Mandamus decisions / District of Columbia
Shawuti v. U.S. Citizenship & Immigration Services
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 |
USCIS
Read by a model
Defendant United States Citizenship and Immigration Services (“USCIS”) received her application on May 5, 2015. |
|---|---|
| Form or filing |
N-400 (naturalization)
Read by a model
Plaintiff applied to become a naturalized United States citizen on May 1, 2015, by filing Form N-400.. (Compl. at 3, 5). |
| What the suit asked for |
Decide the application
Read by a model
On October 26, 2016, Plaintiff brought this action under 8 U.S.C. § 1447(b) to “demand that [her] application be adjudicated as soon as possible.” (Id.). |
| Kind of order |
A ruling on a motion or the petition
Read by a model
Defendant’s motion to dismiss will be granted. |
| Motion decided |
Motion to dismiss for lack of jurisdiction
Read by a model
USCIS moves to dismiss the complaint for lack of subject matter jurisdiction on two grounds. |
| Whose motion |
The government's motion
Read by a model
USCIS moves to dismiss the complaint for lack of subject matter jurisdiction on two grounds. |
| Disposition |
Dismissed as moot
Dismissed or denied as moot because the agency acted.
Read by a model
Here, USCIS’ denial of Plaintiffs application for naturalization February 3, 2017, after she had filed her Complaint, rendered her claim moot. |
| Prevailing party |
Neither side
Read by a model
Here, USCIS’ denial of Plaintiffs application for naturalization February 3, 2017, after she had filed her Complaint, rendered her claim moot. |
| The delay claim |
Moot: the agency acted
Read by a model
Here, USCIS’ denial of Plaintiffs application for naturalization February 3, 2017, after she had filed her Complaint, rendered her claim moot. |
| Months pending |
17.9 months from the application to the suit; 21.2 months from the application to the agency's action
Read by a model
on February 3, 2017, USCIS denied her application as premature |
| Months since the naturalization interview |
0.7 months from the interview (2017-01-13)
Read by a model
On January 13, 2017, Plaintiff “appeared for an interview to determine [her] eligibility status for naturalization,” |
| TRAC factors | The court did not weigh the TRAC factors Read by a model |
| Threshold rulings |
Held moot
Read by a model
Here, USCIS’ denial of Plaintiffs application for naturalization February 3, 2017, after she had filed her Complaint, rendered her claim moot. |
Other orders in this case
The group holds 2 decisions from this suit, oldest first. Outcome counts on these pages count the case once, by its latest decision. How decisions are grouped into cases.
| Decision | Decided | Judge | Disposition |
|---|---|---|---|
| Shawuti v. U.S. Citizenship & Immigration ServicesThis decision | August 8, 2017 | Tanya S. Chutkan | Dismissed as moot |
| Shawuti v. Uscis Washington, Dc Field OfficeThe case's latest decision: its outcome is the one counted | August 8, 2017 | Tanya S. Chutkan | Dismissed as moot |
How the case ended
- Docket
- No. 1:16-cv-02292
- Filed
- November 14, 2016
- Ended
- August 8, 2017
- Suit's filing to its end
- 267 days
- How it ended
- Ended once the agency acted
- 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.
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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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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
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Da Costa v. Immigration Investor Program Office, 80 F.4th 330
D.C. Circuit, August 18, 2023. EB-5 petition delays of roughly four years were not unreasonable under TRAC where USCIS adjudicates in a rule-of-reason order and expediting the plaintiffs would only move them ahead of others in the queue.
ImmCite: treatment available, history exists, not clearance
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American Hospital Ass'n v. Burwell, 812 F.3d 183
D.C. Circuit, February 9, 2016. A delay claim under the Mandamus Act requires a clear duty, a clear right and no adequate alternative remedy, and the TRAC factors then decide whether the delay warrants relief, with a statutory deadline weighing heavily.
ImmCite: treatment available, history exists, not clearance
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Afghan and Iraqi Allies v. Blinken, 103 F.4th 807
D.C. Circuit, June 7, 2024. TRAC governs visa-processing delay claims in district court, a court that finds unreasonable delay may set adjudication deadlines, and expediting a whole class in queue order is not line-jumping.
ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-10-28; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 49 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.