Mandamus decisions / Northern District of California

Mahabadi v. United States Department of State

Northern District of CaliforniaLaurel D. BeelerDecided June 26, 2026No. 3:25-cv-10508

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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 Following that interview, the U.S. Embassy in Stockholm refused the plaintiff’s visa application and placed it into administrative processing under Section 221(g) of the Immigration and Nationality Act (INA), 8 U.S.C. § 1201(g).
Form or filing	221(g) (consular refusal); DS-160 (nonimmigrant visa) Read by a model The plaintiff, who is representing himself, is a Swedish-Iranian dual citizen seeking a writ of mandamus compelling the government to adjudicate his L-1B nonimmigrant visa application.
What the suit asked for	Finish 221(g) processing Read by a model The plaintiff, who is representing himself, is a Swedish-Iranian dual citizen seeking a writ of mandamus compelling the government to adjudicate his L-1B nonimmigrant visa application.
Kind of order	A ruling on a motion or the petition Read by a model ORDER GRANTING MOTION TO DISMISS
Motion decided	Motion to dismiss for lack of jurisdiction Read by a model ORDER GRANTING MOTION TO DISMISS
Whose motion	The government's motion Read by a model The defendants assert that (1) the plaintiff’s petition is moot because his visa application has been fully adjudicated through an initial refusal under INA § 221(g) and a later refusal under § 306 of the Visa Entry Reform Act
Disposition	Dismissed as moot Dismissed or denied as moot because the agency acted. Read by a model The plaintiff’s visa application has been adjudicated, and thus, his petition is moot.
Prevailing party	Neither side Read by a model The plaintiff’s visa application has been adjudicated, and thus, his petition is moot.
The delay claim	Moot: the agency acted Read by a model The plaintiff’s visa application has been adjudicated, and thus, his petition is moot.
Months pending	20 months from the application to the suit The agency acted before this decision, so the months up to the decision are not a delay and are not shown. Read by a model He submitted his application and had his consular interview in April 2024.
TRAC factors	The court did not weigh the TRAC factors Read by a model
Threshold rulings	Held moot Read by a model The plaintiff’s visa application has been adjudicated, and thus, his petition is moot.
Nationality	Sweden Read by a model The plaintiff, who is representing himself, is a Swedish-Iranian dual citizen

How the case ended

Docket: No. 3:25-cv-10508
Filed: December 8, 2025
Ended: June 26, 2026
Suit's filing to its end: 200 days
How it ended: Ended once the agency acted
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.

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
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.
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.
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
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.