Mandamus decisions / District of Puerto Rico

Marin-Mata v. Rubio

District of Puerto RicoAida M. Delgado-ColonDecided January 23, 2026No. 3:25-cv-01185

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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 against the United States Department of State, through its Secretary, Hon. Marco Rubio (“Secretary Rubio”)
Form or filing	221(g) (consular refusal); DS-160 (nonimmigrant visa) Read by a model her non-immigrant, intracompany-transferee visa application
What the suit asked for	Finish 221(g) processing Read by a model Defendants further contend that the application is currently pending a discretionary, post-refusal “administrative processing,” and that the decision of whether and when to conclude that process lies solely within the discretion of the consular officer.
Kind of order	A transfer order Read by a model the Court will transfer plaintiff’s action to the District Court for the District of Columbia pursuant to 28 U.S.C. § 1406(a).
Motion decided	Transfer Read by a model Before the Court is defendants’ motion to dismiss and for change of venue, filed on July 8, 2025.
Whose motion	The government's motion Read by a model Before the Court is defendants’ motion to dismiss and for change of venue, filed on July 8, 2025.
Disposition	Transferred to another court An order moving the case to another court. It decides where the suit is heard, not who wins, so it is not counted as either side's win. Read by a model the Court will transfer plaintiff’s action to the District Court for the District of Columbia pursuant to 28 U.S.C. § 1406(a).
Prevailing party	Neither side Read by a model the Court will transfer plaintiff’s action to the District Court for the District of Columbia pursuant to 28 U.S.C. § 1406(a).
The delay claim	Not decided here Read by a model The Court states no opinion as to the arguments included in the defendants’ motion under Fed. R. Civ. P. 12(b)(1) or (6), leaving them to the consideration of the transferee court.
Months pending	Not stated Read by a model
TRAC factors	The court did not weigh the TRAC factors Read by a model
Threshold rulings	None Read by a model
Nationality	Venezuela Read by a model Plaintiff is a citizen of Venezuela

How the case ended

Docket: No. 3:25-cv-01185
Filed: March 31, 2025
Ended: January 23, 2026
Suit's filing to its end: 298 days
How it ended: Transferred
From the record: idb disp 0 (transferred to another district)

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 First 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
Adams v. Baker, 909 F.2d 643

First Circuit, July 26, 1990. A visa denial stands under Mandel where the government states a facially legitimate and bona fide reason, and the court will not weigh the evidence behind it.

ImmCite: caution, adverse or limiting treatment found. Clarified (jurisdictional description superseded by Muñoz), as recognized in Teles De Menezes v. Rubio, 156 F.4th 1 (2025).
Teles De Menezes v. Rubio, 156 F.4th 1

First Circuit, September 18, 2025. After Muñoz, consular nonreviewability is a merits defense rather than a jurisdictional bar, and it does not reach a challenge to the State Department's reclassification of an approved petition as opposed to a visa refusal.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 2 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.
Towns of Wellesley, Concord & Norwood v. FERC, 829 F.2d 275

First Circuit, September 25, 1987. The First Circuit applies the TRAC factors when asked to compel agency action that has been unreasonably delayed.

ImmCite: treatment available, history exists, not clearance
Patel v. Jaddou, 118 F.4th 475

First Circuit, October 16, 2024. Assuming statutory jurisdiction, § 1255(a) does not forbid USCIS from holding adjustment applications until a visa number is immediately available, so no § 706(1) claim lies against the abeyance policy; the Fourth Circuit rejects deciding the merits before the § 1252(a)(2)(B) question.

ImmCite: caution, adverse or limiting treatment found. Reasoning rejected in the Fourth Circuit by Lolakshi Kale v. Angelica Alfonso-Royals, 139 F.4th 329 (2025).