Mandamus decisions / Southern District of New York

Huma Therapeutics, LTD v. U.S. Department of State

Southern District of New YorkSidney H. SteinDecided June 29, 2026No. 1:25-cv-01928

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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 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
  • 1. Rule of reasonfavors the government
  • 2. Congressional timetablefavors the government
  • 3. Human health and welfarefavors the government
  • 4. Competing prioritiesfavors the government
  • 5. Interests prejudicedfavors the government
  • 6. No impropriety neededneutral
Read by a model
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.