Mandamus decisions / District of Columbia
Liu v. Garland
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 |
Department of State
Read by a model
Thus, because the Department of State officials “could play a role in the pace of visa adjudications, an order from [the Court] directing [them] to move quickly would likely redress [the p]laintiffs’ harms.” |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-160 (nonimmigrant visa)
Read by a model
[o]n April 17, 2023, [the plaintiffs allegedly] attended [their] visa interview[s] at the U.S. Consulate in Calgary, Canada[,]” and at the “conclusion of [their] interview[s] [their respective consular officers allegedly] gave [them] a 221(g)-refusal notice[.] |
| What the suit asked for |
Finish 221(g) processing
Read by a model
“But [the p]laintiffs do not seek to have [their] visa adjudication revised; rather, they seek to have the adjudication completed.” |
| Kind of order |
A ruling on a motion or the petition
Read by a model
For the foregoing reasons, the Court concludes that it must grant the 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
Currently pending before the Court is the defendants’ 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
Currently pending before the Court is the defendants’ 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
Accordingly, although the Court is not unsympathetic to the plaintiffs’ situation, the Court must grant the defendants’ motion to dismiss the plaintiffs’ APA and Mandamus Act claims. |
| Prevailing party |
Government
Read by a model
For the foregoing reasons, the Court concludes that it must grant the defendants’ motion to dismiss. |
| The delay claim |
Dismissed
Read by a model
the Court must grant the defendants’ motion to dismiss the plaintiffs’ APA and Mandamus Act claims. |
| Months pending |
2.5 months from the application to the suit; 16.2 months from the application to the court's decision
Read by a model
[o]n April 17, 2023, [the plaintiffs allegedly] attended [their] visa interview[s] at the U.S. Consulate in Calgary, Canada[,] |
| TRAC factors |
The court weighed the TRAC factors
In other words, the first two factors, considered together, favor the defendants. |
| The government's delay arguments |
Line-jumping accepted
Read by a model
But this argument ignores that a court order directing [the defendants] to process [the plaintiffs’] application would still put [them] ahead in the queue of those similarly situated. |
| Threshold rulings | None Read by a model |
| Nationality |
China
Read by a model
citizens of China who have long studied and worked in the United States in lawful nonimmigrant status. |
How the case ended
- Docket
- No. 1:23-cv-01914
- Filed
- July 1, 2023
- Ended
- August 23, 2024
- Suit's filing to its end
- 419 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 D.C. 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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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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Saavedra Bruno v. Albright, 197 F.3d 1153
D.C. Circuit, December 3, 1999. Consular visa decisions are not subject to judicial review absent an express statutory grant, and the APA does not displace that doctrine.
ImmCite: treatment available, history exists, not clearance
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Baan Rao Thai Restaurant v. Pompeo, 985 F.3d 1020
D.C. Circuit, January 22, 2021. Consular nonreviewability bars a federal court from second-guessing a consular officer's decision to issue or withhold a visa, and dismissal on that ground is a merits ruling rather than a jurisdictional one.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 3 published decisions citing this case, as of 2026-10-29; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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Pietersen v. Department of State, 138 F.4th 552
D.C. Circuit, May 30, 2025. Consular nonreviewability does not bar a forward-looking APA challenge to generally applicable State Department guidance, as distinct from review of an individual visa refusal.
ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-11-03; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 24 other decisions citing it, none a Supreme Court, BIA or Attorney General precedent or a published circuit opinion; ImmCite's status does not review them.
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Telecommunications Research & Action Center v. FCC, 750 F.2d 70
D.C. Circuit, October 24, 1984. Whether agency delay is unreasonable turns on six factors: a rule of reason, any statutory timetable, the human welfare interests at stake, the effect of expediting on competing priorities, the interests prejudiced by delay, and no need to find impropriety.
ImmCite: treatment available, history exists, not clearance
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Mashpee Wampanoag Tribal Council, Inc. v. Norton, 336 F.3d 1094
D.C. Circuit, August 8, 2003. A claim that an agency has unreasonably delayed a matter arises under the APA and § 1331, and the TRAC factors decide whether the delay is unreasonable.
ImmCite: treatment available, history exists, not clearance
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Karimova v. Abate, No. 23-5178 (D.C. Cir. July 24, 2024) (unpublished judgment)
D.C. Circuit, July 24, 2024, nonprecedential. Neither § 555(b) nor any other law imposes a clear, nondiscretionary duty on a consular officer to re-adjudicate a visa application that was officially refused under § 1201(g) and placed in administrative processing, so mandamus and § 706(1) relief are unavailable.
ImmCite: not applicable, outside the precedential ImmCite corpus