Arizona v. Mayorkas
The Facts
The Trump administration implemented the Migrant Protection Protocols in 2019, requiring asylum seekers to wait in Mexico pending U.S. immigration hearings. The Biden administration sought to end MPP; lower courts initially blocked termination. The Supreme Court took the case but the program formally ended before decision.
The Application
Once the Biden administration formally terminated the Migrant Protection Protocols before the Supreme Court's decision, the program ceased to exist, eliminating the live controversy required for Article III jurisdiction. Arizona's challenge to the termination became moot because the government action it sought to enjoin had already occurred and there was no reasonable expectation MPP would be reinstated, rendering any judicial pronouncement on the termination's lawfulness merely advisory. The Court therefore lacked jurisdiction to reach the merits of whether the administration had complied with the Immigration and Nationality Act in winding down the program, despite the lower court preliminary injunctions that had initially blocked termination.
The Conclusion
**Dismissed as moot in 2022.** The substantive question of MPP's legality was not resolved on the merits.
No circuit court data for this case.
Case Analysis
Overview
The Supreme Court dismissed Arizona v. Mayorkas as moot after the Biden administration terminated the Remain in Mexico (Migrant Protection Protocols) program. Arizona had challenged the administration's wind-down of MPP, but the Court found no live controversy remained once the program formally ended.
Facts
The Trump administration implemented the Migrant Protection Protocols in 2019, requiring asylum seekers to wait in Mexico pending U.S. immigration hearings. The Biden administration sought to end MPP; lower courts initially blocked termination. The Supreme Court took the case but the program formally ended before decision.
Issue
Whether the Biden administration lawfully terminated the Migrant Protection Protocols (Remain in Mexico policy) under the Immigration and Nationality Act.
Rule
A case becomes moot when the challenged government action has ceased and there is no reasonable expectation it will recur, depriving federal courts of jurisdiction under Article III.
Analysis
Once the Biden administration formally terminated the Migrant Protection Protocols before the Supreme Court's decision, the program ceased to exist, eliminating the live controversy required for Article III jurisdiction. Arizona's challenge to the termination became moot because the government action it sought to enjoin had already occurred and there was no reasonable expectation MPP would be reinstated, rendering any judicial pronouncement on the termination's lawfulness merely advisory. The Court therefore lacked jurisdiction to reach the merits of whether the administration had complied with the Immigration and Nationality Act in winding down the program, despite the lower court preliminary injunctions that had initially blocked termination.
Conclusion
**Dismissed as moot in 2022.** The substantive question of MPP's legality was not resolved on the merits.
Notes
OT2022. Added via SCOTUS bulk import 2026-05-14
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