Mandamus decisions / District of Columbia

Salha v. U.S. Department of Homeland Security

District of ColumbiaKetanji Brown JacksonDecided September 11, 2020No. 1:20-cv-01102

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2,996 written decisions from 2,731 cases in the whole mandamus and agency-delay group, the group's newest decided November 12, 2026. Updated November 14, 2026 at 1:17 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 1,617 public decisions since January 1, 2025 that a CourtListener and GovInfo search for mandamus and agency delay finds, Passim holds 1,406 (87%), 1,039 of them in this group, measured November 14, 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	National Visa Center Read by a model his visa application is currently pending at the National Visa Center, which happens to be located in New Hampshire.
Form or filing	I-130 (relative petition) Read by a model seeking to compel Defendants to adjudicate the I-130 visa application that Salha filed on behalf of his spouse.
What the suit asked for	Decide the application Read by a model seeking to compel Defendants to adjudicate the I-130 visa application that Salha filed on behalf of his spouse.
Kind of order	A transfer order Read by a model it is hereby ORDERED that Defendants’ Motion to Transfer, ECF No. 7, is DENIED.
Motion decided	Transfer Read by a model it is hereby ORDERED that Defendants’ Motion to Transfer, ECF No. 7, is DENIED.
Whose motion	The government's motion Read by a model it is hereby ORDERED that Defendants’ Motion to Transfer, ECF No. 7, is DENIED.
Disposition	Transferred to another court An order moving the case to another court. It decides where the suit is heard, not who wins, so it is not counted as either side's win. Read by a model it is hereby ORDERED that Defendants’ Motion to Transfer, ECF No. 7, is DENIED.
Prevailing party	Neither side Read by a model it is hereby ORDERED that Defendants’ Motion to Transfer, ECF No. 7, is DENIED.
The delay claim	Not decided here Read by a model it is hereby ORDERED that Defendants’ Motion to Transfer, ECF No. 7, is DENIED.
The other claims	Not decided here Read by a model this disagreement pertains to the merits of Salha’s claims, which are not relevant at this stage of the proceedings.
Months pending	Not stated Read by a model
TRAC factors	The court did not weigh the TRAC factors Read by a model
Threshold rulings	None Read by a model

How the case ended

Docket: No. 1:20-cv-01102
Filed: April 28, 2020
Ended: October 1, 2020
Suit's filing to its end: 156 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 14, 2026. Check the current status before relying on one.

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
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
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
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
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. ImmCite has read all 18 published decisions citing this case, as of 2026-11-13; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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 2026-11-13; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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.
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
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. ImmCite has read all 11 published decisions citing this case, as of 2026-11-13; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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. ImmCite has read all 9 published decisions citing this case, as of 2026-11-13; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.