below is a breakdown of the reports about an alleged affair between Noem and Lewandowski. Noem dismissed affair rumor after American Greatness report On Sept. 28, 2021, American Greatness published a report (archived) citing anonymous sources who alleged Noem and Lewandowski had been involved in a monthslong relationship. One source reportedly told the conservative website that some members of Congress referred to the affair as "an open secret." American Greatness did not provide further details about the alleged affair in its article. The following day, Noem, who was serving as South Dakota's governor at the time, dismissed the rumor on Twitter (now X) by calling it "total garbage and a disgusting lie." Multiple news media outlets reported her response. (Twitter, now X) "These old, tired attacks on conservative women are based on a falsehood that we can't achieve anything without a man's help," Noem tweeted. "I love [my husband] Bryon. I'm proud of the God-fearing family we've raised together. Now I'm getting back to work." Daily Mail reports reignited speculation about alleged affair In September 2023, the Daily Mail published an article (archived) claiming the pair had been engaged in a "years-long clandestine affair" that began "in 2019, if not before." According to the newspaper, neither Noem nor Lewandowski denied the affair when initially contacted. The outlet reported that Noem released a statement criticizing the article's timing while Lewandowski did not respond to a request for comment. However, a spokesperson for Noem reportedly pushed back after the article was published, insisting the two never had an affair, the Daily Mail reported. The British tabloid claimed that its investigation "uncovered extensive evidence" of a romantic relationship, including "dozens of trips that mixed business with pleasure, flights on donors' private planes, and stays at luxury resorts where their intimacy was observed and noted." According to the Daily Mail, former Trump operative Charles Johnson described one such incident, writing in a Substack post that he had seen the pair behaving "in a very flirtatious manner" during an August 2020 meeting of the Republican Attorneys General Association (RAGA) at The Cloister resort on Sea Island, Georgia. Although it was not possible to find the exact post in which Johnson reportedly said this, he did post a Substack article in which he claimed Noem and Lewandowski "seemed to be dating" at the Sea Island event "despite being married to other people" (archived). Johnson reportedly told the Daily Mail that he saw Noem "discreetly take Lewandowski's hand and put it in her lap" as he "put his arm on her back." The newspaper alleged that the pair became "virtually inseparable companions on the Trump [2020] campaign trail" and that their relationship was an "open secret" at the White House and among GOP lobbyists and political consultants at the time. In another example, the tabloid said Noem and Lewandowski attended the Republican Governors Association event at the St. Regis in Aspen, Colorado, in summer 2021. Sources reportedly told the paper that Noem missed several events she was expected to attend, with one person alleging she was "holed up" with Lewandowski at a nearby hotel. However, it was not possible to independently verify the details in the Daily Mail article. After the report was published, a spokesperson for Noem denied the allegation, calling it "false." In a statement provided to Sioux Falls Live, a news media outlet based in South Dakota, Noem's spokesperson also criticized the Daily Mail for allegedly failing to publish Noem's denial of the affair and accused the outlet of relying on a reporter with a history of "questionable journalistic integrity." The statement read, in part: It is shameful that Sioux Falls Live would report based on a false and inflammatory tabloid rumor. It was also false that Governor Noem did not deny the allegation to the Daily Mail. They failed to print the denial and failed to appropriately correct the story when that failure was pointed out to them. As Governor Noem said during her endorsement speech for President Trump: 'Yes, I will be attacked for speaking the truth to all of you tonight. Yes, I expect Joe Biden, these candidates, their political operatives, and the media will perpetuate ugly, hateful misinformation in an attempt to destroy me and my family because of my opinions. It's nothing new. I'm getting used to it honestly.' Unfortunately, the Daily Mail piece was par for the course for this individual's history as a reporter with questionable journalistic integrity. In April 2025, the Daily Mail published another report (archived) claiming Noem and Lewandowski were living in rental apartments located across the street from each other in the Navy Yard neighborhood of Washington, D.C. A resident of Noem's building reportedly told the tabloid: "I've seen them together here both in the elevator and in common areas." The Daily Mail also published photos that it claimed showed Lewandowski leaving Noem's apartment complex with a duffel bag. In April 2025, the Wall Street Journal reported that Lewandowski denied the alleged affair. We have reached out to the White House and DHS for comment about the allegations and will update this story if we receive a response. Snopes has previously addressed numerous rumors about Noem, including one accurate claim that she said "only the liberals and the extremists" make fun of women's looks. Her statement was a response to an episode of "South Park" that satirized the DHS secretary and U.S. Immigration and Customs Enforcement (ICE). Ashford, Ben, and Shawn Cohen. "ICE Barbie Kristi Noem and Homeland Security Advisor Corey Lewandowski's Cozy DC Living Arrangement Revealed." Mail Online, Daily Mail, 30 Apr. 2025, Accessed 18 Aug. 2025. Chamlee, Virginia. "Governor Slams 'Disgusting Lie' She Was Involved with Trump Aide as Separate Woman Accuses Him of Harassment." 30 Sept. 2021, Accessed 18 Aug. 2025. Esposito, Joey. 'Kristi Noem Said "only the Liberals and the Extremists" Make Fun of Women's Looks'. Snopes, 8 Aug. 2025, Gibson, Brittany, and Marc Caputo. "Scoop: White House Suspicious of Lewandowski's 'Temp' Work." Axios, 14 Aug. 2025, Accessed 18 Aug. 2025. Gonzalez, Pedro. "Kristi Noem Shows Why Republicans Can't Have Nice Things." American Greatness, 29 Sept. 2021, Accessed 18 Aug. 2025. Governor Kristi Noem on Twitter: 'These Rumors Are Total Garbage and a Disgusting Lie. These Old, Tired Attacks on Conservative Women Are Based on a Falsehood That We Can't Achieve Anything without a Man's Help. I Love Bryon. I'm Proud of the God-Fearing Family We've Raised Together. Now I'm Getting Back to Work'. 1 Oct. 2021, Johnson, Charles. 'Did A U.S. Senate Candidate Ask Me For A Bribe?' Charles Johnson's Thoughts and Adventures, 14 Oct. 2022, 'Kristi Noem'. National Governors Association, 7 Jan. 2023, Kristi Noem Articles | Accessed 19 Aug. 2025. LaCapria, Kim. 'Donald Trump Fires Campaign Manager'. Snopes, 20 Jun. 2016, Lalley, Patrick. "Noem Spokesman: 'the Allegation of an Affair Is False.'" Sioux Falls Live, 20 Sept. 2023, Accessed 18 Aug. 2025. Parti, Tarini, et al. 'How Corey Lewandowski Became Kristi Noem's Gatekeeper at DHS'. The Wall Street Journal, 17 Apr. 2025, "Plea Deal for Ex-Trump Adviser Accused of Unwanted Advances." AP News, 30 Sept. 2022, Accessed 18 Aug. 2025. Rascouët-Paz, Anna. '8 Rumors about Kristi Noem'. Snopes, 15 Jul. 2025, Silverstein, Ken, and Laura Collins. "EXCLUSIVE: Married South Dakota Governor Kristi Noem and Trump Advisor Corey Lewandowski Have Been Having a Years-Long Clandestine Affair." Mail Online, Daily Mail, 15 Sept. 2023, Accessed 18 Aug. 2025.
