Mandamus decisions / Western District of Michigan
Al Zuhairi v. United States Department of State
Read the decisionOriginal on CourtListener
2,914 written decisions from 2,661 cases in the whole mandamus and agency-delay group, the group's newest decided October 30, 2026. Updated November 3, 2026 at 1:24 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 1,606 public decisions since January 1, 2025 that a CourtListener and GovInfo search for mandamus and agency delay finds, Passim holds 1,371 (85%), measured November 3, 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 |
Department of State
Read by a model
Plaintiff seeks a writ of mandamus to require the State Department to adjudicate the visa application within sixty days. |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-160 (nonimmigrant visa)
Read by a model
Rather, Plaintiff asserts that the refusal is not a final decision because the consular officer, by requesting additional information, kept open the “administrative processing” of Mr. Qaddoori’s visa application. |
| What the suit asked for |
Finish 221(g) processing
Read by a model
Rather, Plaintiff asserts that the refusal is not a final decision because the consular officer, by requesting additional information, kept open the “administrative processing” of Mr. Qaddoori’s visa application. |
| Kind of order |
A ruling on a motion or the petition
Read by a model
Defendants’ motion to dismiss (ECF No. 5) is GRANTED. |
| Motion decided |
Motion to dismiss for lack of jurisdiction
Read by a model
On August 8, 2025, the State Department filed its motion to dismiss under Federal Rule of Civil Procedure 12(b)(1), arguing that the Court lacks subject matter jurisdiction; |
| Whose motion |
The government's motion
Read by a model
Defendants’ motion to dismiss (ECF No. 5) is GRANTED. |
| Disposition |
Dismissed
The case or every delay claim was dismissed for a reason other than mootness.
Read by a model
The Court DISMISSES the complaint (ECF No. 1) without prejudice for lack of subject-matter jurisdiction. |
| Prevailing party |
Government
Read by a model
For the reasons discussed above, Defendants’ motion to dismiss (ECF No. 5) is GRANTED. |
| The delay claim |
Dismissed
Read by a model
The Court DISMISSES the complaint (ECF No. 1) without prejudice for lack of subject-matter jurisdiction. |
| The other claims |
Dismissed
Read by a model
Accordingly, Plaintiff’s due process claim will be dismissed for lack of subject matter jurisdiction. |
| Months pending |
25.4 months from the application to the court's decision
Read by a model
The State Department has submitted evidence that Mr. Qaddoori was interviewed by a consular officer at the U.S. Embassy in Ankara, Turkey, on February 14, 2024. |
| TRAC factors | The court did not weigh the TRAC factors Read by a model |
| Threshold rulings |
Consular nonreviewability applied; Mootness argument rejected; No duty to re-adjudicate a 221(g) refusal
Read by a model
The Court further finds that Plaintiff otherwise lacks standing to bring this action on behalf of her fiancé, and that the doctrine of consular non-reviewability applies to this case. |
| Nationality |
Iraq
Read by a model
her fiancé, Aiman Salih Qaddoori Qaddoori, is an Iraqi citizen. |
How the case ended
- Docket
- No. 1:25-cv-00568
- Filed
- May 16, 2025
- Ended
- March 27, 2026
- Suit's filing to its end
- 315 days
- How it ended
- Dismissed on jurisdiction or the merits
- From the record
- idb disp 3 (dismissed: lack of jurisdiction)
A voluntary or stipulated dismissal is how most suits end once the agency acts; the docket rarely says why. Other suits in this court.
Supreme Court and Sixth 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 3, 2026. Check the current status before relying on one.
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Department of State v. Muñoz, 602 U.S. 899
Supreme Court, June 21, 2024. A U.S. citizen has no fundamental liberty interest in a noncitizen spouse's admission, so marriage alone entitles the citizen neither to Mandel review of the consular refusal nor to an explanation beyond the statutory citation.
ImmCite: treatment available, history exists, not clearance
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Trump v. Hawaii, 585 U.S. 667
Supreme Court, June 26, 2018. Mandel's facially-legitimate-and-bona-fide standard governs constitutional challenges to entry restrictions, and a citation to a valid statutory ground ordinarily satisfies it.
ImmCite: treatment available, history exists, not clearance
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Kleindienst v. Mandel, 408 U.S. 753
Supreme Court, June 29, 1972. When a visa refusal burdens a U.S. citizen's own constitutional rights, courts ask only whether the Executive gave a facially legitimate and bona fide reason and do not look behind it.
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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Baaghil v. Miller, 1 F.4th 427
Sixth Circuit, June 14, 2021. Visa denials stood where the consulate gave a facially legitimate and bona fide reason, and a citizen's asserted liberty interest in a relative's admission adds no further process.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 3 published decisions citing this case, as of 2026-10-29; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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Barrios Garcia v. U.S. Department of Homeland Security, 25 F.4th 430
Sixth Circuit, February 10, 2022. Courts may review and compel unreasonably delayed U-visa waitlist placement and bona fide determinations under TRAC, though not discretionary pre-waitlist work authorization, disagreeing in part with the Fourth Circuit's Gonzalez.
ImmCite: unchecked, treatment not confirmed yet, not evidence either way. No verified adverse treatment has been found so far. All 2 precedential decisions citing this case have been reviewed as of 2026-10-29.