Mandamus decisions / Eastern District of Pennsylvania
BYRNE v. NOEM
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
Plaintiff asks this Court to compel the United States Citizenship and Immigration Services (“USCIS”) to issue a decision, or at least an initial review, of Plaintiff’s I-914 Application for a T visa submitted on March 22, 2024. |
|---|---|
| Form or filing |
I-914 (T visa)
Read by a model
Plaintiff asks this Court to compel the United States Citizenship and Immigration Services (“USCIS”) to issue a decision, or at least an initial review, of Plaintiff’s I-914 Application for a T visa submitted on March 22, 2024. |
| What the suit asked for |
Decide the application
Read by a model
Plaintiff asks this Court to compel the United States Citizenship and Immigration Services (“USCIS”) to issue a decision, or at least an initial review, of Plaintiff’s I-914 Application for a T visa submitted on March 22, 2024. |
| Kind of order |
A ruling on a motion or the petition
Read by a model
For the foregoing reasons, Defendants’ Motion to Dismiss the Complaint (Doc. No. 10) will be denied. |
| Motion decided |
Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim
Read by a model
Notably, in primarily moving to dismiss the Complaint for lack of subject matter jurisdiction, Defendants refer to Federal Rule of Civil Procedure 12(b)(6) in a footnote in their Motion, which reads as follows |
| Whose motion |
The government's motion
Read by a model
Before the Court is Defendants’ Motion to Dismiss the Complaint (Doc. No. 10) |
| Disposition |
Denied in the applicant's favor
The principal motion was denied in full: a motion to dismiss denied so the case goes on, or relief denied on the merits.
Read by a model
For the foregoing reasons, Defendants’ Motion to Dismiss the Complaint (Doc. No. 10) will be denied. |
| Prevailing party |
Applicant
Read by a model
For the foregoing reasons, Defendants’ Motion to Dismiss the Complaint (Doc. No. 10) will be denied. |
| The delay claim |
The delay claim goes on
Read by a model
Counts I and II will not be dismissed for insufficient pleading. |
| Months pending |
17 months from the application to the court's decision
Read by a model
Plaintiff’s I-914 Application for a T visa submitted on March 22, 2024. |
| TRAC factors | The court did not weigh the TRAC factors Read by a model |
| The government's delay arguments |
Line-jumping accepted
Read by a model
Defendants oppose moving Plaintiff to the head of the line for consideration of T visas because it would unfairly prejudice a considerable number of other applicants who may have been waiting longer. There appears to be merit to this argument. |
| Threshold rulings |
APA adequate-remedy bar rejected
Read by a model
Next, pursuant to 28 U.S.C. § 1361 (Mandamus Act), Plaintiff has alleged enough facts to give rise to an inference that USCIS violated a duty for which there is no alternative remedy. |
| Nationality |
Ireland
Read by a model
Irish national Keith Michael Byrne |
How the case ended
- Docket
- No. 2:25-cv-01077
- Filed
- February 28, 2025
- Ended
- May 18, 2026
- Suit's filing to its end
- 444 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. Other suits in this court.
Supreme Court and Third 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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Oil, Chemical & Atomic Workers Union v. OSHA, 145 F.3d 120
Third Circuit, March 16, 1998. The Third Circuit weighs the TRAC factors in deciding whether to compel agency action that has been unreasonably delayed.
ImmCite: treatment available, history exists, not clearance. ImmCite has read the one published decision citing this case, as of 2026-11-03; it does not treat the case adversely. That describes that decision; it is not a determination that the case is good law.
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Geda v. Director, USCIS, 126 F.4th 835
Third Circuit, January 23, 2025. Section 1255(a) commits both the adjustment decision and the process and pace for reaching it to the Secretary's discretion, so § 1252(a)(2)(B)(ii) strips district courts of jurisdiction over challenges to USCIS's adjudication hold policy and § 1252(a)(2)(D) does not restore it.
ImmCite: treatment available, history exists, not clearance