Mandamus decisions / Eastern District of California
Ghahraloud v. United States 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
On June 18, 2025, the State Department issued a final adjudication of Plaintiff’s application. |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-260 (immigrant visa)
Read by a model
Plaintiff’s visa application was refused that same day under section 221(g) of the Immigration and Nationality Act. |
| What the suit asked for |
Finish 221(g) processing
Read by a model
Plaintiff’s request that the court order Defendants to immediately adjudicate Plaintiff’s pending immigrant visa application (ECF No. 1) be DENIED as moot; |
| Kind of order |
A magistrate judge's recommendation
Read by a model
These findings and recommendations are submitted to the United States district judge assigned to the case |
| Motion decided |
Motion to dismiss for lack of jurisdiction
Read by a model
Because it is jurisdictional, mootness can be raised through a Rule 12(b)(1) motion to dismiss. |
| Whose motion |
The government's motion
Read by a model
Defendant’s motion to dismiss Plaintiff’s complaint be GRANTED with leave to file a supplemental complaint; |
| Disposition |
Magistrate judge's recommendation
A magistrate judge's report and recommendation. The district judge decides whether to adopt it, so it is not counted as either side's win.
Read by a model
These findings and recommendations are submitted to the United States district judge assigned to the case |
| Prevailing party |
Neither side
Read by a model
These findings and recommendations are submitted to the United States district judge assigned to the case |
| The delay claim |
Moot: the agency acted
Read by a model
Plaintiff’s request that the court order Defendants to immediately adjudicate Plaintiff’s pending immigrant visa application (ECF No. 1) be DENIED as moot; |
| The other claims |
Not decided here
Read by a model
Nevertheless, the court is reluctant to foreclose Plaintiff from raising supplemental claims in response to the government’s post-complaint adjudication given the liberality of Rule 15(d). |
| Months pending |
30 months from the application to the suit; 31.9 months from the application to the agency's action
Read by a model
On June 18, 2025, the State Department issued a final adjudication of Plaintiff’s application. |
| TRAC factors | The court did not weigh the TRAC factors Read by a model |
| Threshold rulings |
APA adequate-remedy bar applied (mandamus claim fails); Held moot
Read by a model
As a threshold matter, Plaintiff’s dual avenues for relief—the Administrative Procedure Act (“APA”), 5 U.S.C. § 701, et seq., and the Mandamus Act, 28 U.S.C § 1361—cannot coexist here. |
| Nationality |
Iran
Read by a model
Plaintiff is an Iranian citizen. |
| 212(f) proclamation |
Proclamation 10949
Read by a model
(listing misapplication of Presidential Proclamation 10949, failure to apply the exemption to Plaintiff as the spouse of a United States citizen, and internal inconsistency). |
How the case ended
- Docket
- No. 1:25-cv-00466
- On the docket
- This ruling (ECF 36)
- Filed
- April 23, 2025
- Ended
- December 10, 2025
- Suit's filing to its end
- 231 days
- How it ended
- Ended, outcome not recorded
- From the record
- terminated; no disposition recorded
A voluntary or stipulated dismissal is how most suits end once the agency acts; the docket rarely says why.
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 Ninth 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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Allen v. Milas, 896 F.3d 1094
Ninth Circuit, July 24, 2018. The APA provides no avenue for review of a consular visa refusal beyond Mandel's facially-legitimate-and-bona-fide inquiry, and consular nonreviewability is not a jurisdictional bar.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 8 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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Sanchez Gonzalez v. United States Department of State, No. 23-4205 (9th Cir. Apr. 30, 2026)
Ninth Circuit, April 30, 2026. After Muñoz, a citizen spouse's own First Amendment interest triggered Mandel review, which a facially legitimate and bona fide reason satisfied absent a showing of bad faith.
ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-10-18; it checks for new citing decisions daily. That is not a determination that the case is good law.
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Independence Mining Co. v. Babbitt, 105 F.3d 502
Ninth Circuit, January 23, 1997. Mandamus and APA § 706(1) claims to compel delayed agency action are analyzed alike under the TRAC factors.
ImmCite: treatment available, history exists, not clearance
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Vaz v. Neal, 33 F.4th 1131
Ninth Circuit, May 9, 2022. Section 706(1) compels only a clear, mandatory and discrete duty that has been unreasonably delayed under TRAC, and the APA's prerequisites go to the merits while § 1331 supplies jurisdiction.
ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-11-10; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 145 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.