Mandamus decisions / Southern District of Ohio
Igal v. the U.S. Consulate General in Johannesburg
Read the decisionOriginal on CourtListener
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.
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 |
Department of State
Read by a model
Over a year later, in January 2023, the United States Consulate General in Johannesburg interviewed Plaintiff’s husband. |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-260 (immigrant visa)
Read by a model
Those facts are strikingly similar to Plaintiff’s case, whose husband’s immediate relative visa application also sits in administrative processing. |
| What the suit asked for |
Finish 221(g) processing
Read by a model
In her Complaint, Plaintiff requests an order compelling Defendants to complete processing and adjudication of her husband’s visa application. |
| Kind of order |
A ruling on a motion or the petition
Read by a model
Defendants’ Motion to Dismiss (Doc. 15) is GRANTED in part and DENIED in part. |
| Motion decided |
Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim
Read by a model
For the foregoing reasons, Defendants’ Motion to Dismiss (Doc. 15) is GRANTED in part and DENIED in part. |
| Whose motion |
The government's motion
Read by a model
Defendants’ Motion to Dismiss (Doc. 15) is GRANTED in part and DENIED in part. |
| Disposition |
Dismissed in part; some claims go on
The government's motion to dismiss was granted in part: some claims were dismissed and others go on.
Read by a model
Plaintiff’s remaining claims may proceed for further development. |
| Prevailing party |
Each side in part
Read by a model
Plaintiff’s remaining claims may proceed for further development. |
| The delay claim |
The delay claim goes on
Read by a model
Plaintiff’s remaining claims may proceed for further development. |
| The other claims |
Dismissed
Read by a model
Plaintiff’s due process claims are DISMISSED. |
| Months pending |
16.7 months from the application to the court's decision
Read by a model
Over a year later, in January 2023, the United States Consulate General in Johannesburg interviewed Plaintiff’s husband. |
| TRAC factors | The court did not weigh the TRAC factors Read by a model |
| The government's delay arguments |
Line-jumping rejected
Read by a model
Even so, usual administrative delay does not absolve Defendants of their duty to adjudicate visas within a reasonable time. |
| Threshold rulings |
Consular nonreviewability rejected; Mootness argument rejected; Duty to re-adjudicate a 221(g) refusal found
Read by a model
Similarly, the Court rejects Defendants’ argument that the doctrine of consular nonreviewability bars Plaintiff’s claims. |
| I-130 category |
Immediate relative
Read by a model
Those facts are strikingly similar to Plaintiff’s case, whose husband’s immediate relative visa application also sits in administrative processing. |
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 |
|---|---|---|---|
| Igal v. the U.S. Consulate General in JohannesburgThis decision | June 7, 2024 | Kimberly A. Jolson | Dismissed in part; some claims go on |
| Igal v. the U.S. Consulate General in JohannesburgThe case's latest decision: its outcome is the one counted | June 7, 2024 | Kimberly A. Jolson | Dismissed in part; some claims go on |
How the case ended
- Docket
- No. 2:23-cv-04160
- Filed
- November 29, 2023
- Ended
- October 24, 2024
- Suit's filing to its end
- 330 days
- How it ended
- Ended once the agency acted
- From the record
- stipulated dismissal 2024-10-24; 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 Sixth 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.
-
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
-
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
-
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
-
Baaghil v. Miller, 1 F.4th 427
Sixth Circuit, June 14, 2021. Visa denials stood where the consulate gave a facially legitimate and bona fide reason, and a citizen's asserted liberty interest in a relative's admission adds no further process.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 3 published decisions citing this case, as of 2026-11-10; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
-
Barrios Garcia v. U.S. Department of Homeland Security, 25 F.4th 430
Sixth Circuit, February 10, 2022. Courts may review and compel unreasonably delayed U-visa waitlist placement and bona fide determinations under TRAC, though not discretionary pre-waitlist work authorization, disagreeing in part with the Fourth Circuit's Gonzalez.
ImmCite: unchecked, treatment not confirmed yet, not evidence either way. No verified adverse treatment has been found so far. All 2 precedential decisions citing this case have been reviewed as of 2026-11-13.