Mandamus decisions / District of Massachusetts
Washington v. Mayorkas
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
Washington does not dispute that USCIS’s last-in, firstout system of reviewing asylum applications is a rule of a reason, and the nothing in the text of the enabling statute independently compels the conclusion that a different system is required. |
|---|---|
| Form or filing |
I-589 (asylum)
Read by a model
Plaintiff Raymond Washington filed this action to compel immediate adjudication of his asylum application. |
| What the suit asked for |
Decide the asylum application
Read by a model
Plaintiff Raymond Washington filed this action to compel immediate adjudication of his asylum application. |
| Kind of order |
A ruling on a motion or the petition
Read by a model
For the following reasons, the court will allow both motions. |
| Motion decided |
Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim
Read by a model
Defendants move to dismiss pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6) |
| Whose motion |
The government's motion
Read by a model
Defendants move to dismiss pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6) |
| Disposition |
Dismissed
The case or every delay claim was dismissed for a reason other than mootness.
Read by a model
For the foregoing reasons, the motion to dismiss Count I for lack of subject matter jurisdiction is ALLOWED, and the motion to dismiss Count II for failure to state a claim is ALLOWED. |
| Prevailing party |
Government
Read by a model
The Clerk shall enter judgment against plaintiff and close this case. |
| The delay claim |
Dismissed
Read by a model
For the foregoing reasons, the motion to dismiss Count I for lack of subject matter jurisdiction is ALLOWED, and the motion to dismiss Count II for failure to state a claim is ALLOWED. |
| Months pending | Not stated Read by a model |
| TRAC factors |
The court weighed the TRAC factors
The first two TRAC factors, which are “typically considered together,” see Milligan v. Pompeo, 502 F. Supp. 3d 302, 317 (D.D.C. 2020), weigh in defendants’ favor. |
| The government's delay arguments |
First-in, first-out processing accepted; Line-jumping accepted
Read by a model
weigh in defendants’ favor. Washington does not dispute that USCIS’s last-in, firstout system of reviewing asylum applications is a rule of a reason |
| Threshold rulings | None Read by a model |
How the case ended
- Docket
- No. 1:24-cv-10318
- Filed
- February 8, 2024
- Ended
- August 15, 2024
- Suit's filing to its end
- 189 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 First 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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Towns of Wellesley, Concord & Norwood v. FERC, 829 F.2d 275
First Circuit, September 25, 1987. The First Circuit applies the TRAC factors when asked to compel agency action that has been unreasonably delayed.
ImmCite: treatment available, history exists, not clearance
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Patel v. Jaddou, 118 F.4th 475
First Circuit, October 16, 2024. Assuming statutory jurisdiction, § 1255(a) does not forbid USCIS from holding adjustment applications until a visa number is immediately available, so no § 706(1) claim lies against the abeyance policy; the Fourth Circuit rejects deciding the merits before the § 1252(a)(2)(B) question.
ImmCite: caution, adverse or limiting treatment found. Reasoning rejected in the Fourth Circuit by Lolakshi Kale v. Angelica Alfonso-Royals, 139 F.4th 329 (2025).