Mandamus decisions / Northern District of Georgia

Sarar v. United States Department of State

Northern District of GeorgiaThomas W. Thrash Jr.Decided August 3, 2026No. 1:25-cv-05916

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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 According to Sarar, the State Department has failed to render a final decision on her parents’ immigrant visa applications within a reasonable time, which she alleges the State Department has a nondiscretionary duty to do.
Form or filing	221(g) (consular refusal); DS-260 (immigrant visa) Read by a model Plaintiff Afnan Mohd Ayman Abu Sarar requests a writ of mandamus directing the Defendants to, among other things, issue a final adjudication of her parents’ immigrant visa applications.
What the suit asked for	Finish 221(g) processing Read by a model Plaintiff Afnan Mohd Ayman Abu Sarar requests a writ of mandamus directing the Defendants to, among other things, issue a final adjudication of her parents’ immigrant visa applications.
Kind of order	A ruling on a motion or the petition Read by a model For the reasons set forth below, the Court GRANTS the Defendants’ Motion to Dismiss [Doc. 10].
Motion decided	Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim Read by a model The Defendants move to dismiss the Complaint under Rules 12(b)(1) and 12(b)(6).
Whose motion	The government's motion Read by a model It is before the Court on Defendants Marco Rubio; Peter T. Shea; U.S. Embassy in Amman, Jordan; and U.S. Department of State’s Motion to Dismiss [Doc. 10].
Disposition	Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model For the reasons set forth above, the Court GRANTS the Defendants’ Motion to Dismiss [Doc. 10]. The Clerk is directed to enter judgment and close the case.
Prevailing party	Government Read by a model For the reasons set forth above, the Court GRANTS the Defendants’ Motion to Dismiss [Doc. 10]. The Clerk is directed to enter judgment and close the case.
The delay claim	Dismissed Read by a model Because Sarar has not identified a final nondiscretionary action that the State Department has not taken, the Court grants the Defendants’ Motion to Dismiss Count I.
The other claims	Dismissed Read by a model Therefore, the Court grants the Defendants’ Motion to Dismiss Sarar’s due process claim (Count II).
Months pending	29.6 months from the application to the court's decision Read by a model A consular officer interviewed both parents in February 2024.
TRAC factors	The court did not weigh the TRAC factors Read by a model
Threshold rulings	No duty to re-adjudicate a 221(g) refusal Read by a model Sarar does not point to— and this Court is unable to locate—any laws or regulations that would impose additional adjudication duties on the State Department and enable the Court to compel further action.
Nationality	Jordan Read by a model Sarar is a U.S. citizen, while her parents are citizens of Jordan.
I-130 category	Immediate relative Read by a model Sarar filed “immediate relative” visa petitions for her parents

How the case ended

Docket: No. 1:25-cv-05916
Filed: October 15, 2025
Ended: August 3, 2026
Suit's filing to its end: 292 days
How it ended: Dismissed on jurisdiction or the merits
From the record: order 2026-08-03 for the defendants, ground not stated

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 Eleventh 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
Del Valle v. Secretary of State, 16 F.4th 832

Eleventh Circuit, October 26, 2021. Consular nonreviewability is not jurisdictional, but a refusal citing specific inadmissibility provisions is facially legitimate and bona fide, and in camera review of the underlying evidence is foreclosed absent plausibly alleged bad faith.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 3 published decisions citing this case, as of 2026-10-29; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
Kanapuram v. Director, USCIS, 131 F.4th 1302

Eleventh Circuit, March 20, 2025. Section 1252(a)(2)(B)(ii) strips district courts of jurisdiction over APA unreasonable-delay claims about pending adjustment applications where the delay is part of the discretionary adjudication process, including retrogression holds.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 2 published decisions citing this case, as of 2026-11-02; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.