Mandamus decisions / Southern District of New York
Huma Therapeutics, LTD v. U.S. Department of State
Read the decisionOriginal 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 the U.S. Department of State is indeed obligated to render a final determination on Vahdat’s visa applications presently in administrative processing, the TRAC factors do not support that a final determination has been unreasonably delayed. |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-160 (nonimmigrant visa)
Read by a model
a B-1/B-2 visa. (Id. ¶ 52.) Vahdat appeared at the U.S. Embassy in London for an interview in connection with these applications on November 7, 2024. (Id. ¶ 53.) On that same day, Vahdat’s visa applications were “refused” and placed in a state of administrative processing. |
| What the suit asked for |
Finish 221(g) processing
Read by a model
the relief that plaintiffs seek is an order directing defendants to complete the administrative processing of Vahdat’s visa applications. |
| Kind of order |
A ruling on a motion or the petition
Read by a model
For the reasons that follow, the Court grants defendants’ motion and dismisses the complaint. |
| Motion decided |
Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim
Read by a model
Because plaintiffs' claim that defendants acted arbitrarily and capriciously is moot and unripe, the Court grants defendants' motion to dismiss this claim pursuant to Rule 12(b)(l) and 12(b)(6). |
| Whose motion |
The government's motion
Read by a model
Defendants have moved to dismiss plaintiffs’ complaint pursuant to Rule 12(b)(1) and 12(b)(6) of the Federal Rules of Civil Procedure. |
| 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 defendants' motion to dismiss the complaint. |
| Prevailing party |
Government
Read by a model
For the reasons set forth above, the Court grants defendants' motion to dismiss the complaint. |
| The delay claim |
Dismissed
Read by a model
Accordingly, the Court grants defendants’ motion pursuant to Rule 12(b)(6) to dismiss plaintiffs’ claim that defendants have unreasonably delayed the final determination of Vahdat’s visa applications. |
| The other claims |
Dismissed
Read by a model
Because plaintiffs' claim that defendants acted arbitrarily and capriciously is moot and unripe, the Court grants defendants' motion to dismiss this claim pursuant to Rule 12(b)(l) and 12(b)(6). |
| 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
Vahdat appeared at the U.S. Embassy in London for an interview in connection with these applications on November 7, 2024. |
| TRAC factors |
The court weighed the TRAC factors
Accordingly, TRAC factors one and two weigh in favor of defendants. |
| The government's delay arguments |
Line-jumping accepted
Read by a model
it is inconceivable that an order directing defendants to complete that vetting forthwith would result in no “shift[ing of] resources away from equally deserving applicants.” |
| Threshold rulings |
Consular nonreviewability rejected; Held moot; Mootness argument rejected; Duty to re-adjudicate a 221(g) refusal found
Read by a model
the Court declines to invoke the doctrine of consular nonreviewability to insulate defendants from claims that they have been derelict in fulfilling their statutorily prescribed duties within a reasonable amount of time. |
| Nationality |
United Kingdom
Read by a model
Danoosh Vahdat is a dual national of the United Kingdom and Iran |
How the case ended
- Docket
- No. 1:25-cv-01928
- On the docket
- This ruling (ECF 33)
- Filed
- March 7, 2025
- Ended
- June 30, 2026
- Suit's filing to its end
- 480 days
- How it ended
- Dismissed on jurisdiction or the merits
- From the record
- judgment 2026-06-30 dismisses on the TRAC factors; 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 Second 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.
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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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American Academy of Religion v. Napolitano, 573 F.3d 115
Second Circuit, July 17, 2009. Where a visa refusal implicates U.S. citizens' First Amendment rights, Mandel review applies: the government must identify a properly construed statutory ground and the officer's reason to believe it applies, and the applicant must have a chance to rebut a knowing material-support charge.
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.
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Chen v. Rubio, 158 F.4th 393
Second Circuit, October 29, 2025. After Muñoz, consular nonreviewability insulates relatives' visa refusals from a citizen sponsor's challenge, and the claims were properly dismissed with prejudice.
ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-11-13; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 5 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.