Mandamus decisions / Western District of Virginia

Abrarahadi v. U.S. Department of State

Western District of VirginiaElizabeth K. DillonDecided August 11, 2026No. 7:25-cv-00515

Read the decision Original 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 While this case was proceeding, the U.S. Embassy—the record shows, and the parties agree—refused the visas for which Abrarahadi’s wife and daughter applied.
Form or filing	221(g) (consular refusal); DS-260 (immigrant visa) Read by a model to adjudicate the immigrant visa applications of his wife and daughter, which had been in administrative processing at the U.S. Embassy in Ankara, Turkey.
What the suit asked for	Finish 221(g) processing Read by a model brought this suit for an order or writ to compel defendants to adjudicate the immigrant visa applications of his wife and daughter, which had been in administrative processing at the U.S. Embassy in Ankara, Turkey.
Kind of order	A ruling on a motion or the petition Read by a model The refusals of visas to Abrarahadi’s wife and daughter mooted this case, so the court must dismiss it without prejudice for want of jurisdiction.
Motion decided	Motion to dismiss for lack of jurisdiction Read by a model The refusals of visas to Abrarahadi’s wife and daughter mooted this case, so the court must dismiss it without prejudice for want of jurisdiction. See Fed. R. Civ. P. 12(b)(1).
Whose motion	The government's motion Read by a model Defendants moved to dismiss.
Disposition	Dismissed as moot Dismissed or denied as moot because the agency acted. Read by a model The refusals of visas to Abrarahadi’s wife and daughter mooted this case, so the court must dismiss it without prejudice for want of jurisdiction.
Prevailing party	Neither side Read by a model The refusals of visas to Abrarahadi’s wife and daughter mooted this case, so the court must dismiss it without prejudice for want of jurisdiction.
The delay claim	Moot: the agency acted Read by a model The refusals of visas to Abrarahadi’s wife and daughter mooted this case, so the court must dismiss it without prejudice for want of jurisdiction.
Months pending	Not stated at filing The agency acted before this decision, so the months up to the decision are not a delay and are not shown. Read by a model
TRAC factors	The court did not weigh the TRAC factors Read by a model
Threshold rulings	Consular nonreviewability applied; Held moot Read by a model And the doctrine of consular nonreviewability prevents the court from examining their refusals.
Nationality	Iran Read by a model petitioned for his Iranian wife and daughter
212(f) proclamation	Proclamation 10998 Read by a model a consular officer found you ineligible for an immigrant visa under Section 212(f) of the Immigration and Nationality Act, pursuant to Presidential Proclamation 10998
I-130 category	Immediate relative Read by a model petitioned for his Iranian wife and daughter to receive immediate-relative (IR1 and IR2) immigrant visas.

How the case ended

Docket: No. 7:25-cv-00515
Filed: July 30, 2025
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.

Supreme Court and Fourth 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.

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
Sesay v. United States, 984 F.3d 312

Fourth Circuit, January 5, 2021. Consular nonreviewability bars review of a relative's visa refusal; under Din and Trump v. Hawaii a valid statutory citation satisfies Mandel, and the court will not look behind it absent a particularized showing of bad faith.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 4 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.
Gonzalez v. Cuccinelli, 985 F.3d 357

Fourth Circuit, January 14, 2021. Courts may review delay in placing U-visa petitioners on the waitlist under the TRAC factors and should not dismiss such claims at the pleading stage, but lack jurisdiction over delay in pre-waitlist work-permit requests, a point on which the Sixth Circuit disagrees.

ImmCite: caution, adverse or limiting treatment found. Rejected in the Sixth Circuit by Barrios Garcia v. U.S. Department of Homeland Security, 25 F.4th 430 (2022).
Lovo v. Miller, 107 F.4th 199

Fourth Circuit, July 3, 2024. The 'decision or action' language of § 1182(a)(9)(B)(v), which the court treated as coextensive with § 1252(a)(2)(B)(ii), does not reach USCIS inaction, so a district court may hear a claim that USCIS unreasonably delayed a provisional unlawful-presence waiver.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 5 published decisions citing this case, as of 2026-11-07; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.