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Mandamus decisions / District of Columbia

Sawahreh v. United States Department of State

District of ColumbiaJames E. BoasbergDecided September 21, 2022No. 1:22-cv-01456

Read the decisionOriginal on CourtListener

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What the decision decided

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Agency Department of State Read by a model
Turning to those merits now,the Court understands that the thrust of Sawahreh’s suit is his allegation that the State Department has unreasonably delayed the adjudication of his application for a J-1 visa, which has remained in administrative processing for more than fifteen months.
Form or filing 221(g) (consular refusal); DS-160 (nonimmigrant visa) Read by a model
Sawahreh submitted a Form DS-160 on April 20, 2021.
What the suit asked for Finish 221(g) processing Read by a model
He argues that “Defendants should complete processing of his J-1 visa application before the later-filed applications they appear to be prioritizing.”
Kind of order A ruling on a motion or the petition Read by a model
For the foregoing reasons, the Court will grant Defendants’ Motion to Dismiss.
Motion decided Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim Read by a model
As the Court resolves this case without addressing Plaintiff’s Cross-Motion, it sets out only the standards for Defendants’ Motion to Dismiss ,which invokes Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6).
Whose motion The government's motion Read by a model
As the Court resolves this case without addressing Plaintiff’s Cross-Motion, it sets out only the standards for Defendants’ Motion to Dismiss
Disposition Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model
For the foregoing reasons, the Court will grant Defendants’ Motion to Dismiss.
Prevailing party Government Read by a model
For the foregoing reasons, the Court will grant Defendants’ Motion to Dismiss.
The delay claim Dismissed Read by a model
For the foregoing reasons, the Court will grant Defendants’ Motion to Dismiss.
Months pending 11.1 months from the application to the suit; 17.1 months from the application to the court's decision Read by a model
Sawahreh submitted a Form DS-160 on April 20, 2021.
TRAC factors The court weighed the TRAC factors
  • 1. Rule of reasonfavors the government
  • 2. Congressional timetablefavors the government
  • 3. Human health and welfarefavors the applicant
  • 4. Competing prioritiesfavors the government
  • 5. Interests prejudicedfavors the applicant
  • 6. No impropriety neededfavors the government
Read by a model
The first two TRAC factors favor Defendants .
The government's delay arguments Line-jumping accepted Read by a model
The fourth factor examines “the effect of expediting delayed action on agency activities of a higher or competing priority,” TRAC , 750 F.2d at 80, and “ carries the greatest weight in many cases.” Milligan I , 502 F. Supp. 3d at 319. It does so here as well and favors Defendants.
Threshold rulings Consular nonreviewability rejected Read by a model
the doctrine of consular non- reviewability is “inapplicable to this claim, as Plaintiff[] do[es] not seek review of any decision but instead of ‘the Government's failure to decide.’”
Nationality Jordan Read by a model
Sawahr eh is a Jordanian citizen residing in Qatar and a licensed medical doctor.

How the case ended

Docket
No. 1:22-cv-01456
Filed
May 24, 2022
Ended
September 21, 2022
Suit's filing to its end
120 days
How it ended
Dismissed on jurisdiction or the merits
From the record
idb disp 6 (judgment: motion before trial), judgment for defendant

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.