Mandamus decisions / Northern District of Illinois

Patel v. Mayorkas

Northern District of IllinoisJorge Luis AlonsoDecided May 23, 2025No. 1:24-cv-12143

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.

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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	USCIS Read by a model The Court therefore lacks jurisdiction to review Plaintiffs’ claims regarding USCIS’s delay in adjudicating their EAD applications.
Form or filing	I-765 (EAD); I-918 (U visa) Read by a model Plaintiffs petitioned for U visas and applied for EADs in August 2024.
What the suit asked for	Issue a work permit Read by a model The Court therefore lacks jurisdiction to review Plaintiffs’ claims regarding USCIS’s delay in adjudicating their EAD applications.
Kind of order	A ruling on a motion or the petition Read by a model the Court grants Defendants’ motion to dismiss (ECF No. 5) and terminates this case.
Motion decided	Motion to dismiss for lack of jurisdiction; Other motion to dismiss Read by a model The Court denies Plaintiffs’ motion for leave to file a late response (ECF No. 10), grants Defendants’ motion to dismiss (ECF No. 5), and dismisses this case for lack of jurisdiction and improper venue.
Whose motion	The government's motion Read by a model the Court grants Defendants’ motion to dismiss (ECF No. 5) and terminates this case.
Disposition	Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model The Court denies Plaintiffs’ motion for leave to file a late response (ECF No. 10), grants Defendants’ motion to dismiss (ECF No. 5), and dismisses this case for lack of jurisdiction and improper venue.
Prevailing party	Government Read by a model The Court denies Plaintiffs’ motion for leave to file a late response (ECF No. 10), grants Defendants’ motion to dismiss (ECF No. 5), and dismisses this case for lack of jurisdiction and improper venue.
The delay claim	Dismissed Read by a model The Court denies Plaintiffs’ motion for leave to file a late response (ECF No. 10), grants Defendants’ motion to dismiss (ECF No. 5), and dismisses this case for lack of jurisdiction and improper venue.
Months pending	9.2 months from the application to the court's decision Read by a model Plaintiffs petitioned for U visas and applied for EADs in August 2024.
TRAC factors	The court did not weigh the TRAC factors Read by a model
Threshold rulings	Section 1252(a)(2)(B) bar applied Read by a model Because the decision to grant an EAD is at USCIS’s discretion, the decision to delay adjudicating an EAD application likewise is discretionary and barred by § 1252(a)(2)(B)(ii).
U visa claims	Final decision: dismissed; Work permit: dismissed under 1252(a)(2)(b) Read by a model Accordingly, Plaintiffs have not established that venue is proper in this District, and the Court dismisses Plaintiffs’ claims for improper venue regardless of whether the Court has jurisdiction.
Nationality	India Read by a model Plaintiffs are Indian citizens

How the case ended

Docket: No. 1:24-cv-12143
On the docket: This ruling (ECF 11)
Filed: November 25, 2024
Ended: May 23, 2025
Suit's filing to its end: 179 days
How it ended: Dismissed on jurisdiction or the merits
From the record: order 2025-05-23 dismisses for want of jurisdiction; idb disp 6 (judgment: motion before trial), judgment for defendant

A voluntary or stipulated dismissal is how most suits end once the agency acts; the docket rarely says why. Other suits in this court.

The ruling's entry is the docket's one order or judgment entered the day of the decision. Both come from CourtListener's copy of the docket; check them there.

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 14, 2026. Check the current status before relying on one.

Kucana v. Holder, 558 U.S. 233

Supreme Court, January 20, 2010. Section 1252(a)(2)(B)(ii) bars review only of decisions whose discretionary character is specified by statute, not discretion the agency gives itself by regulation.

ImmCite: treatment available, history exists, not clearance
Patel v. Garland, 596 U.S. 328

Supreme Court, May 16, 2022. Section 1252(a)(2)(B)(i) bars review of any judgment regarding the granting of the listed forms of relief, including the factual findings on which a denial of adjustment rests.

ImmCite: treatment available, history exists, not clearance
Bouarfa v. Mayorkas, 604 U.S. 6

Supreme Court, December 10, 2024. Revoking an approved visa petition under § 1155 is a discretionary decision or action that § 1252(a)(2)(B)(ii) places beyond judicial review.

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
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. ImmCite has read all 3 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.
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 2026-11-13; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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.