Mandamus decisions / District of Massachusetts

Saadat Mostafavi v. Trump

District of MassachusettsAllison Dale BurroughsDecided September 18, 2026No. 1:25-cv-12287

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2,917 written decisions from 2,664 cases in the whole mandamus and agency-delay group, the group's newest decided October 30, 2026. Updated November 3, 2026 at 7:07 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	Department of State Read by a model They argue that the denial of their visa applications was not a decision made within the consular’s discretion because the State Department’s implementation guidance for Proclamation 10949 required consular officers to refuse their visas thus making the decision nondiscretionary.
Form or filing	221(g) (consular refusal); DS-260 (immigrant visa) Read by a model On November 8, 2022, Plaintiffs submitted their DS-260 application with additional information.
What the suit asked for	Not recorded Read by a model
Kind of order	A ruling on a motion or the petition Read by a model Defendants’ motion to dismiss, [ECF No. 22], is GRANTED IN PART and DENIED IN PART.
Motion decided	Motion to dismiss for failure to state a claim Read by a model When deciding a motion to dismiss under Rule 12(b)(6), the Court must accept as true all well-pleaded facts, analyze those facts in the light most favorable to the plaintiff, and draw all reasonable factual inferences in favor of the plaintiff.
Whose motion	The government's motion Read by a model Defendants’ motion to dismiss, [ECF No. 22], is GRANTED IN PART and DENIED IN PART.
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 Counts I, III, VI, VII, VIII, and IX are dismissed in their entirety.
Prevailing party	Each side in part Read by a model Counts I, III, VI, VII, VIII, and IX are dismissed in their entirety.
The delay claim	Dismissed Read by a model Counts I, III, VI, VII, VIII, and IX are dismissed in their entirety.
The other claims	Some dismissed, some go on Read by a model Counts II and V are dismissed only insofar as they challenge the denial of Plaintiffs’ individual visa applications, as discussed in detail above.
Months pending	33.2 months from the application to the suit; 46.3 months from the application to the court's decision Read by a model On November 8, 2022, Plaintiffs submitted their DS-260 application with additional information.
TRAC factors	The court did not weigh the TRAC factors Read by a model
Threshold rulings	Consular nonreviewability applied; Consular nonreviewability rejected Read by a model Accordingly, the Court finds that Plaintiffs’ challenges to the government’s individualized determinations regarding their visa applications are barred by the doctrine of consular nonreviewability.
Nationality	Iran Read by a model Mostafavi, an Iranian national, is a physician and researcher
212(f) proclamation	Proclamation 10949 Read by a model they were found ineligible for immigrant visas under Proclamation 10949 and INA 212(f)

How the case ended

Docket: No. 1:25-cv-12287
Filed: August 15, 2025
Ended: October 28, 2026
Suit's filing to its end: 439 days
How it ended: Ended once the agency acted
From the record: voluntary dismissal 2026-10-23

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).