Mandamus decisions / District of Columbia
SORBI v. RUBIO et al
Read the decisionOriginal on GovInfo
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
In May 2026, after the motion to dismiss Mrs. Sorbi’s complaint was fully briefed,4 the U.S. Embassy issued a Refusal Worksheet to Mr. Kalantarikhandani. |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-260 (immigrant visa)
Read by a model
In early 2023, Plaintiff Parisa Sorbi filed an IR-1 immigrant visa petition on behalf of her Iranian husband, Amirbahman Kalantarikhandani, as the pair sought to “begin [their] life together in the United States.” |
| What the suit asked for |
Finish 221(g) processing
Read by a model
When she filed this lawsuit in July 2025, Mrs. Sorbi sought to compel a final adjudication of her husband’s visa application, which had been placed in administrative processing following a refusal under INA § 221(g). |
| Kind of order |
A ruling on a motion or the petition
Read by a model
For the foregoing reasons, the Court GRANTS Defendants’ motion to dismiss (ECF Nos. 21, 31); |
| Motion decided |
Motion to dismiss for lack of jurisdiction
Read by a model
For the foregoing reasons, the Court GRANTS Defendants’ motion to dismiss (ECF Nos. 21, 31); |
| Whose motion |
Cross-motions
Read by a model
For the foregoing reasons, the Court GRANTS Defendants’ motion to dismiss (ECF Nos. 21, 31); DENIES Plaintiff’s motion for leave to file an amended complaint (ECF Nos. 30, 32– 37); |
| Disposition |
Dismissed
The case or every delay claim was dismissed for a reason other than mootness.
Read by a model
This Court joins that growing consensus in concluding that Mrs. Sorbi’s unreasonable-delay claims are now moot, warranting dismissal of her complaint. |
| Prevailing party |
Government
Read by a model
This Court joins that growing consensus in concluding that Mrs. Sorbi’s unreasonable-delay claims are now moot, warranting dismissal of her complaint. |
| The delay claim |
Moot: the agency acted
Read by a model
This Court joins that growing consensus in concluding that Mrs. Sorbi’s unreasonable-delay claims are now moot, warranting dismissal of her complaint. |
| The other claims |
Dismissed
Read by a model
For this reason, Mrs. Sorbi’s claims concerning the consular officer’s refusal would not survive a motion to dismiss and her requests to amend the complaint are therefore futile. |
| Months pending |
14 months from the application to the suit; 24 months from the application to the agency's action
Read by a model
The refusal notice Mr. Kalantarikhandani received in May 2026 expressly informed him that a consular officer had deemed him ineligible for a visa under § 212(f), that this decision could not be appealed, and that an NIE would not be granted in his case. |
| TRAC factors | The court did not weigh the TRAC factors Read by a model |
| Threshold rulings |
Consular nonreviewability applied; Held moot
Read by a model
Although the Court construes Mrs. Sorbi’s recent filings as a motion for leave to amend her complaint to challenge the § 212(f) refusal, those proposed claims are futile because they are barred by the doctrine of consular nonreviewability. |
| Nationality |
Iran
Read by a model
Plaintiff Parisa Sorbi is an American citizen who petitioned for an Immediate Relative (“IR-1”) visa on behalf of her Iranian husband, Amirbahman Kalantarikhandani. |
| 212(f) proclamation |
Proclamation 10998
Read by a model
a consular officer found [him] ineligible for an immigrant visa under Section 212(f) of the Immigration and Nationality Act, pursuant to Presidential Proclamation 10998. |
| I-130 category |
Immediate relative
Read by a model
Plaintiff Parisa Sorbi is an American citizen who petitioned for an Immediate Relative (“IR-1”) visa on behalf of her Iranian husband, Amirbahman Kalantarikhandani. |
How the case ended
- Docket
- No. 1:25-cv-02353
- Filed
- July 13, 2025
- Ended
- August 24, 2026
- Suit's filing to its end
- 407 days
- How it ended
- Ended once the agency acted
- 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. Other suits in this court.
Supreme Court and D.C. 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.
-
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
-
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
-
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
-
Saavedra Bruno v. Albright, 197 F.3d 1153
D.C. Circuit, December 3, 1999. Consular visa decisions are not subject to judicial review absent an express statutory grant, and the APA does not displace that doctrine.
ImmCite: treatment available, history exists, not clearance
-
Baan Rao Thai Restaurant v. Pompeo, 985 F.3d 1020
D.C. Circuit, January 22, 2021. Consular nonreviewability bars a federal court from second-guessing a consular officer's decision to issue or withhold a visa, and dismissal on that ground is a merits ruling rather than a jurisdictional one.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 3 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.
-
Pietersen v. Department of State, 138 F.4th 552
D.C. Circuit, May 30, 2025. Consular nonreviewability does not bar a forward-looking APA challenge to generally applicable State Department guidance, as distinct from review of an individual visa refusal.
ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-11-03; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 24 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.
-
Telecommunications Research & Action Center v. FCC, 750 F.2d 70
D.C. Circuit, October 24, 1984. Whether agency delay is unreasonable turns on six factors: a rule of reason, any statutory timetable, the human welfare interests at stake, the effect of expediting on competing priorities, the interests prejudiced by delay, and no need to find impropriety.
ImmCite: treatment available, history exists, not clearance
-
Mashpee Wampanoag Tribal Council, Inc. v. Norton, 336 F.3d 1094
D.C. Circuit, August 8, 2003. A claim that an agency has unreasonably delayed a matter arises under the APA and § 1331, and the TRAC factors decide whether the delay is unreasonable.
ImmCite: treatment available, history exists, not clearance
-
Karimova v. Abate, No. 23-5178 (D.C. Cir. July 24, 2024) (unpublished judgment)
D.C. Circuit, July 24, 2024, nonprecedential. Neither § 555(b) nor any other law imposes a clear, nondiscretionary duty on a consular officer to re-adjudicate a visa application that was officially refused under § 1201(g) and placed in administrative processing, so mandamus and § 706(1) relief are unavailable.
ImmCite: not applicable, outside the precedential ImmCite corpus