The director of U.S. Citizenship and Immigration Services violated the law by disregarding dangerous conditions in Haiti when recommending the termination of temporary protected status for refugees who fled the country following a devastating 2010 earthquake, the director's predecessor told a federal judge at a Brooklyn trial testing the Trump administration's decision.

Leon Rodriguez, a partner at Seyfarth Shaw who served as USCIS director from 2014 to 2017, told U.S. District Judge William Kuntz II of the Eastern District of New York that the law governing temporary protected status (TPS) requires that officials consider persistent ills that continue to affect Haiti, such as ongoing threats to public safety and food shortages, when assessing whether or not Haitian refugees should continue to receive protected status.

But in his recommendation to then-Acting Homeland Security Secretary Elaine Duke to terminate TPS, Rodriguez's successor as USCIS director, L. Francis Cissna, said Haiti had largely bounced back from the 2010 earthquake—which killed more than 200,000 people, according to some estimates—and that ongoing problems in Haiti like food insecurity and gender-based violence are unrelated to the earthquake.