Mandamus decisions / Western District of Washington

Manjunath v. Rubio

Western District of WashingtonRicardo S. MartinezDecided October 2, 2026No. 2:26-cv-01277

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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	Department of State Read by a model Plaintiff Manjunath applied for his visa in India and the State Department refused his application in India.
Form or filing	DS-160 (nonimmigrant visa) Read by a model A U.S. consular officer in India adjudicated and refused Manjunath’s nonimmigrant visa application in October 2025.
What the suit asked for	Some other action Read by a model Plaintiffs seek to compel Defendants to re-adjudicate this visa application under the Mandamus Act and the Administrative Procedure Act.
Kind of order	A transfer order Read by a model Accordingly, Plaintiffs have failed to establish that venue is proper in this district and the Court will dismiss this case under Rule 12(b)(3).
Motion decided	Other motion to dismiss Read by a model Defendants move to dismiss for improper venue under Rule 12(b)(3).
Whose motion	The government's motion Read by a model This matter comes before the Court on Defendants’ Motion to Dismiss, Dkt. #5.
Disposition	Transferred to another court An order moving the case to another court. It decides where the suit is heard, not who wins, so it is not counted as either side's win. Read by a model Accordingly, Plaintiffs have failed to establish that venue is proper in this district and the Court will dismiss this case under Rule 12(b)(3).
Prevailing party	Neither side Read by a model Accordingly, Plaintiffs have failed to establish that venue is proper in this district and the Court will dismiss this case under Rule 12(b)(3).
The delay claim	Dismissed Read by a model Plaintiffs’ claims are DISMISSED without prejudice to refile in the proper venue.
Months pending	Not stated Read by a model
TRAC factors	The court did not weigh the TRAC factors Read by a model
Threshold rulings	None Read by a model
Nationality	India Read by a model Plaintiffs Dilip Sagar Manjunath and Akshatha Chickamagalur Pramodkumar are Indian national who currently reside in India.

How the case ended

Docket: No. 2:26-cv-01277
Filed: April 14, 2026
Ended: October 2, 2026
Suit's filing to its end: 171 days
How it ended: Ended, outcome not recorded
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 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.

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
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
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
Allen v. Milas, 896 F.3d 1094

Ninth Circuit, July 24, 2018. The APA provides no avenue for review of a consular visa refusal beyond Mandel's facially-legitimate-and-bona-fide inquiry, and consular nonreviewability is not a jurisdictional bar.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 8 published decisions citing this case, as of 2026-10-31; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
Sanchez Gonzalez v. United States Department of State, No. 23-4205 (9th Cir. Apr. 30, 2026)

Ninth Circuit, April 30, 2026. After Muñoz, a citizen spouse's own First Amendment interest triggered Mandel review, which a facially legitimate and bona fide reason satisfied absent a showing of bad faith.

ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-10-18; it checks for new citing decisions daily. That is not a determination that the case is good law.
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.