Mandamus decisions / District of Columbia
GONA v. UNITED STATES CITIZENSHIP AND IMMIGRATION SERVICES
Read the decisionOriginal on CourtListener
2,914 written decisions from 2,661 cases in the whole mandamus and agency-delay group, the group's newest decided October 30, 2026. Updated November 3, 2026 at 1:24 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 1,606 public decisions since January 1, 2025 that a CourtListener and GovInfo search for mandamus and agency delay finds, Passim holds 1,371 (85%), measured November 3, 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
USCIS has not yet acted on those applications. |
|---|---|
| Form or filing |
I-539 (change or extension of stay); I-765 (EAD)
Read by a model
See id. (Form I-765 to extend work authorization); 8 C.F.R. § 214.2(h)(9)(iv) (Form I-539 to extend visa). |
| What the suit asked for |
Issue a work permit
Read by a model
She alleges that the agency unreasonably delayed acting on her applications and improperly denied an automatic extension of her authorization to work. She now seeks a preliminary injunction to force the agency to process her applications within seven days. |
| Kind of order |
A ruling on a motion or the petition
Read by a model
Upon consideration of the motion, briefs (ECF Nos. 7-1, 11, 12), exhibits (ECF Nos. 7-2– 17, 11-1–2, 12-1), and all other papers of record, the Court will DENY the motion. |
| Motion decided |
Preliminary injunction or TRO
Read by a model
Eight weeks after she filed her complaint, Ms. Gona moved for a preliminary injunction to compel USCIS to promptly adjudicate her applications. |
| Whose motion |
The plaintiff's motion
Read by a model
Eight weeks after she filed her complaint, Ms. Gona moved for a preliminary injunction to compel USCIS to promptly adjudicate her applications. |
| Disposition |
Denied in the government's favor
The principal motion was denied in full: a motion to dismiss denied so the case goes on, or relief denied on the merits.
Read by a model
Based on the foregoing, the Court will deny the motion by separate order. |
| Prevailing party |
Government
Read by a model
Based on the foregoing, the Court will deny the motion by separate order. |
| The delay claim |
Relief denied
Read by a model
Based on the foregoing, the Court will deny the motion by separate order. |
| The other claims |
Not decided here
Read by a model
Because Ms. Gona does not address her § 274a.13(d) claim in her preliminary injunction filings, the Court construes her motion for a preliminary injunction as seeking only an order pertaining to her unreasonable delay claim. |
| Months pending |
7.6 months from the application to the court's decision
Read by a model
On July 9, 2020, she filed applications to renew both her visa and her employment authorization. |
| TRAC factors |
The court weighed the TRAC factors
The first factor, therefore, supports USCIS. |
| The government's delay arguments |
First-in, first-out processing accepted; Line-jumping accepted
Read by a model
In sum, Ms. Gona has not disproven the agency’s assertion that it follows a first-in, firstout process. The first factor, therefore, supports USCIS. |
| Threshold rulings | None Read by a model |
| Nationality |
India
Read by a model
Ms. Gona is an Indian national who lives in Rockville, Maryland. |
How the case ended
- Docket
- No. 1:20-cv-03680
- Filed
- December 15, 2020
- Ended
- April 27, 2021
- Suit's filing to its end
- 133 days
- How it ended
- Dismissed, ground not recorded
- From the record
- idb disp 2 (dismissed: want of prosecution)
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 3, 2026. Check the current status before relying on one.
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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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Telecommunications Research & Action Center v. FCC, 750 F.2d 70
D.C. Circuit, October 24, 1984. Whether agency delay is unreasonable turns on six factors: a rule of reason, any statutory timetable, the human welfare interests at stake, the effect of expediting on competing priorities, the interests prejudiced by delay, and no need to find impropriety.
ImmCite: treatment available, history exists, not clearance
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Mashpee Wampanoag Tribal Council, Inc. v. Norton, 336 F.3d 1094
D.C. Circuit, August 8, 2003. A claim that an agency has unreasonably delayed a matter arises under the APA and § 1331, and the TRAC factors decide whether the delay is unreasonable.
ImmCite: treatment available, history exists, not clearance
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In re Core Communications, Inc., 531 F.3d 849
D.C. Circuit, July 8, 2008. Mandamus to compel unreasonably delayed agency action is an extraordinary remedy guided by the TRAC factors, granted here after years of unexplained delay.
ImmCite: treatment available, history exists, not clearance
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Da Costa v. Immigration Investor Program Office, 80 F.4th 330
D.C. Circuit, August 18, 2023. EB-5 petition delays of roughly four years were not unreasonable under TRAC where USCIS adjudicates in a rule-of-reason order and expediting the plaintiffs would only move them ahead of others in the queue.
ImmCite: treatment available, history exists, not clearance
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American Hospital Ass'n v. Burwell, 812 F.3d 183
D.C. Circuit, February 9, 2016. A delay claim under the Mandamus Act requires a clear duty, a clear right and no adequate alternative remedy, and the TRAC factors then decide whether the delay warrants relief, with a statutory deadline weighing heavily.
ImmCite: treatment available, history exists, not clearance
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Afghan and Iraqi Allies v. Blinken, 103 F.4th 807
D.C. Circuit, June 7, 2024. TRAC governs visa-processing delay claims in district court, a court that finds unreasonable delay may set adjudication deadlines, and expediting a whole class in queue order is not line-jumping.
ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-10-28; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 49 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.