Passim

Mandamus decisions / District of Columbia

Bonafos De Belinay v. Mayorkas

District of ColumbiaChristopher R. CooperDecided March 3, 2025No. 1:24-cv-00240

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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
Following the interview, the Embassy informed Plaintiff that his application had been placed into administrative processing, leaving his case stalled with no clear timeline for resolution.
Form or filing 221(g) (consular refusal); DS-160 (nonimmigrant visa) Read by a model
Plaintiff Hubert de Bonafos de Belinay, a French citizen, brings this action to compel several government agencies to adjudicate his nonimmigrant visa application.
What the suit asked for Finish 221(g) processing Read by a model
As already explained, Plaintiff does not challenge the government’s decision to admit, exclude, or deny his petition, but rather argues that the government has unreasonably delayed its completion of administrative processing.
Kind of order A ruling on a motion or the petition Read by a model
It is further ORDERED that [12] Defendants’ Motion to Dismiss is otherwise DENIED.
Motion decided Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim Read by a model
The defendants have moved to dismiss the complaint 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
The defendants have moved to dismiss the complaint 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 in part; some claims go on The government's motion to dismiss was granted in part: some claims were dismissed and others go on. Read by a model
the Court will dismiss Plaintiff’s unreasonable delay claim for failure to state a claim.
Prevailing party Each side in part Read by a model
the Court will dismiss Plaintiff’s unreasonable delay claim for failure to state a claim.
The delay claim Dismissed Read by a model
the Court will dismiss Plaintiff’s unreasonable delay claim for failure to state a claim.
The other claims The delay claim goes on Read by a model
Because the government does not argue that Plaintiff failed to state a claim for procedural or substantive due process, the Court will decline to do the government’s work for it and will allow that claim to proceed.
Months pending 2 months from the application to the suit; 15.6 months from the application to the court's decision Read by a model
The now 16-month delay in processing Plaintiff’s application since his November 2023 interview falls comfortably within the range that courts in this district have held not to be unreasonable.
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 neededneutral
Read by a model
Factors one, two, and four favor the defendants
The government's delay arguments Line-jumping accepted Read by a model
but he cannot escape the reality that “[c]onsular processing capacity is presently a zero-sum game, so granting [Plaintiff] relief would necessarily mean additional delays for other applicants—many of whom undoubtedly face hardships of their own.”
Threshold rulings Consular nonreviewability rejected Read by a model
In this context, consular nonreviewability has no application and does not bar the Court’s review.
Nationality France Read by a model
Hubert de Bonafos de Belinay, a citizen of France, resides in Paris with his family.

How the case ended

Docket
No. 1:24-cv-00240
Filed
January 26, 2024
Ended
March 11, 2025
Suit's filing to its end
410 days
How it ended
Ended once the agency acted
From the record
idb disp 12 (dismissed: voluntarily)

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.