Mandamus decisions / Western District of New York
Chowdhury v. United States Department of State
Read the decisionOriginal on CourtListener
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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
First, she alleges that the failure of the U.S. Embassy in Dhaka to make a final determination of her husband’s I-130 immigrant visa application constitutes an unlawfully withheld or unreasonably delayed agency action under the Administrative Procedure Act. |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-260 (immigrant visa)
Read by a model
First, she alleges that the failure of the U.S. Embassy in Dhaka to make a final determination of her husband’s I-130 immigrant visa application constitutes an unlawfully withheld or unreasonably delayed agency action under the Administrative Procedure Act. |
| What the suit asked for |
Finish 221(g) processing
Read by a model
She also seeks three writs of mandamus to compel Defendants: (1) “to promptly complete all administrative processing within sixty days;” |
| Kind of order |
A ruling on a motion or the petition
Read by a model
For the foregoing reasons, Defendants’ motion to dismiss is granted. |
| Motion decided |
Motion to dismiss for lack of jurisdiction
Read by a model
As a result, it is proper for this Court to construe Defendants’ motion as one under Rule 12(b)(1). |
| Whose motion |
The government's motion
Read by a model
Defendants have moved to dismiss Plaintiffs claims. |
| Disposition |
Dismissed
The case or every delay claim was dismissed for a reason other than mootness.
Read by a model
Plaintiff's case is moot because she has, in fact, received a final decision on her husband’s visa application. |
| Prevailing party |
Government
Read by a model
Plaintiff's case is moot because she has, in fact, received a final decision on her husband’s visa application. |
| The delay claim |
Moot: the agency acted
Read by a model
Plaintiff's case is moot because she has, in fact, received a final decision on her husband’s visa application. |
| The other claims |
Dismissed
Read by a model
Plaintiff lacks standing to bring her due process claim because she did not list her husband as a plaintiff. |
| Months pending |
0 months from the application to the agency's action
Read by a model
May 19, 2025. Id. at 4 J{ 15-16. Following the interview, his application was Case 1:25-cv-01174-JLS Document9 _ Filed 05/14/26 Page 4of9 placed in “administrative processing.” |
| TRAC factors | The court did not weigh the TRAC factors Read by a model |
| Threshold rulings |
Held moot
Read by a model
Plaintiff's case is moot because she has, in fact, received a final decision on her husband’s visa application. |
| Nationality |
Bangladesh
Read by a model
her husband, Md Rubel Ahmed, is a citizen of Bangladesh. |
| I-130 category |
Immediate relative
Read by a model
Plaintiff Jannat Chowdhury is a U.S. citizen, and her husband, Md Rubel Ahmed, is a citizen of Bangladesh. |
How the case ended
- Docket
- No. 1:25-cv-01174
- Filed
- November 13, 2025
- Ended
- May 14, 2026
- Suit's filing to its end
- 182 days
- How it ended
- Ended once the agency acted
- 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.
Supreme Court and Second 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.
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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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American Academy of Religion v. Napolitano, 573 F.3d 115
Second Circuit, July 17, 2009. Where a visa refusal implicates U.S. citizens' First Amendment rights, Mandel review applies: the government must identify a properly construed statutory ground and the officer's reason to believe it applies, and the applicant must have a chance to rebut a knowing material-support charge.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 4 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.
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Chen v. Rubio, 158 F.4th 393
Second Circuit, October 29, 2025. After Muñoz, consular nonreviewability insulates relatives' visa refusals from a citizen sponsor's challenge, and the claims were properly dismissed with prejudice.
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 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.