Mandamus decisions / Northern District of Illinois

Jarrar v. Noem

Northern District of IllinoisSara Lee EllisDecided December 16, 2025No. 1:25-cv-05216

Read the decision Original 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	USCIS Read by a model Finally, the Court cannot agree with Jarrar that the Administrative Procedure Act (“APA”) authorizes the Court to compel USCIS to adjudicate his I-485 application.
Form or filing	I-485 (adjustment of status) Read by a model Jarrar then filed his I-485 application on July 22, 2022, which remains pending.
What the suit asked for	Decide the application Read by a model Jarrar alleges that the delay has caused him significant hardship, including uncertainty, employment limitations, and emotional distress, and therefore seeks to compel Defendants to adjudicate his I-485 application.
Kind of order	A ruling on a motion or the petition Read by a model The Court grants Defendants’ motion to dismiss [23].
Motion decided	Motion to dismiss for lack of jurisdiction Read by a model Defendants move to dismiss Jarrar’s complaint pursuant to Federal Rules of Civil Procedure 12(b)(1).
Whose motion	The government's motion Read by a model The Court grants Defendants’ motion to dismiss [23].
Disposition	Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model The Court dismisses Plaintiff Sayel Jarrar’s complaint without prejudice.
Prevailing party	Government Read by a model The Court grants Defendants’ motion to dismiss [23].
The delay claim	Dismissed Read by a model The Court therefore grants Defendants’ motion to dismiss and dismisses Jarrar’s claims without prejudice.
Months pending	33.7 months from the application to the suit; 40.8 months from the application to the court's decision Read by a model Jarrar then filed his I-485 application on July 22, 2022, which remains pending.
TRAC factors	The court did not weigh the TRAC factors Read by a model
Threshold rulings	Section 1252(a)(2)(B) bar applied Read by a model Jarrar argues, however, that the delay in adjudicating an I-485 application is not a “decision or action” and therefore does not fall under § 1252(a)(2)(B)(ii). The Court disagrees.
Nationality	Jordan Read by a model Jarrar is a citizen of Jordan

How the case ended

Docket: No. 1:25-cv-05216
On the docket: This ruling (ECF 31)
Filed: May 12, 2025
Ended: December 16, 2025
Suit's filing to its end: 218 days
How it ended: Dismissed on jurisdiction or the merits
From the record: idb disp 3 (dismissed: lack of jurisdiction)

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 Seventh 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.

Kucana v. Holder, 558 U.S. 233

Supreme Court, January 20, 2010. Section 1252(a)(2)(B)(ii) bars review only of decisions whose discretionary character is specified by statute, not discretion the agency gives itself by regulation.

ImmCite: treatment available, history exists, not clearance
Patel v. Garland, 596 U.S. 328

Supreme Court, May 16, 2022. Section 1252(a)(2)(B)(i) bars review of any judgment regarding the granting of the listed forms of relief, including the factual findings on which a denial of adjustment rests.

ImmCite: treatment available, history exists, not clearance
Bouarfa v. Mayorkas, 604 U.S. 6

Supreme Court, December 10, 2024. Revoking an approved visa petition under § 1155 is a discretionary decision or action that § 1252(a)(2)(B)(ii) places beyond judicial review.

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
Iddir v. INS, 301 F.3d 492

Seventh Circuit, August 6, 2002. INS had a nondiscretionary duty to adjudicate diversity-visa applications and § 1252(a)(2)(B)(ii) does not bar review of a failure to act, but no relief is available once the fiscal year ends.

ImmCite: caution, adverse or limiting treatment found. Questioned by Akash Shahi v. United States Department of S, 33 F.4th 927 (2022).
Calderon-Ramirez v. McCament, 877 F.3d 272

Seventh Circuit, December 5, 2017. USCIS must process U-visa petitions within a reasonable time, but neither mandamus nor the APA offers relief to an applicant who shows nothing setting him apart from those ahead of him in the oldest-first queue.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 3 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.
Pak v. Biden, 91 F.4th 896

Seventh Circuit, January 31, 2024. Consular nonreviewability bars a systemic challenge to how terrorism-related inadmissibility exemptions are considered, a matter the statute commits to the Secretaries' sole unreviewable discretion, and a statutory citation with a facial link to the record satisfies Mandel.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 2 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.
Shahi v. United States Department of State, 33 F.4th 927

Seventh Circuit, May 6, 2022. Courts cannot order a diversity visa issued after the fiscal year ends whatever relief is requested, because the statute ends eligibility, and the Mandamus Act supplies a remedy rather than jurisdiction.

ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-10-29; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 10 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.