Passim

Mandamus decisions / District of Columbia

LIEW v. SANDERS

District of ColumbiaTrevor N. McFaddenDecided June 17, 2024No. 1:24-cv-00342

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.

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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
But after the interview, the U.S. Department of State refused her visa and placed her application into “administrative processing.”
Form or filing 221(g) (consular refusal); DS-260 (immigrant visa) Read by a model
confirming “Immigrant Visa Case Number: MTL2022740012” has been “Refused”
What the suit asked for Finish 221(g) processing Read by a model
Both claims challenge State’s alleged “failure to conclude the processing of [Liew’s] visa application within a reasonable time.”
Kind of order A ruling on a motion or the petition Read by a model
So the Court will grant State’s 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
State moved to dismiss the Complaint under Rules 12(b)(1) and 12(b)(6) of the Federal Rules of Civil Procedure.
Whose motion The government's motion Read by a model
State moved to dismiss the Complaint under Rules 12(b)(1) and 12(b)(6) of the Federal Rules of Civil Procedure.
Disposition Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model
So the Court will grant its Motion and dismiss the Complaint.
Prevailing party Government Read by a model
So the Court will grant its Motion and dismiss the Complaint.
The delay claim Dismissed Read by a model
So the Court will grant its Motion and dismiss the Complaint.
Months pending 10 months from the application to the court's decision Read by a model
The balance of the TRAC factors reveals the reasonableness of State’s alleged ten-month delay.
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 government
  • 4. Competing prioritiesfavors the government
  • 5. Interests prejudicedfavors the government
  • 6. No impropriety neededfavors the government
Read by a model
The first two factors “strongly favor” State because “Congress has not supplied a rule of reason” or “statutory deadline” for processing immigrant visa applications.
The government's delay arguments Line-jumping accepted Read by a model
The fourth factor “strongly disfavors” Liew because granting her application would condone judicial “line jumping” that puts her application “ahead of longer-pending petitions.”
Threshold rulings Consular nonreviewability applied; No duty to re-adjudicate a 221(g) refusal Read by a model
Second, the doctrine of consular nonreviewability forbids the Court from tinkering with State’s refusal decision.
Nationality Canada Read by a model
Liew is a Canadian citizen who resides in Waterloo, Ontario.
I-130 category Immediate relative Read by a model
Because Liew’s husband is a U.S. citizen, he sponsored her immigration application by filing a Form I-130 Petition with the U.S. Citizenship and Immigration Services.

How the case ended

Docket
No. 1:24-cv-00342
Filed
February 6, 2024
Ended
June 18, 2024
Suit's filing to its end
133 days
How it ended
Dismissed, ground not recorded
From the record
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.