Mandamus decisions / Northern District of Indiana
Bhaidas v. Secretary US Department of Homeland Security
Read the decisionOriginal on CourtListener
2,996 written decisions from 2,731 cases in the whole mandamus and agency-delay group, the group's newest decided November 12, 2026. Updated November 14, 2026 at 1:17 a.m. CT; the Passim connector counts the live collection, which can differ by the day's additions and retirements (which total to quote). Coverage: of the 1,617 public decisions since January 1, 2025 that a CourtListener and GovInfo search for mandamus and agency delay finds, Passim holds 1,406 (87%), 1,039 of them in this group, measured November 14, 2026. Some of what that search finds are not mandamus decisions. Tell us about a decision we're missing.
These are counts of past written decisions and dockets, not predictions of how any case will be decided. A distribution appears only when at least 5 decisions (or 5 dockets) are behind it; smaller groups are listed, not summarized. How it's counted.
What the decision decided
Each value cites the passage it was read from. Values read by a model were checked against that passage; values read by rule come from fixed text patterns. Read the decision before relying on either.
| Agency |
USCIS
Read by a model
The assertion that USCIS’s now-47-month delay in reviewing the I-130 constitutes an unreasonable delay isn’t frivolous, so the court has jurisdiction over this mandamus request. |
|---|---|
| Form or filing |
I-130 (relative petition); I-485 (adjustment of status)
Read by a model
Messrs. Bhaidas and Bhaidasna seek a writ of mandamus or alternatively relief under the APA for the government’s alleged inaction and for unreasonably delaying the adjudication of their I-130 and I-485 petitions. |
| What the suit asked for |
Decide the application
Read by a model
They also seek a writ of mandamus to compel the government to adjudicate their petitions. |
| Kind of order |
A ruling on a motion or the petition
Read by a model
Accordingly, the court GRANTS IN PART and DENIES IN PART the government’s motion to dismiss [14]. |
| Motion decided |
Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim
Read by a model
The government moves to dismiss for lack of subject matter jurisdiction and for failure to state a claim. See Fed. R. Civ. P. 12(b)(1), (b)(6). |
| Whose motion |
The government's motion
Read by a model
Accordingly, the court GRANTS IN PART and DENIES IN PART the government’s motion to dismiss [14]. |
| Disposition |
Dismissed in part; some claims go on
The government's motion to dismiss was granted in part: some claims were dismissed and others go on.
Read by a model
Considering all factors together, Mr. Bhaidas has plausibly alleged enough to proceed on his APA claim—the only one over which the court has jurisdiction. |
| Prevailing party |
Each side in part
Read by a model
Considering all factors together, Mr. Bhaidas has plausibly alleged enough to proceed on his APA claim—the only one over which the court has jurisdiction. |
| The delay claim |
The delay claim goes on
Read by a model
Considering all factors together, Mr. Bhaidas has plausibly alleged enough to proceed on his APA claim—the only one over which the court has jurisdiction. |
| Months pending |
39.9 months from the application to the suit; 48.4 months from the application to the court's decision
Read by a model
On October 11, 2021, Mr. Bhaidas filed a Form I-130 Petition for Alien Relative with USCIS that named Mr. Bhaidasna as a beneficiary [id. ¶ 16]. |
| TRAC factors |
The court weighed the TRAC factors
the first, second, fourth, and fifth factors weigh to some degree in his favor |
| The government's delay arguments |
First-in, first-out processing rejected; Line-jumping rejected
Read by a model
Nor does the government explain why the mere existence of a rule must mean that the agency is following that rule—two separate questions, and at least the one is not answerable at this pleading stage. |
| Threshold rulings |
Section 1252(a)(2)(B) bar applied; APA adequate-remedy bar applied (mandamus claim fails)
Read by a model
When the statute says the court cannot review this discretionary petition, that is exactly what it means—the court lacks jurisdiction. 8 U.S.C. § 1252 (a)(2)(B); |
| Nationality |
India
Read by a model
his son Jash Bhaidasna is an Indian citizen |
| I-130 category |
Immediate relative
Read by a model
allows a United States citizen to file a Form I-130 petition for classification of a child as an immediate relative for immigration purposes. |
How the case ended
- Docket
- No. 3:25-cv-00242
- On the docket
- This ruling (ECF 20), deciding the motion (ECF 14)
- Filed
- March 20, 2025
- Ended
- December 18, 2025
- Suit's filing to its end
- 273 days
- How it ended
- Ended once the agency acted
- From the record
- voluntary dismissal 2025-12-16
A voluntary or stipulated dismissal is how most suits end once the agency acts; the docket rarely says why. Other suits in this court.
The ruling's entry is the docket's one order or judgment entered the day of the decision, and the motion number is read from that entry's text. Both come from CourtListener's copy of the docket; check them there.
Supreme Court and Seventh Circuit authority
District decisions bind no one. On the questions this decision raises, the Supreme Court decisions and the circuit's published decisions listed here bind this court; a circuit disposition marked nonprecedential was not published as precedent and is persuasive only. ImmCite status as read November 14, 2026. Check the current status before relying on one.
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Kucana v. Holder, 558 U.S. 233
Supreme Court, January 20, 2010. Section 1252(a)(2)(B)(ii) bars review only of decisions whose discretionary character is specified by statute, not discretion the agency gives itself by regulation.
ImmCite: treatment available, history exists, not clearance
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Patel v. Garland, 596 U.S. 328
Supreme Court, May 16, 2022. Section 1252(a)(2)(B)(i) bars review of any judgment regarding the granting of the listed forms of relief, including the factual findings on which a denial of adjustment rests.
ImmCite: treatment available, history exists, not clearance
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Bouarfa v. Mayorkas, 604 U.S. 6
Supreme Court, December 10, 2024. Revoking an approved visa petition under § 1155 is a discretionary decision or action that § 1252(a)(2)(B)(ii) places beyond judicial review.
ImmCite: treatment available, history exists, not clearance
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Norton v. Southern Utah Wilderness Alliance, 542 U.S. 55
Supreme Court, June 14, 2004. Section 706(1) and mandamus reach only a discrete agency action that the agency is legally required to take, so a court cannot compel programmatic improvements or action the law leaves to agency discretion.
ImmCite: treatment available, history exists, not clearance
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Iddir v. INS, 301 F.3d 492
Seventh Circuit, August 6, 2002. INS had a nondiscretionary duty to adjudicate diversity-visa applications and § 1252(a)(2)(B)(ii) does not bar review of a failure to act, but no relief is available once the fiscal year ends.
ImmCite: caution, adverse or limiting treatment found. Questioned by Akash Shahi v. United States Department of S, 33 F.4th 927 (2022).
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Calderon-Ramirez v. McCament, 877 F.3d 272
Seventh Circuit, December 5, 2017. USCIS must process U-visa petitions within a reasonable time, but neither mandamus nor the APA offers relief to an applicant who shows nothing setting him apart from those ahead of him in the oldest-first queue.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 3 published decisions citing this case, as of 2026-11-13; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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Pak v. Biden, 91 F.4th 896
Seventh Circuit, January 31, 2024. Consular nonreviewability bars a systemic challenge to how terrorism-related inadmissibility exemptions are considered, a matter the statute commits to the Secretaries' sole unreviewable discretion, and a statutory citation with a facial link to the record satisfies Mandel.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 2 published decisions citing this case, as of 2026-11-13; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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Shahi v. United States Department of State, 33 F.4th 927
Seventh Circuit, May 6, 2022. Courts cannot order a diversity visa issued after the fiscal year ends whatever relief is requested, because the statute ends eligibility, and the Mandamus Act supplies a remedy rather than jurisdiction.
ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-10-29; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 10 other decisions citing it, none a Supreme Court, BIA or Attorney General precedent or a published circuit opinion; ImmCite's status does not review them.