Passim

Mandamus decisions / District of Columbia

TEHRAN v. RUBIO

District of ColumbiaJia M. CobbDecided December 11, 2025No. 1:25-cv-01584

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
On October 17, 2023, the U.S. Embassy and Consulate in Ankara, Turkey interviewed both applicants.
Form or filing 221(g) (consular refusal); DS-260 (immigrant visa) Read by a model
Saloomeh Tehran sues alongside her parents Afsaneh Molaei and Mohammad Memarzadeh Tehran (collectively, Plaintiffs), seeking to compel the adjudication of her parents’ immigration visa applications.
What the suit asked for Finish 221(g) processing Read by a model
Plaintiffs contend that the applications at issue have been stuck in administrative processing for years and thus have been unreasonably delayed in violation of the Administrative Procedure Act (APA) and the Mandamus Act.
Kind of order A ruling on a motion or the petition Read by a model
Accordingly, the Court will GRANT Defendants’ motion to dismiss.
Motion decided Motion to dismiss for failure to state a claim Read by a model
The Court resolves the pending motion under Rule 12(b)(6).
Whose motion The government's motion Read by a model
Defendants have moved to dismiss Plaintiffs’ claims on various grounds.
Disposition Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model
Plaintiffs’ complaint is DISMISSED.
Prevailing party Government Read by a model
Accordingly, the Court finds that Plaintiffs have failed to state a claim for unreasonable delay and grants Defendants’ motion to dismiss under Rule 12(b)(6).
The delay claim Dismissed Read by a model
Accordingly, the Court finds that Plaintiffs have failed to state a claim for unreasonable delay and grants Defendants’ motion to dismiss under Rule 12(b)(6).
Months pending 19 months from the application to the suit; 25.8 months from the application to the court's decision Read by a model
On October 17, 2023, the U.S. Embassy and Consulate in Ankara, Turkey interviewed both applicants.
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 neededneutral
Read by a model
As such, these factors weigh in favor of Defendants.
The government's delay arguments Line-jumping accepted Read by a model
Because Plaintiffs’ request for relief would require the Court to take charge of the consulate’s priority-setting, ordering the agency to redistribute its resources and prioritize Plaintiffs’ applications, the fourth TRAC factor weighs in favor of Defendants.
Threshold rulings Consular nonreviewability rejected; Duty to re-adjudicate a 221(g) refusal found Read by a model
The consular nonreviewability doctrine does not apply here because Plaintiffs’ claims are based on Defendants’ failure to render a decision on their applications; Plaintiffs do not seek judicial review of any consular officer’s final determination.

How the case ended

Docket
No. 1:25-cv-01584
Filed
May 16, 2025
Ended
December 11, 2025
Suit's filing to its end
209 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.