TPS Reverification in Flux: Navigating Changing Dates and Compliance Obligations

Kimberley Best Robidoux
John Mazzeo
Amy Peck
Kimberley Best Robidoux | WR Immigration
John Mazzeo | Seyfarth Shae LLP
Amy Peck | Jackson Lewis

Live Video-Broadcast: September 11, 2026

2 hour CLE

Tuition: $195.00
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Program Summary

 

The same reverification sweep can create unauthorized-employment liability on one side and a discrimination claim on the other

The Supreme Court’s June 2026 decision in Mullin v. Doe removed longstanding judicial barriers to TPS terminations. Termination dates now shift with litigation, court orders, and agency updates — while ICE’s March 2026 reclassification treats more Form I-9 errors as substantive violations.

The exposure cuts both ways. Miss a reverification deadline and you face unauthorized employment liability. Over-document or single out workers by national origin and you trigger discrimination exposure under 8 U.S.C. § 1324b. Treat an E-Verify Status Change Report casually and it becomes a constructive knowledge event. Rely on a placeholder date and your timeline is calibrated to the wrong legal trigger.

Attendees walk away with concrete deliverables: a calendar-driven reverification workflow, a country-by-country monitoring protocol, and a practical framework for termination-timing decisions that hold up under both ICE scrutiny and anti-discrimination review.

Key topics to be discussed:

  • The Post-Mullin Landscape
    What the Supreme Court’s June 2026 decision in Mullin v. Doe changed for employers with TPS workers — and why compressed reverification timelines demand action now.
  • Category Codes Decoded
    How to identify A12 and C19 EAD card holders and apply country-specific automatic extension rules — and how those rules differ from the general 540-day EAD extension.
  • Supplement B Mechanics
    How to complete Form I-9 and Supplement B reverification without creating new violations under ICE’s March 2026 reclassification of substantive versus technical violations.
  • Placeholder-Date Triggers
    How to tell a final TPS termination date from a placeholder across country tiers — and which legal trigger starts each country’s reverification clock.
  • Constructive Knowledge Events
    When an E-Verify Status Change Report creates constructive knowledge of unauthorized employment — and what a monitoring protocol must do next.
  • Anti-Discrimination Guardrails
    Where over-documentation and inconsistent sweeps create IER exposure under 8 U.S.C. § 1324b — and the records that prove reverification was date-driven, not worker-targeted.

This course is co-sponsored with myLawCLE.

Date / Time: September 11, 2026

  • 12:00 pm – 2:10 pm Eastern
  • 11:00 pm – 1:10 pm Central
  • 10:00 am – 12:10 pm Mountain
  • 9:00 am – 11:10 am Pacific

Closed-captioning available

Speakers

Kimberley Best Robidoux, Partner | WR Immigration

Kimberley Best Robidoux is a partner in the San Diego office of WR Immigration, where she counsels corporate clients on employment-based immigration and related nonimmigrant visa matters as well as worksite enforcement and compliance, including Form I-9 Employment Eligibility Verification. With more than 25 years of immigration law experience, she approaches immigration through a holistic business lens, crafting solutions that account for the broader issues that impact HR.

  • Education & Credentials

Ms. Robidoux earned her law degree from Albany Law School (1993–1996) and her B.S. in Industrial and Labor Relations, with honors, from Cornell University’s School of Industrial and Labor Relations (1991). She is a member of the Bar of the Supreme Court of California, the Bar of the Court of Appeals of Maryland, and the Bar of the Court of Appeals of Washington, D.C.

  • Recognition & Leadership

Ms. Robidoux serves as Chair of the Verification and Documentation Committee of the American Immigration Lawyers Association (AILA), an organization of 18,000 members. Her recognitions include The Best Lawyers in America (named Best Immigration Lawyer in San Diego in 2020 and listed in the 2023 edition), Southern California Super Lawyers, Who’s Who Legal: Corporate Immigration, the International Who’s Who of Corporate Immigration Lawyers, the San Diego Business Journal’s Best of the Bar, and a nomination for an Athena San Diego Pinnacle Award for Individual in Services.

  • Professional Involvement

A longtime AILA member, Ms. Robidoux is a frequent speaker on business immigration issues to human resource personnel and management, and at seminars throughout the United States on business immigration and related topics. Her practice emphasizes proactive education — designing internal Form I-9 and E-Verify processes, conducting self-audits, and training teams to eliminate compliance exposure.

  • Experience

Before joining WR Immigration as a partner in March 2022, Ms. Robidoux was a senior attorney and shareholder at Maggio Kattar (2014–2022), where she established the firm’s first West Coast office in San Diego; a senior associate attorney at Larrabee Albi Coker LLP (2004–2014), focusing on corporate immigration for the high-tech, pharmaceutical/biotech, and hospitality industries; and a senior associate attorney at Mintz Levin in Boston (1999–2004). She began her career in Washington, D.C. as a paralegal in immigration, labor, and employment law and as a research analyst at a non-profit, and she has successfully defended employers against I-9 compliance audits, conducted in-house audits, and performed I-9 management training.

 

John Mazzeo, Counsel | Seyfarth Shae LLP

John W. Mazzeo is counsel in the immigration practice of Seyfarth Shaw LLP, focusing on immigration compliance and worksite enforcement. He helps employers of all sizes address enterprise immigration compliance and employment eligibility verification obligations — matters of business continuity, growth, and risk mitigation — while balancing compliance goals with business and operational realities.

  • Education & Credentials

Mr. Mazzeo earned his J.D. from the Drexel University Thomas R. Kline School of Law and his B.A. from Ursinus College. He is licensed in Pennsylvania; he is not admitted to practice in the District of Columbia, and his practice is limited to immigration and nationality law.

  • Recognition & Leadership

Mr. Mazzeo serves as Vice Chair of the American Immigration Lawyers Association’s Verification and Documentation Liaison Committee (2024–present), served as Vice Chair of the Association of Corporate Counsel (International) (2024–2025) and now serves as its Chair (2025–2026), and served on Law360’s Immigration Editorial Board (2023–2025).

  • Professional Involvement

A member of the American Immigration Lawyers Association since 2021, Mr. Mazzeo co-authors legal updates and articles and speaks at AILA, SHRM, and ABA conferences on Form I-9, E-Verify, and worksite enforcement compliance.

  • Experience

Mr. Mazzeo combines years of experience as an ICE trial attorney focusing on worksite enforcement with years counseling one of the nation’s largest providers of onboarding services and solutions — experience that gives him insight into both the legal and operational issues inherent in employment eligibility verification and immigration compliance.

 

Amy Peck, Principal | Jackson Lewis

Amy L. Peck is a principal in the Omaha office of Jackson Lewis P.C. and co-leader of the firm’s Immigration group, with a presence in the firm’s Sioux Falls office as well. She partners with employers to manage immigration compliance, translating complex regulatory requirements into practical, risk-reducing solutions, and stays ahead of employer needs with creative and efficient answers to immigration compliance and workforce issues.

  • Education & Credentials

Ms. Peck earned her J.D. from the University of Nebraska College of Law in 1987 and her B.A. from the University of Nebraska–Lincoln in 1984, where she was inducted into Phi Beta Kappa. She is admitted in Nebraska and Iowa, before the U.S. District Court for the District of Nebraska, and before the Eighth Circuit Court of Appeals.

  • Recognition & Leadership

Her recognitions include Chambers USA for Immigration (2016–present); The Best Lawyers in America for Immigration Law (2010–present), including Lawyer of the Year for Immigration Law (2023); Super Lawyers (2012–present); and the AILA President’s Award (2025). Within the American Immigration Lawyers Association, she chairs the AILA Verification Committee, served twelve years as an elected Director on the Board of Governors, and has chaired multiple committees, including the EOIR, FOIA, and ICE liaison committees.

  • Professional Involvement

Ms. Peck serves on the Board of Trustees of the American Immigration Council, is a frequent national speaker, and is a trusted voice on employment and immigration enforcement issues whose insights are sought by national media.

  • Experience

An attorney with Jackson Lewis since June 2010, Ms. Peck also manages Peck Law Firm. Her practice centers on proactive Form I-9 compliance — employment eligibility verification training, internal audits and risk assessments, and electronic system review — and, when necessary, responding to agency worksite enforcement actions. Emphasizing proactivity, she is a go-to for ICE raid defense and ICE visit preparedness, and counsels employers on Social Security No-Match Letter guidance, policy drafting, and the use of E-Verify.

Agenda

SESSION 1 – TPS Reverification Rundown: Category Codes and Form I-9 Compliance | 12:00pm – 1:00pm

This session walks employment counsel and HR attorneys through the mechanics of a compliant TPS reverification sweep in the wake of the Supreme Court’s June 2026 decision in Mullin v. Doe. That ruling removed judicial barriers to TPS terminations and compressed employer timelines for I-9 compliance. Attorneys will learn how to identify A12 and C19 EAD card holders, apply country-specific automatic extension rules, and execute Form I-9 correctly while understanding ICE’s March 2026 enforcement reclassification of I-9 violations. Attendees will leave with a defensible, calendar-driven workflow for reverifying TPS employees without triggering discrimination liability or substantive I-9 violations.

BREAK | 1:00pm – 1:10pm

SESSION 2 – Managing Moving Dates: Monitoring, Termination Timing, and I-9 Compliance Risks | 1:10pm – 2:10pm

This session addresses the live compliance challenge employers face when TPS termination dates shift repeatedly due to litigation, court orders, and USCIS placeholder updates. Attorneys will learn how to build a country-by-country monitoring protocol, apply the correct work authorization reverification trigger, and manage the E-Verify Status Change Report as a constructive knowledge event. Attendees will leave with practical frameworks for avoiding both unauthorized employment liability and anti-discrimination exposure under 8 U.S.C. § 1324b.

Credits

Alaska

Approved for CLE Credits
2 General

Our programs are CLE-eligible through Alaska’s recognition of multi-jurisdictional reciprocity.
Alabama

Approved for Self-Study Credits
2 General

Arkansas

Approved for CLE Credits
2 General

Arizona

Approved for CLE Credits
2 General

California

Approved for CLE Credits
2 General

Colorado

Pending CLE Approval
2 General

Connecticut

Approved for CLE Credits
2 General

District of Columbia

No MCLE Required
2 CLE Hour(s)

Delaware

Pending CLE Approval
2 General

Florida

Approved via Attorney Submission
2 General Hours

Receive CLE credit in Florida via attorney submission.
Georgia

Approved for CLE Credits
2 General

Hawaii

Approved for CLE Credits
2 General

Iowa

Pending CLE Approval
2 General

Idaho

Pending CLE Approval
2 General

Illinois

Pending CLE Approval
2 General

Indiana

Pending CLE Approval
2 General

Kansas

Pending CLE Approval
2 Substantive

Kentucky

Pending CLE Approval
2 General

Louisiana

Pending CLE Approval
2 General

Massachusetts

No MCLE Required
2 CLE Hour(s)

Maryland

No MCLE Required
2 CLE Hour(s)

Maine

Pending CLE Approval
2 General

Michigan

No MCLE Required
2 CLE Hour(s)

Minnesota

Pending CLE Approval
2 General

Missouri

Approved for Self-Study Credits
2.4 General

Mississippi

Pending CLE Approval
2 General

Montana

Pending CLE Approval
2 General

North Carolina

Pending CLE Approval
2 General

North Dakota

Approved for CLE Credits
2 General

Our programs are CLE-eligible through North Dakota’s recognition of multi-jurisdictional reciprocity. Section 1, Policy 1.14
Nebraska

Pending CLE Approval
2 General

myLawCLE reports attendance to Nebraska on each attorney’s behalf for all programs. Please do not self-report.
New Hampshire

Approved for CLE Credits
120 General minutes

As of July 1, 2014, the NHMCLE Board no longer provides pre- or post-approval of courses. Attendees must self-determine whether a program is eligible for credit, and self-report their attendance online at www.nhbar.org, based on qualification provisions of Rule 53.
New Jersey

Approved for CLE Credits
2 General

Our programs are CLE-eligible through New Jersey’s recognition of multi-jurisdictional reciprocity, except for the courses required under BCLE Reg. 201:2
New Mexico

Approved for Self-Study Credits
2 General

Nevada

Pending CLE Approval
2 General

New York

Approved for CLE Credits
2 General

Our programs are CLE-eligible through New York’s Approved Jurisdiction Group “B”.
Ohio

Approved for Self-Study Credits
2 General

Oklahoma

Pending CLE Approval
2.5 General

Oregon

Pending CLE Approval
2 General

Pennsylvania

Approved for Self-Study Credits
2 General

Rhode Island

Pending CLE Approval
2.5 General

South Carolina

Pending CLE Approval
2 General

South Dakota

No MCLE Required
2 CLE Hour(s)

Tennessee

Approved for Self-Study Credits
2 General

Texas

Approved for CLE Credits
2 General

Utah

Pending CLE Approval
2 General

Virginia

Not Eligible
2 General Hours

Vermont

Approved for CLE Credits
2 General

Washington

Approved via Attorney Submission
2 Law & Legal Hours

Receive CLE credit in Washington via attorney submission.
Wisconsin

Approved for Self-Study Credits
2 General

West Virginia

Pending CLE Approval
2.4 General

Wyoming

Pending CLE Approval
2 General

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