Mandamus decisions / Northern District of Illinois
Ebrahimi v. Blinken
Read the decisionOriginal on CourtListener
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.
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
In this case, not only was Akbar’s application refused for administrative processing under Section 221(g), but he was also later informed by the State Department that further adjudication would be necessary: “You will receive another adjudication once such [administrative] processing is complete.” |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-260 (immigrant visa)
Read by a model
On November 28, 2021, plaintiffs-petitioners filed Form DS-260 and paid the required processing fees. |
| What the suit asked for |
Finish 221(g) processing
Read by a model
a plaintiff-petitioner seeks an expedited adjudication of a visa application that has been refused for administrative processing under Section 221(g) and for which the applicant has been assured of further adjudication. |
| Kind of order |
A ruling on a motion or the petition
Read by a model
For the foregoing reasons, the motion to dismiss (dkt. 11) is granted. |
| Motion decided |
Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim
Read by a model
Defendants-respondents move to dismiss under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). |
| Whose motion |
The government's motion
Read by a model
Defendants-respondents move to dismiss under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). |
| Disposition |
Dismissed
The case or every delay claim was dismissed for a reason other than mootness.
Read by a model
For the foregoing reasons, the motion to dismiss (dkt. 11) is granted. Counts I and IV are dismissed with prejudice, but Counts II and III are dismissed without prejudice. |
| Prevailing party |
Government
Read by a model
For the foregoing reasons, the motion to dismiss (dkt. 11) is granted. Counts I and IV are dismissed with prejudice, but Counts II and III are dismissed without prejudice. |
| The delay claim |
Dismissed
Read by a model
Counts I and IV are dismissed with prejudice, but Counts II and III are dismissed without prejudice. |
| Months pending |
18.7 months from the application to the suit; 29.1 months from the application to the court's decision
Read by a model
On November 28, 2021, plaintiffs-petitioners filed Form DS-260 and paid the required processing fees. |
| TRAC factors |
The court weighed the TRAC factors
In sum, all TRAC factors favor finding that plaintiffs-petitioners have not plausibly alleged that the 11-month “delay” in the adjudication of Akbar’s application is unreasonable. |
| The government's delay arguments |
Line-jumping accepted
Read by a model
the lack of differentiation nonetheless supports the government’s position since compelling an expedited adjudication of Akbar’s application would presumably divert resources away from other competing priorities. |
| Threshold rulings |
Consular nonreviewability rejected; Mootness argument rejected; APA adequate-remedy bar applied (mandamus claim fails)
Read by a model
Just as the ongoing adjudication of Akbar’s application satisfies standing doctrine’s redressability prong, that ongoing adjudication means that no final decision has been made that would implicate the doctrine of consular nonreviewability. |
| Nationality |
Iran
Read by a model
her father, Iranian national Akbar Ebrahimi |
| I-130 category |
Immediate relative
Read by a model
On or about February 20, 2020, United States citizen Samaneh Ebrahimi filed a petition for an immigration visa on behalf of her father, Iranian national Akbar Ebrahimi, via Form I-130 (“Petition for Alien Relative”). |
Other orders in this case
The group holds 2 decisions from this suit, oldest first. Outcome counts on these pages count the case once, by its latest decision, this one. How decisions are grouped into cases.
| Decision | Decided | Judge | Disposition |
|---|---|---|---|
| Ebrahimi v. Blinken | May 3, 2024 | Joan H. Lefkow | Dismissed |
| Ebrahimi v. BlinkenThis decisionThe case's latest decision: its outcome is the one counted | May 3, 2024 | Joan Humphrey Lefkow | Dismissed |
How the case ended
- Docket
- No. 1:23-cv-03867
- Filed
- June 20, 2023
- Ended
- August 14, 2024
- Suit's filing to its end
- 421 days
- How it ended
- Ended once the agency acted
- From the record
- idb disp 12 (dismissed: voluntarily)
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 Seventh 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.
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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
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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
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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
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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
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Pak v. Biden, 91 F.4th 896
Seventh Circuit, January 31, 2024. Consular nonreviewability bars a systemic challenge to how terrorism-related inadmissibility exemptions are considered, a matter the statute commits to the Secretaries' sole unreviewable discretion, and a statutory citation with a facial link to the record satisfies Mandel.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 2 published decisions citing this case, as of 2026-10-30; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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Matushkina v. Nielsen, 877 F.3d 289
Seventh Circuit, December 7, 2017. Consular nonreviewability is a merits rule rather than a limit on subject-matter jurisdiction, and it bars indirect attacks on a visa refusal through the underlying inadmissibility finding.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 11 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.
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Yafai v. Pompeo, 912 F.3d 1018
Seventh Circuit, January 4, 2019. A visa refusal citing a statutory inadmissibility ground supported by facts in the record is facially legitimate and bona fide, and bad faith must be affirmatively shown before a court looks further.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 8 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.
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Iddir v. INS, 301 F.3d 492
Seventh Circuit, August 6, 2002. INS had a nondiscretionary duty to adjudicate diversity-visa applications and § 1252(a)(2)(B)(ii) does not bar review of a failure to act, but no relief is available once the fiscal year ends.
ImmCite: caution, adverse or limiting treatment found. Questioned by Akash Shahi v. United States Department of S, 33 F.4th 927 (2022).
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Calderon-Ramirez v. McCament, 877 F.3d 272
Seventh Circuit, December 5, 2017. USCIS must process U-visa petitions within a reasonable time, but neither mandamus nor the APA offers relief to an applicant who shows nothing setting him apart from those ahead of him in the oldest-first queue.
ImmCite: treatment available, history exists, not clearance
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Shahi v. United States Department of State, 33 F.4th 927
Seventh Circuit, May 6, 2022. Courts cannot order a diversity visa issued after the fiscal year ends whatever relief is requested, because the statute ends eligibility, and the Mandamus Act supplies a remedy rather than jurisdiction.
ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-10-29; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 10 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.