Passim

Mandamus decisions / District of Columbia

LIU v. RUBIO

District of ColumbiaChristopher R. CooperDecided November 4, 2026No. 1:25-cv-04465

Read the decisionOriginal on CourtListener

2,948 written decisions from 2,691 cases in the whole mandamus and agency-delay group, the group's newest decided November 10, 2026. Updated November 11, 2026 at 1:21 p.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 1,632 public decisions since January 1, 2025 that a CourtListener and GovInfo search for mandamus and agency delay finds, Passim holds 1,398 (86%), measured November 11, 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
Nearly six months later, the State Department had yet to provide any substantive updates.
Form or filing 221(g) (consular refusal); DS-160 (nonimmigrant visa) Read by a model
On May 24, 2025, he filed a DS-160 application to renew his F-1 nonimmigrant visa.
What the suit asked for Finish 221(g) processing Read by a model
Liu requests that the Court issue a writ of mandamus under 28 U.S.C. § 1361 compelling Defendants to adjudicate the visa application within 14 days or as soon as practicable and declare that Defendants’ delay in processing the application violates the APA, INA, and ISIIA.
Kind of order A ruling on a motion or the petition Read by a model
Because Liu fails to identify a discrete action that the agency must take, the Court will grant the government’s motion and dismiss this case.
Motion decided Motion to dismiss for failure to state a claim Read by a model
Defendants move to dismiss for lack of subject matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1) and failure to state a claim under Rule 12(b)(6).
Whose motion The government's motion Read by a model
Defendants move to dismiss for lack of subject matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1) and failure to state a claim under Rule 12(b)(6).
Disposition Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model
Accordingly, the Court will dismiss his complaint.
Prevailing party Government Read by a model
Because Liu has not identified a discrete agency action that the government is required to take, he has failed to state a claim upon which relief can be granted.
The delay claim Dismissed Read by a model
Because Liu has not identified a discrete agency action that the government is required to take, he has failed to state a claim upon which relief can be granted.4 Accordingly, the Court will dismiss his complaint.
Months pending 6.7 months from the application to the suit; 17.4 months from the application to the court's decision Read by a model
On May 24, 2025, he filed a DS-160 application to renew his F-1 nonimmigrant visa.
TRAC factors The court weighed the TRAC factors
  • 1. Rule of reasonfavors the government
  • 2. Congressional timetablenot reached
  • 3. Human health and welfarefavors the applicant
  • 4. Competing prioritiesnot reached
  • 5. Interests prejudicedfavors the applicant
  • 6. No impropriety neededfavors the government
Read by a model
And, most importantly, the delay here does not rise to the level of unreasonableness, even viewing that delay on “the longest possible timeline.”
Threshold rulings No duty to re-adjudicate a 221(g) refusal Read by a model
The Court thus concludes that the APA creates no non-discretionary duty to act on Liu’s “refused” application.
Nationality China Read by a model
Zhilin Liu, a Chinese citizen, applied for an F-1 nonimmigrant visa.

How the case ended

Docket
No. 1:25-cv-04465
Filed
December 22, 2025
Ended
November 4, 2026
Suit's filing to its end
317 days
How it ended
Dismissed on jurisdiction or the merits
From the record
order 2026-11-04 for the defendants, ground not stated

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 D.C. 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 11, 2026. Check the current status before relying on one.