Mandamus decisions / Western District of Washington

Chen v. United States Citizenship & Immigration Services

Western District of WashingtonDavid G. EstudilloDecided September 18, 2026No. 2:26-cv-01685

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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	USCIS Read by a model USCIS SHALL adjudicate Plaintiff’s naturalization application within 30 days of this order, and if approved, SHALL schedule Plaintiff’s naturalization ceremony immediately thereafter.
Form or filing	N-400 (naturalization) Read by a model USCIS SHALL adjudicate Plaintiff’s naturalization application within 30 days of this order, and if approved, SHALL schedule Plaintiff’s naturalization ceremony immediately thereafter.
What the suit asked for	Naturalization hearing or remand (1447(b)) Read by a model Under 8 U.S.C. § 1447(b), if United States Citizenship & Immigration Services (“USCIS”) has not adjudicated a naturalization application within 120 days of the applicant’s interview, then the applicant may apply to federal district court for a hearing.
Kind of order	A ruling on a motion or the petition Read by a model Plaintiff opposes remand, expressing concerns that remand will likely result in further administrative delay.
Motion decided	Remand under 1447(b) Read by a model This case comes before this Court on Defendants’ motion to remand.
Whose motion	The government's motion Read by a model This case comes before this Court on Defendants’ motion to remand.
Disposition	Remanded to the agency Sent back to the agency, with or without instructions. Read by a model It is hereby ORDERED that Defendants’ motion (Dkt. No. 9) is GRANTED and that this action is remanded to USCIS.
Prevailing party	Applicant Read by a model USCIS SHALL adjudicate Plaintiff’s naturalization application within 30 days of this order, and if approved, SHALL schedule Plaintiff’s naturalization ceremony immediately thereafter.
The delay claim	Remanded to the agency Read by a model It is hereby ORDERED that Defendants’ motion (Dkt. No. 9) is GRANTED and that this action is remanded to USCIS.
Months pending	Not stated A section 1447(b) suit: these months run from the naturalization application. The statute's 120 days run from the interview, which they do not measure. Read by a model
Months since the naturalization interview	18.9 months from the interview (2025-02-19) Read by a model Plaintiff Zhisong Chen’s naturalization interview took place on February 19, 2025.
TRAC factors	The court did not weigh the TRAC factors Read by a model
Threshold rulings	None Read by a model

How the case ended

Docket: No. 2:26-cv-01685
Filed: May 17, 2026
Ended: September 18, 2026
Suit's filing to its end: 124 days
How it ended: Remanded to the agency
From the record: remand order 2026-09-18

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 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 3, 2026. Check the current status before relying on one.

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
Yith v. Nielsen, 881 F.3d 1155

Ninth Circuit, February 7, 2018. The 'examination' that starts § 1447(b)'s 120-day clock is the interview, a notice to appear is not a warrant of arrest under § 1429, and USCIS fails to make a determination when it misses the deadline; the Sixth Circuit's Ebu disagrees in part.

ImmCite: caution, adverse or limiting treatment found. Rejected in the Sixth Circuit by Joseph Ebu v. USCIS, 134 F.4th 895 (2025).
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
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 2026-11-03; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 144 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.