Mandamus decisions / Northern District of Illinois

Bahiraei v. Blinken

Northern District of IllinoisJoan Humphrey LefkowDecided February 15, 2024No. 1:22-cv-07360

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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 After publication of the June 2022 IMSE, plaintiffs took steps to seek reconsideration of the visa applications or otherwise inquire as to their eligibility under this exemption, but consular officers either denied or did not respond to all such requests.
Form or filing	DS-260 (immigrant visa) Read by a model The named plaintiffs in this case include family-based immigrant visa applicants, their U.S. citizen or legal permanent resident family members, and employment-based immigrant visa applicants.
What the suit asked for	Not recorded Read by a model
Kind of order	A ruling on a motion or the petition Read by a model For the foregoing reasons, the government’s motion to dismiss (dkt. 59) is granted
Motion decided	Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim; Preliminary injunction or TRO Read by a model Pending before the court are plaintiffs’ motions for class certification (dkt. 43), preliminary injunction (dkt. 46), and evidentiary hearing (dkt. 70), as well as the government’s motion to dismiss for lack of jurisdiction and failure to state a claim (dkt. 59).
Whose motion	Cross-motions Read by a model For the foregoing reasons, the government’s motion to dismiss (dkt. 59) is granted, and plaintiffs’ motions for class certification, a preliminary injunction, and evidentiary hearing (dkts. 43, 46, 70) are accordingly denied as moot.
Disposition	Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model For the reasons described below, the government’s motion to dismiss is granted and the plaintiffs’ motions are denied as moot.
Prevailing party	Government Read by a model For the reasons described below, the government’s motion to dismiss is granted and the plaintiffs’ motions are denied as moot.
The other claims	Dismissed Read by a model Although plaintiffs have standing to present their case in federal court, the doctrine of consular nonreviewability clearly requires dismissal of their claims.
Months pending	Not stated Read by a model
TRAC factors	The court did not weigh the TRAC factors Read by a model
Threshold rulings	Consular nonreviewability applied Read by a model Although plaintiffs have standing to bring these claims, the doctrine of consular nonreviewability clearly requires dismissal of this lawsuit.
Nationality	Iran Read by a model All are Iranian citizens who were involuntarily conscripted into the IRGC and completed this mandatory military service before the IRGC was designated a Tier I FTO in April 2019.

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
Bahiraei v. Blinken	February 15, 2024	Joan H. Lefkow	Dismissed
Bahiraei v. BlinkenThis decisionThe case's latest decision: its outcome is the one counted	February 15, 2024	Joan Humphrey Lefkow	Dismissed

How the case ended

Docket: No. 1:22-cv-07360
Filed: December 30, 2022
Ended: July 2, 2024
Suit's filing to its end: 550 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.

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.

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
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
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
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.
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.
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.
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).
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
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.