Mandamus decisions / District of Massachusetts

Mustafin v. Blinken

District of MassachusettsAllison Dale BurroughsDecided June 5, 2025No. 1:24-cv-12484

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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 At the conclusion of the interview, the consular officer handed him a 221(g)-refusal notice for administrative processing.
Form or filing	221(g) (consular refusal); DS-160 (nonimmigrant visa) Read by a model On June 10, 2024, he applied to renew his F-1 visa by filing the online DS-160 application
What the suit asked for	Finish 221(g) processing Read by a model At issue here, as the Court construes it, is not whether the Court can review a final visa adjudication, but rather whether the Court can compel Defendants to adjudicate a visa application during administrative processing.
Kind of order	A ruling on a motion or the petition Read by a model For the reasons set forth above, Defendants’ motion to dismiss, [ECF No. 11], is GRANTED without prejudice.
Motion decided	Motion to dismiss for failure to state a claim Read by a model Court will therefore review the unreasonable delay claim under Rule 12(b)(6).
Whose motion	The government's motion Read by a model Presently before the Court is Defendants’ motion to dismiss, [ECF No. 11]
Disposition	Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model For the reasons set forth above, Defendants’ motion to dismiss, [ECF No. 11], is GRANTED without prejudice.
Prevailing party	Government Read by a model For the reasons set forth above, Defendants’ motion to dismiss, [ECF No. 11], is GRANTED without prejudice.
The delay claim	Dismissed Read by a model For the reasons set forth above, Defendants’ motion to dismiss, [ECF No. 11], is GRANTED without prejudice.
Months pending	3.6 months from the application to the suit; 11.8 months from the application to the court's decision Read by a model On June 10, 2024, he applied to renew his F-1 visa by filing the online DS-160 application
TRAC factors	The court weighed the TRAC factors 1. Rule of reasonfavors the government 2. Congressional timetablefavors the government 3. Human health and welfareneutral 4. Competing prioritiesfavors the government 5. Interests prejudicedneutral 6. No impropriety neededneutral Read by a model Neither factor supports a finding of unreasonable delay here.
The government's delay arguments	First-in, first-out processing accepted; Line-jumping accepted Read by a model As to the first factor, for visa applications, courts have generally found that an agency’s process is governed by a “rule of reason,” namely adjudicating applications “in the order they were filed.”
Threshold rulings	None Read by a model
Nationality	Russia Read by a model Plaintiff is a Russian citizen

How the case ended

Docket: No. 1:24-cv-12484
Filed: September 27, 2024
Ended: June 6, 2025
Suit's filing to its end: 252 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 First 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.

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
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
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
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
Adams v. Baker, 909 F.2d 643

First Circuit, July 26, 1990. A visa denial stands under Mandel where the government states a facially legitimate and bona fide reason, and the court will not weigh the evidence behind it.

ImmCite: caution, adverse or limiting treatment found. Clarified (jurisdictional description superseded by Muñoz), as recognized in Teles De Menezes v. Rubio, 156 F.4th 1 (2025).
Teles De Menezes v. Rubio, 156 F.4th 1

First Circuit, September 18, 2025. After Muñoz, consular nonreviewability is a merits defense rather than a jurisdictional bar, and it does not reach a challenge to the State Department's reclassification of an approved petition as opposed to a visa refusal.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 2 published decisions citing this case, as of 2026-10-31; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
Towns of Wellesley, Concord & Norwood v. FERC, 829 F.2d 275

First Circuit, September 25, 1987. The First Circuit applies the TRAC factors when asked to compel agency action that has been unreasonably delayed.

ImmCite: treatment available, history exists, not clearance
Patel v. Jaddou, 118 F.4th 475

First Circuit, October 16, 2024. Assuming statutory jurisdiction, § 1255(a) does not forbid USCIS from holding adjustment applications until a visa number is immediately available, so no § 706(1) claim lies against the abeyance policy; the Fourth Circuit rejects deciding the merits before the § 1252(a)(2)(B) question.

ImmCite: caution, adverse or limiting treatment found. Reasoning rejected in the Fourth Circuit by Lolakshi Kale v. Angelica Alfonso-Royals, 139 F.4th 329 (2025).