Mandamus decisions / Western District of Washington

Nazemi v. Rubio

Western District of WashingtonJamal N WhiteheadDecided June 18, 2026No. 2:25-cv-02466

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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

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Agency	Department of State Read by a model The petition was approved and on April 15, 23 2025, Shahidi attended a scheduled immigrant visa interview at the U.S. Embassy DISMISSAL ORDER - 1 1 in Ankara, Turkey.
Form or filing	221(g) (consular refusal); DS-260 (immigrant visa) Read by a model immigrant visa interview at the U.S. Embassy DISMISSAL ORDER - 1 1 in Ankara, Turkey. Subsequently, Shahidi’s visa application was refused for 2 administrative processing
What the suit asked for	Finish 221(g) processing Read by a model requesting that this Court compel Defendants to complete all administrative 7 processing within sixty days
Kind of order	A ruling on a motion or the petition Read by a model the Court GRANTS the motion for the reasons stated below.
Motion decided	Motion to dismiss for failure to state a claim Read by a model Defendants 9 have moved to dismiss under Federal Rule of Civil Procedure 12(b)(6).
Whose motion	The government's motion Read by a model This matter comes before the Court on Defendants’ motion to dismiss.
Disposition	Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model The 12 complaint is DISMISSED with prejudice.
Prevailing party	Government Read by a model Accordingly, Defendants’ motion to dismiss, Dkt. No. 7, is GRANTED.
The delay claim	Dismissed Read by a model complaint is DISMISSED with prejudice.
Months pending	14.1 months from the application to the court's decision Read by a model The petition was approved and on April 15, 23 2025, Shahidi attended a scheduled immigrant visa interview at the U.S. Embassy DISMISSAL ORDER - 1 1 in Ankara, Turkey.
TRAC factors	The court weighed the TRAC factors 1. Rule of reasonnot reached 2. Congressional timetablenot reached 3. Human health and welfarenot reached 4. Competing prioritiesnot reached 5. Interests prejudicednot reached 6. No impropriety needednot reached Read by a model
Threshold rulings	No duty to re-adjudicate a 221(g) refusal Read by a model Shahidi’s visa application had already been adjudicated when it was 7 refused on April 15, 2025, and the agency was under no mandatory, 8 nondiscretionary duty to readjudicate.
I-130 category	Immediate relative Read by a model application for an IR-1 immigration visa.

How the case ended

Docket: No. 2:25-cv-02466
Filed: December 5, 2025
Ended: June 18, 2026
Suit's filing to its end: 195 days
How it ended: Ended, outcome not recorded
From the record: idb disp 6 (judgment: motion before trial), judgment for unknown

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.