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Mandamus decisions / Southern District of New York

Chang v. Jaddou

Southern District of New YorkJohn P. CronanDecided July 18, 2025No. 1:24-cv-06565

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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
The Court assumes that, as of the date of this Order, USCIS has yet to adjudicate Chang’s asylum application.
Form or filing I-589 (asylum) Read by a model
Chang submitted an asylum application on June 28, 2021, which was received by USCIS on July 7, 2021.
What the suit asked for Decide the asylum application Read by a model
seeking an order compelling the Secretary of the Department of Homeland Security and the Director of United States Citizenship and Immigration Services (“USCIS”) to render a decision as to his application for asylum in the United States.
Kind of order A ruling on a motion or the petition Read by a model
For reasons that follow, the Court overrules Chang’s objections, adopts the Report and Recommendation in its entirety, and dismisses the Complaint without prejudice.
Motion decided Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim Read by a model
On November 4, 2024, Defendants moved to dismiss the Complaint for want of jurisdiction and for failure to state a claim.
Whose motion The government's motion Read by a model
On November 4, 2024, Defendants moved to dismiss the Complaint for want of jurisdiction and for failure to state a claim.
Disposition Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model
Accordingly, the Court adopts the Report and Recommendation in its entirety, dismisses the Complaint without prejudice, and denies Chang leave to amend the Complaint.
Prevailing party Government Read by a model
Accordingly, the Court adopts the Report and Recommendation in its entirety, dismisses the Complaint without prejudice, and denies Chang leave to amend the Complaint.
The delay claim Dismissed Read by a model
Accordingly, the Court adopts the Report and Recommendation in its entirety, dismisses the Complaint without prejudice, and denies Chang leave to amend the Complaint.
Months pending 38.1 months from the application to the suit; 48.7 months from the application to the court's decision Read by a model
Chang submitted an asylum application on June 28, 2021, which was received by USCIS on July 7, 2021.
TRAC factors The court weighed the TRAC factors
  • 1. Rule of reasonfavors the government
  • 2. Congressional timetablenot reached
  • 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
“the Court joins the chorus of judges in this Circuit finding that the time USCIS takes to adjudicate asylum applications through its LIFO policy is governed by a rule of reason.”
The government's delay arguments First-in, first-out processing accepted; Line-jumping accepted Read by a model
First, “the Court joins the chorus of judges in this Circuit finding that the time USCIS takes to adjudicate asylum applications through its LIFO policy is governed by a rule of reason.”
Threshold rulings APA adequate-remedy bar applied (mandamus claim fails) Read by a model
As discussed more below, see infra III.B, Chang has available an alternative remedy under the APA, thus depriving this Court of subject matter jurisdiction over his mandamus claim.
Nationality China Read by a model
As a citizen of China and current resident of the United States, Chang submitted an asylum application

Other orders in this case

The group holds 4 decisions from this suit, oldest first. Outcome counts on these pages count the case once, by its latest decision, this one. How decisions are grouped into cases.

DecisionDecidedJudgeDisposition
Chang v. Jaddou February 11, 2025 John P. Cronan Magistrate judge's recommendation
Chang v. Jaddou February 11, 2025 Sarah L. Cave Magistrate judge's recommendation
Chang v. Jaddou February 26, 2025 John P. Cronan Dismissed
Chang v. JaddouThis decisionThe case's latest decision: its outcome is the one counted July 18, 2025 John P. Cronan Dismissed

How the case ended

Docket
No. 1:24-cv-06565
Filed
August 30, 2024
Ended
July 18, 2025
Suit's filing to its end
136 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.

Supreme Court and Second 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.