Passim

Mandamus decisions / District of Minnesota

Patel v. Noem

District of MinnesotaDulce J. FosterDecided September 12, 2025No. 0:25-cv-03167

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.

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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 ICE Read by a model
He is now “presently detained by [ICE] at the Freeborn County Jail in Albert Lea, Minnesota” (ECF No. 1 at 2) while ICE awaits receipt of a new travel document so it can deport Mr. Patel to India (ECF No. 12 at 3).
Form or filing I-918 (U visa) Read by a model
issue a writ of mandamus to require United States Citizenship and Immigration Services (“USCIS”) to adjudicate his application for a U-visa, which has been pending since April 2024
What the suit asked for Not recorded Read by a model
Kind of order A magistrate judge's recommendation Read by a model
This Report and Recommendation is not an order or judgment of the District Court
Motion decided None Read by a model
Whose motion The plaintiff's motion Read by a model
Petitioner Dipakkumar Baldevbhai Patel’s Petition for Writ of Habeas Corpus, Writ of Mandamus, and Complaint for Declaratory Judgment, and Injunctive Relief for an Order to Show Cause (ECF No. 1) be DENIED.
Disposition Magistrate judge's recommendation A magistrate judge's report and recommendation. The district judge decides whether to adopt it, so it is not counted as either side's win. Read by a model
This Report and Recommendation is not an order or judgment of the District Court
Prevailing party Neither side Read by a model
This Report and Recommendation is not an order or judgment of the District Court
The delay claim Dismissed Read by a model
This Court joins these other courts and concludes Mr. Patel’s requests for a writ of mandamus and declaratory relief are not properly presented. If Mr. Patel wishes to pursue those forms of relief, he must do so through a separate action.
The other claims Dismissed Read by a model
Furthermore, the Court concludes Mr. Patel’s request for habeas relief—in other words, his request for an order requiring Respondents to release him—should be dismissed for lack of subject matter jurisdiction.
Months pending 16.9 months from the application to the court's decision Read by a model
his application for a U-visa, which has been pending since April 2024
TRAC factors The court did not weigh the TRAC factors Read by a model
Threshold rulings None Read by a model
U visa claims Final decision: dismissed Read by a model
This Court joins these other courts and concludes Mr. Patel’s requests for a writ of mandamus and declaratory relief are not properly presented. If Mr. Patel wishes to pursue those forms of relief, he must do so through a separate action.
Nationality India Read by a model
is a native and citizen of India

How the case ended

Docket
No. 0:25-cv-03167
Filed
August 8, 2025
Ended
October 3, 2025
Suit's filing to its end
56 days
How it ended
Dismissed, ground not recorded
From the record
idb disp 14 (dismissed: other)

A voluntary or stipulated dismissal is how most suits end once the agency acts; the docket rarely says why.

Supreme Court and Eighth 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.