Mandamus decisions / Eastern District of California
Soltani Bozchalooi v. US Dept. 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
do[] not seek to have the Court determine the merits of Plaintiff’s applications, but only to compel the State Department to follow its statutory and regulatory mandate to process their applications to completion, either to a denial with reasons of denial or an issuance of a visa. |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-260 (immigrant visa)
Read by a model
Plaintiff Oskoui submitted her completed DS-260 on October 7, 2023. |
| What the suit asked for |
Finish 221(g) processing
Read by a model
But the Court’s analysis is focused on the delay at issue here, which is the post-interview delay while the visa application remains in administrative processing. |
| Kind of order |
A ruling on a motion or the petition
Read by a model
In accordance with the above, it is hereby ORDERED that Defendants’ Motion for Dismissal and Summary Judgment (ECF No. 8) is GRANTED. |
| Motion decided |
Summary judgment
Read by a model
Defendants’ Motion for Dismissal and Summary Judgment (ECF No. 8) is GRANTED. |
| Whose motion |
The government's motion
Read by a model
Defendants move for dismissal or, in the alternative, summary judgment on Plaintiffs’ claims that Defendants have unreasonably delayed adjudication of Plaintiffs’ immigrant visa application. |
| Disposition |
Granted in the government's favor
The principal motion was granted in full: summary judgment for either side, an injunction or TRO, a writ or order to act, fees. A motion to dismiss granted in full counts as Dismissed; a transfer is listed apart.
Read by a model
Defendants’ Motion for Dismissal and Summary Judgment (ECF No. 8) is GRANTED. |
| Prevailing party |
Government
Read by a model
The Clerk of Court is directed to enter judgment in Defendants’ favor. |
| The delay claim |
Relief denied
Read by a model
Accordingly, the Court concludes that Defendants are entitled to summary judgment on Plaintiffs’ APA claim for unreasonable delay. |
| The other claims |
Relief denied
Read by a model
Thus, even if Plaintiffs did bring a due process claim, the Court would grant summary judgment in Defendants’ favor. |
| Months pending |
30.3 months from the application to the court's decision
Read by a model
Plaintiff Oskoui submitted her completed DS-260 on October 7, 2023. |
| TRAC factors |
The court weighed the TRAC factors
Accordingly, the first TRAC factor weighs in Defendants’ favor. |
| The government's delay arguments |
Line-jumping accepted
Read by a model
Granting relief and ordering Defendants to adjudicate Plaintiff Oskoui’s application would necessarily push others further back in the process. |
| Threshold rulings |
Consular nonreviewability rejected; Duty to re-adjudicate a 221(g) refusal found
Read by a model
Plaintiffs’ claims are thus not barred by the doctrine of consular nonreviewability. |
| Nationality |
Iran
Read by a model
Plaintiff Mahvash Oskoui is a national and resident of Iran. |
| I-130 category |
Immediate relative
Read by a model
Plaintiff Iman Solanti Bozchalooi is a United States citizen. (Compl. (ECF No. 1) ¶ 4.) Plaintiff Mahvash Oskoui is a national and resident of Iran. (Id. ¶ 14.) Plaintiff Oskoui is Plaintiff Bozchalooi’s biological mother. (Id. ¶ 4.) |
How the case ended
- Docket
- No. 2:25-cv-02983
- Filed
- October 15, 2025
- Ended
- April 17, 2026
- Suit's filing to its end
- 184 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 Ninth 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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Allen v. Milas, 896 F.3d 1094
Ninth Circuit, July 24, 2018. The APA provides no avenue for review of a consular visa refusal beyond Mandel's facially-legitimate-and-bona-fide inquiry, and consular nonreviewability is not a jurisdictional bar.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 8 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.
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Sanchez Gonzalez v. United States Department of State, No. 23-4205 (9th Cir. Apr. 30, 2026)
Ninth Circuit, April 30, 2026. After Muñoz, a citizen spouse's own First Amendment interest triggered Mandel review, which a facially legitimate and bona fide reason satisfied absent a showing of bad faith.
ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-10-18; it checks for new citing decisions daily. That is not a determination that the case is good law.
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Independence Mining Co. v. Babbitt, 105 F.3d 502
Ninth Circuit, January 23, 1997. Mandamus and APA § 706(1) claims to compel delayed agency action are analyzed alike under the TRAC factors.
ImmCite: treatment available, history exists, not clearance
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Vaz v. Neal, 33 F.4th 1131
Ninth Circuit, May 9, 2022. Section 706(1) compels only a clear, mandatory and discrete duty that has been unreasonably delayed under TRAC, and the APA's prerequisites go to the merits while § 1331 supplies jurisdiction.
ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-11-03; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 144 other decisions citing it, none a Supreme Court, BIA or Attorney General precedent or a published circuit opinion; ImmCite's status does not review them.