Passim

Mandamus decisions / Southern District of New York

Echegoyen Cohen v. Renaud

Southern District of New YorkPaul A. CrottyDecided March 15, 2023No. 1:21-cv-05025

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.

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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
On June 7, 2021, Plaintiff filed this Complaint against the Director of U.S. Citizenship and Immigration Services (“USCIS”) seeking to compel USCIS to adjudicate his application for a green card.
Form or filing I-526 (investor petition) Read by a model
He filed his I-526 petition on October 23, 2019.
What the suit asked for Decide the application Read by a model
On June 7, 2021, Plaintiff commenced this action seeking to compel the adjudication of his 1-526 application.
Kind of order A ruling on a motion or the petition Read by a model
For the foregoing reasons, the motion to dismiss is GRANTED without prejudice to its renewal should Plaintiff's application remain pending to an unreasonable degree.
Motion decided Motion to dismiss for failure to state a claim Read by a model
USCIS moves to dismiss the Complaint for failure to state a clatm pursuant to Federal Rule of Civil Procedure 12(b)(6).
Whose motion The government's motion Read by a model
On August 26, 2022, Defendant filed a motion to dismiss the Complaint, arguing that Plaintiff failed to allege his wait time has been unreasonable.
Disposition Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model
For the foregoing reasons, the motion to dismiss is GRANTED without prejudice to its renewal should Plaintiff's application remain pending to an unreasonable degree.
Prevailing party Government Read by a model
For the foregoing reasons, the motion to dismiss is GRANTED without prejudice to its renewal should Plaintiff's application remain pending to an unreasonable degree.
The delay claim Dismissed Read by a model
For the foregoing reasons, the motion to dismiss is GRANTED without prejudice to its renewal should Plaintiff's application remain pending to an unreasonable degree.
Months pending 19.5 months from the application to the suit; 40.7 months from the application to the court's decision Read by a model
He filed his I-526 petition on October 23, 2019.
TRAC factors The court weighed the TRAC factors
  • 1. Rule of reasonfavors the government
  • 2. Congressional timetablefavors the applicant
  • 3. Human health and welfarefavors the applicant
  • 4. Competing prioritiesfavors the government
  • 5. Interests prejudicedfavors the applicant
  • 6. No impropriety neededneutral
Read by a model
On whole, the first and fourth TRAC factors favor Defendant, while the second, third and fifth slightly favor Plaintiff and the sixth is neutral.
The government's delay arguments First-in, first-out processing accepted; Line-jumping accepted Read by a model
The process is then governed by a “first in, first out” approach of processing petitions in the order the agency receives them, similar to the process recently upheld by this Court as reasonable.
Threshold rulings APA adequate-remedy bar applied (mandamus claim fails) Read by a model
Plaintiff cannot pursue a Mandamus claim when an adequate remedy is available under the APA.
Nationality El Salvador Read by a model
Plaintiff is a citizen of El Salvador who resides in the United States as a student at Washington University.

How the case ended

Docket
No. 1:21-cv-05025
Filed
June 7, 2021
Ended
March 16, 2023
Suit's filing to its end
647 days
How it ended
Dismissed on jurisdiction or the merits
From the record
idb disp 6 (judgment: motion before trial), judgment for defendant

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 Second 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.