Mandamus decisions / Northern District of Alabama
Nikpanah v. United States Department of State
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
On October 26, 2023, the State Department conducted visa interviews for Nikpanah’s parents. |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-260 (immigrant visa)
Read by a model
“issue a writ of mandamus compelling Defendants to adjudicate long- delayed immediate relative visa applications” |
| What the suit asked for |
Finish 221(g) processing
Read by a model
Plaintiff requests that the court “compel[] Defendants to promptly complete all administrative processing within sixty days.” |
| Kind of order |
A ruling on a motion or the petition
Read by a model
GRANTING DEFENDANTS’ MOTION TO DISMISS |
| Motion decided |
Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim
Read by a model
On August 24, 2024, Defendants filed this motion 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
On August 24, 2024, Defendants filed this motion 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 reasons stated above, Defendants’ motion to dismiss (Doc. 24) is GRANTED. This action is DISMISSED WITHOUT PREJUDICE. |
| Prevailing party |
Government
Read by a model
For the reasons stated above, Defendants’ motion to dismiss (Doc. 24) is GRANTED. This action is DISMISSED WITHOUT PREJUDICE. |
| The delay claim |
Dismissed
Read by a model
For the reasons stated above, Defendants’ motion to dismiss (Doc. 24) is GRANTED. This action is DISMISSED WITHOUT PREJUDICE. |
| The other claims |
Dismissed
Read by a model
As a result, on the due process cause of action, Plaintiff cannot state a plausible claim for relief. |
| Months pending |
5.2 months from the application to the suit; 15.3 months from the application to the court's decision
Read by a model
On October 26, 2023, the State Department conducted visa interviews for Nikpanah’s parents. |
| TRAC factors | The court did not weigh the TRAC factors Read by a model |
| Threshold rulings |
No duty to re-adjudicate a 221(g) refusal
Read by a model
In sum, Plaintiff has not identified any basis for the court to find that the State Department has a discrete, nondiscretionary duty to take any action beyond the action that it did take: refusing the visas for Plaintiff’s parents after their consular interviews. |
| Nationality |
Iran
Read by a model
Nikpanah’s parents, Seyedmostafa Nikpanah and Monir Mostaghimi, are Iranian citizens who currently reside in Iran. |
| I-130 category |
Immediate relative
Read by a model
In April 2021, Nikpanah filed immediate relative visa petitions for her parents with U.S. Citizenship and Immigration Services (USCIS). |
How the case ended
- Docket
- No. 2:24-cv-00404
- On the docket
- This ruling (ECF 32)
- Filed
- April 1, 2024
- Ended
- February 3, 2025
- Suit's filing to its end
- 308 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.
The ruling's entry is the docket's one order or judgment entered the day of the decision. Both come from CourtListener's copy of the docket; check them there.
Supreme Court and Eleventh 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.
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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
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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
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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
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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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Del Valle v. Secretary of State, 16 F.4th 832
Eleventh Circuit, October 26, 2021. Consular nonreviewability is not jurisdictional, but a refusal citing specific inadmissibility provisions is facially legitimate and bona fide, and in camera review of the underlying evidence is foreclosed absent plausibly alleged bad faith.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 3 published decisions citing this case, as of 2026-11-13; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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Kanapuram v. Director, USCIS, 131 F.4th 1302
Eleventh Circuit, March 20, 2025. Section 1252(a)(2)(B)(ii) strips district courts of jurisdiction over APA unreasonable-delay claims about pending adjustment applications where the delay is part of the discretionary adjudication process, including retrogression holds.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 2 published decisions citing this case, as of 2026-11-09; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.