Passim

Mandamus decisions / Eastern District of New York

Edwards v. Garland

Eastern District of New YorkRamon E. Reyes Jr.Decided September 16, 2025No. 1:24-cv-07367

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
Defendant U.S. Citizenship and Immigration Services (“USCIS” or, along with its officers, collectively “Defendants”) informed her that same month that it would hold the I-485 application in abeyance and address it along with the I-360 application.
Form or filing I-360 (special immigrant petition); I-485 (adjustment of status) Read by a model
In March 2022, with the assistance of Safe Horizon of New York, Edwards filed a Form I-360 Petition for Amerasian, Widow, or Special Immigrant filed under VAWA.
What the suit asked for Decide the application Read by a model
Plaintiff seeks an order compelling Defendants to adjudicate her immigration applications within thirty days.
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 is granted.
Motion decided Motion to dismiss for failure to state a claim Read by a model
On January 29, 2025, Defendants moved to dismiss the complaint for failure to state a claim under Rule 12(b)(6) of the Federal Rules of Civil Procedure.
Whose motion The government's motion Read by a model
On January 29, 2025, Defendants moved to dismiss the complaint for failure to state a claim under Rule 12(b)(6) of the Federal Rules of Civil Procedure.
Disposition Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model
Accordingly, this case is dismissed without prejudice for failure to state a claim.
Prevailing party Government Read by a model
For the reasons set forth above, Defendants’ motion to dismiss is granted.
The delay claim Dismissed Read by a model
For the reasons set forth above, Defendants’ motion to dismiss is granted. Accordingly, this case is dismissed without prejudice for failure to state a claim.
The other claims Dismissed Read by a model
III. Plaintiff’s Due Process Claim is Dismissed
Months pending 31.3 months from the application to the suit; 42.1 months from the application to the court's decision Read by a model
In March 2022, with the assistance of Safe Horizon of New York, Edwards filed a Form I-360 Petition for Amerasian, Widow, or Special Immigrant filed under VAWA.
TRAC factors The court weighed the TRAC factors
  • 1. Rule of reasonfavors the government
  • 2. Congressional timetablefavors the government
  • 3. Human health and welfarefavors the government
  • 4. Competing prioritiesfavors the government
  • 5. Interests prejudicedfavors the government
  • 6. No impropriety neededneutral
Read by a model
Additionally, USCIS’s attempt to better address processing times through a centralized process further bolsters its rule of reason.
The government's delay arguments First-in, first-out processing accepted; Line-jumping accepted Read by a model
The Court has previously determined that similar “first-in-first-out” (“FIFO”) procedures constitute a “rule of reason.”
Threshold rulings APA adequate-remedy bar applied (mandamus claim fails) Read by a model
Second, the APA is itself an adequate remedy, even if her claim fails there too.

How the case ended

Docket
No. 1:24-cv-07367
Filed
October 22, 2024
Ended
September 17, 2025
Suit's filing to its end
330 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.