Mandamus decisions / District of Columbia
BEHZAD MEHR v. BLINKEN
Read the decisionOriginal on CourtListener
2,996 written decisions from 2,731 cases in the whole mandamus and agency-delay group, the group's newest decided November 12, 2026. Updated November 14, 2026 at 1:17 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 1,617 public decisions since January 1, 2025 that a CourtListener and GovInfo search for mandamus and agency delay finds, Passim holds 1,406 (87%), 1,039 of them in this group, measured November 14, 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 close of that interview, the consular officer advised Plaintiffs that their application would be placed into administrative processing, directed them to complete another online questionnaire (Form DS- 5535), and issued a Section 221(g) refusal. |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-260 (immigrant visa)
Read by a model
Plaintiffs submitted a Form DS-260 on March 31, 2023, and NVC confirmed that Plaintiffs were documentarily qualified on April 27, 2023. |
| What the suit asked for |
Finish 221(g) processing
Read by a model
After the interview, Plaintiffs were issued a “refusal” under Section 221(g) of the Immigration and Nationality Act (“INA”) and were told that their application required further “administrative processing.” |
| Kind of order |
A ruling on a motion or the petition
Read by a model
For the foregoing reasons, the Court GRANTS Defendant’s motion to dismiss (ECF No. 12). |
| Motion decided |
Motion to dismiss for failure to state a claim
Read by a model
Invoking Rule 12(b)(1) and 12(b)(6), the Secretary presses three arguments for dismissal: |
| Whose motion |
The government's motion
Read by a model
For the foregoing reasons, the Court GRANTS Defendant’s motion to dismiss (ECF No. 12). |
| Disposition |
Dismissed
The case or every delay claim was dismissed for a reason other than mootness.
Read by a model
For the foregoing reasons, the Court GRANTS Defendant’s motion to dismiss (ECF No. 12). |
| Prevailing party |
Government
Read by a model
For the foregoing reasons, the Court GRANTS Defendant’s motion to dismiss (ECF No. 12). |
| The delay claim |
Dismissed
Read by a model
Applying these principles here, and accepting Plaintiffs’ allegations as true, the Court agrees with the Secretary that the complaint fails to state a claim of unreasonable delay under either the APA or the Mandamus Act. |
| Months pending |
15.5 months from the application to the suit; 40.4 months from the application to the court's decision
Read by a model
Plaintiffs submitted a Form DS-260 on March 31, 2023, and NVC confirmed that Plaintiffs were documentarily qualified on April 27, 2023. |
| TRAC factors |
The court weighed the TRAC factors
So, the first factors— among the “most important” ones, Da Costa, 80 F.4th at 340—cut against Plaintiffs. |
| The government's delay arguments |
Line-jumping accepted
Read by a model
This factor likewise tilts against Plaintiffs. If the Court grants the relief they seek, they would suddenly be prioritized over so many others who likewise await action on their visa applications. |
| Threshold rulings | None Read by a model |
| Nationality |
Iran
Read by a model
Dr. Raziyeh Behzad Mehr and her family are Iranian citizens and residents. |
How the case ended
- Docket
- No. 1:24-cv-02197
- On the docket
- This ruling (ECF 19)
- Filed
- July 25, 2024
- Status
- Pending as of the last docket check
A voluntary or stipulated dismissal is how most suits end once the agency acts; the docket rarely says why. Other suits in this court.
The ruling's entry is the docket's one order or judgment entered the day of the decision. Both come from CourtListener's copy of the docket; check them there.
Supreme Court and D.C. 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 14, 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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Saavedra Bruno v. Albright, 197 F.3d 1153
D.C. Circuit, December 3, 1999. Consular visa decisions are not subject to judicial review absent an express statutory grant, and the APA does not displace that doctrine.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 18 published decisions citing this case, as of 2026-11-13; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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Baan Rao Thai Restaurant v. Pompeo, 985 F.3d 1020
D.C. Circuit, January 22, 2021. Consular nonreviewability bars a federal court from second-guessing a consular officer's decision to issue or withhold a visa, and dismissal on that ground is a merits ruling rather than a jurisdictional one.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 3 published decisions citing this case, as of 2026-11-13; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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Pietersen v. Department of State, 138 F.4th 552
D.C. Circuit, May 30, 2025. Consular nonreviewability does not bar a forward-looking APA challenge to generally applicable State Department guidance, as distinct from review of an individual visa refusal.
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 24 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.
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Telecommunications Research & Action Center v. FCC, 750 F.2d 70
D.C. Circuit, October 24, 1984. Whether agency delay is unreasonable turns on six factors: a rule of reason, any statutory timetable, the human welfare interests at stake, the effect of expediting on competing priorities, the interests prejudiced by delay, and no need to find impropriety.
ImmCite: treatment available, history exists, not clearance
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Mashpee Wampanoag Tribal Council, Inc. v. Norton, 336 F.3d 1094
D.C. Circuit, August 8, 2003. A claim that an agency has unreasonably delayed a matter arises under the APA and § 1331, and the TRAC factors decide whether the delay is unreasonable.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 11 published decisions citing this case, as of 2026-11-13; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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Karimova v. Abate, No. 23-5178 (D.C. Cir. July 24, 2024) (unpublished judgment)
D.C. Circuit, July 24, 2024, nonprecedential. Neither § 555(b) nor any other law imposes a clear, nondiscretionary duty on a consular officer to re-adjudicate a visa application that was officially refused under § 1201(g) and placed in administrative processing, so mandamus and § 706(1) relief are unavailable.
ImmCite: not applicable, outside the precedential ImmCite corpus