Mandamus decisions / Western District of Texas

Edris v. Garland et al

Western District of TexasRichard B. FarrerDecided September 2, 2025No. 5:24-cv-01164

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 April 8, 2025, Defendants filed an advisory, informing the Court that the Department of State had issued the visa to Plaintiff Qasimi that formed the basis of Plaintiffs’ Petition, and the matter was now moot.
Form or filing	221(g) (consular refusal); I-130 (relative petition) Read by a model Plaintiffs were motivated to file the instant lawsuit after their Form I-130 had spent an allegedly prolonged period of time in administrative processing.
What the suit asked for	Decide the application Read by a model seeking action by Defendants on Plaintiff Akrami’s Form I-130 Petition for Alien Relative
Kind of order	A magistrate judge's recommendation Read by a model REPORT AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE
Motion decided	None Read by a model
Whose motion	The court on its own Read by a model “authorizes the district court to dismiss an action sua sponte for failure to prosecute or comply with a court order”
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 REPORT AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE
Prevailing party	Neither side Read by a model REPORT AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE
The delay claim	Dismissed Read by a model Dismissal is therefore warranted for want of prosecution and failure to follow a Court order.
Months pending	60.2 months from the application to the suit; 71 months from the application to the court's decision Read by a model Plaintiff Akrami’s Form I-130 Petition for Alien Relative, filed on behalf of his mother, Plaintiff Qasimi, on October 3, 2019.
TRAC factors	The court did not weigh the TRAC factors Read by a model
Threshold rulings	None Read by a model

Other orders in this case

The group holds 2 decisions from this suit, oldest first. Outcome counts on these pages count the case once, by its latest decision. How decisions are grouped into cases.

Decision	Decided	Judge	Disposition
Edris v. Garland et alThis decision	September 2, 2025	Richard B. Farrer	Magistrate judge's recommendation
Edris v. Garland et alThe case's latest decision: its outcome is the one counted	October 20, 2025	Orlando L. Garcia	Dismissed

How the case ended

Docket: No. 5:24-cv-01164
On the docket: This ruling (ECF 10)
Filed: October 7, 2024
Ended: October 20, 2025
Suit's filing to its end: 378 days
How it ended: Dismissed, ground not recorded
From the record: idb disp 14 (dismissed: other)

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 Fifth 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.

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
Centeno v. Shultz, 817 F.2d 1212

Fifth Circuit, June 1, 1987. Decisions of consular officers on visa applications are not reviewable by federal courts, and a denial under a ground that carries no waiver is subject to no review at all.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 6 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.
Cheejati v. Blinken, 106 F.4th 388

Fifth Circuit, July 5, 2024. The pace at which USCIS adjudicates adjustment applications during visa retrogression is a discretionary action under § 1255(a) that § 1252(a)(2)(B)(ii) shields from review, agreeing with the Eighth Circuit's Thigulla.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 7 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.
Mendoza-Tarango v. Flores, 982 F.3d 395

Fifth Circuit, December 8, 2020. A § 706(1) or mandamus claim requires a discrete, legally required action, and USCIS had no nondiscretionary duty to administer the naturalization oath at a prison.

ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-11-01; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 7 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.