Mandamus decisions / District of Columbia
RAHIMIAN v. BLINKEN
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 |
Department of State
Read by a model
For the application process to proceed, the State Department must schedule a consular interview, after which a consular officer will issue or refuse the visa. |
|---|---|
| Form or filing |
DS-260 (immigrant visa)
Read by a model
First, the State Department website describes the backlog of immigrant visa applications worldwide and the 377,953 applicant interviews still pending scheduling after all December 2022 interview slots were taken. |
| What the suit asked for |
Decide the application
Read by a model
On March 23, 2022, plaintiff filed this case “to compel the [d]efendants to take action on and adjudicate his wife’s [] visa application.” |
| Kind of order |
A ruling on a motion or the petition
Read by a model
For the reasons given, defendants’ motion to dismiss is granted. |
| Motion decided |
Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim
Read by a model
Defendants provide three reasons for dismissal under Rule 12(b)(1) and (6): |
| Whose motion |
The government's motion
Read by a model
Defendants thereafter moved to dismiss the complaint under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). |
| Disposition |
Dismissed
The case or every delay claim was dismissed for a reason other than mootness.
Read by a model
For the reasons given, defendants’ motion to dismiss is granted. |
| Prevailing party |
Government
Read by a model
For the reasons given, defendants’ motion to dismiss is granted. |
| The delay claim |
Dismissed
Read by a model
The Alleged Delay in Decision on Plaintiff’s Application Is Not Unreasonable, Requiring Dismissal of Claims for Failure to State a Claim |
| The other claims |
Dismissed
Read by a model
Given the absence of any factual predicate, defendants’ motion to dismiss the CARRP claim is granted. |
| Months pending |
Not stated at filing
The agency acted before this decision, so the months up to the decision are not a delay and are not shown.
Read by a model
Accordingly, the forty-one-month delay in this case is not long enough to tilt the first two TRAC factors in favor of plaintiff. |
| TRAC factors |
The court weighed the TRAC factors
Given this backlog and ongoing public health considerations impacting consular staff operations, the first two TRAC factors weigh decisively in defendants’ favor. |
| The government's delay arguments |
Line-jumping accepted
Read by a model
Accordingly, deference must be given to the State Department’s priority-setting and resource-allocation decisions. |
| Threshold rulings |
Held moot
Read by a model
Plaintiff’s claims against officials from the Department of Homeland Security and USCIS are moot. |
| I-130 category |
Immediate relative
Read by a model
Plaintiff Yousof Rahimian, a U.S. citizen, seeks to compel defendants—various federal officials in their official capacities—to adjudicate his wife’s visa application, which has been pending without decision for over three years. |
How the case ended
- Docket
- No. 1:22-cv-00785
- Filed
- March 22, 2022
- Ended
- January 10, 2023
- Suit's filing to its end
- 294 days
- How it ended
- Dismissed on jurisdiction or the merits
- From the record
- order 2023-01-10 for the defendants, ground not stated; idb disp 14 (dismissed: other)
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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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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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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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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Saavedra Bruno v. Albright, 197 F.3d 1153
D.C. Circuit, December 3, 1999. Consular visa decisions are not subject to judicial review absent an express statutory grant, and the APA does not displace that doctrine.
ImmCite: treatment available, history exists, not clearance
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Baan Rao Thai Restaurant v. Pompeo, 985 F.3d 1020
D.C. Circuit, January 22, 2021. Consular nonreviewability bars a federal court from second-guessing a consular officer's decision to issue or withhold a visa, and dismissal on that ground is a merits ruling rather than a jurisdictional one.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 3 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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Pietersen v. Department of State, 138 F.4th 552
D.C. Circuit, May 30, 2025. Consular nonreviewability does not bar a forward-looking APA challenge to generally applicable State Department guidance, as distinct from review of an individual visa refusal.
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 24 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.
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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