Mandamus decisions / District of Columbia
Voghouei v. Secretary, Department of Homeland Security
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
One week after the issuance of the Proclamation, a consular officer determined that Javanmardi and Khani, who are Iranian nationals, were ineligible for immigrant visas pursuant to INA Section 212(f), 8 U.S.C. § 1182(f). |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-260 (immigrant visa)
Read by a model
The plaintiffs are six foreign nationals who are either primary or derivative applicants for immigrant visas. |
| What the suit asked for |
Finish 221(g) processing
Read by a model
Rather, they allege that the “refusals” under Section 221(g) and subsequent placement into “administrative processing” were not “final adjudications” such that the government has unreasonably delayed deciding their visa applications. |
| Kind of order |
A ruling on a motion or the petition
Read by a model
Upon careful consideration of the parties’ written submissions and the relevant authorities, the Court will grant the government’s motion and dismiss the complaint. |
| Motion decided |
Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim
Read by a model
On January 14, 2026, the government filed a motion to dismiss pursuant to Rules 12(b)(1) and 12(b)(6) of the Federal Rules of Civil Procedure. |
| Whose motion |
The government's motion
Read by a model
On January 14, 2026, the government filed a motion to dismiss pursuant to Rules 12(b)(1) and 12(b)(6) of the Federal Rules of Civil Procedure. |
| Disposition |
Dismissed
The case or every delay claim was dismissed for a reason other than mootness.
Read by a model
Upon careful consideration of the parties’ written submissions and the relevant authorities, the Court will grant the government’s motion and dismiss the complaint. |
| Prevailing party |
Government
Read by a model
Upon careful consideration of the parties’ written submissions and the relevant authorities, the Court will grant the government’s motion and dismiss the complaint. |
| The delay claim |
Dismissed
Read by a model
Upon careful consideration of the parties’ written submissions and the relevant authorities, the Court will grant the government’s motion and dismiss the complaint. |
| The other claims |
Dismissed
Read by a model
Upon careful consideration of the parties’ written submissions and the relevant authorities, the Court will grant the government’s motion and dismiss the complaint. |
| Months pending |
17.9 months from the application to the suit
The agency acted before this decision, so the months up to the decision are not a delay and are not shown.
Read by a model
Sabetamal and Ehyaei executed their visa applications during an interview with a consular officer in Sydney, Australia, on May 30, 2023. |
| TRAC factors |
The court weighed the TRAC factors
The Court therefore determines that the first two TRAC factors weigh in the government’s favor. |
| The government's delay arguments |
Line-jumping accepted
Read by a model
But “[i]t would be improper for the [C]ourt to intervene and expedite [the] [p]laintiffs’ visa applications at the expense of others.” Majlesi v. Rubio, 2026 WL 654377, at *9. This factor thus strongly favors the government’s position. |
| Threshold rulings |
Held moot; No duty to re-adjudicate a 221(g) refusal
Read by a model
The Court therefore will dismiss as moot the claims brought by plaintiffs Javanmardi and Khani. |
| Nationality |
Iran
Read by a model
Plaintiff Hassan Sabetamal is a dual national of Iran and Australia and the primary applicant for an immigrant visa. |
| 212(f) proclamation |
Proclamation 10949
Read by a model
One week after the issuance of the Proclamation, a consular officer determined that Javanmardi and Khani, who are Iranian nationals, were ineligible for immigrant visas pursuant to INA Section 212(f), 8 U.S.C. § 1182(f). |
How the case ended
- Docket
- No. 1:25-cv-01893
- Filed
- June 17, 2025
- Ended
- May 18, 2026
- Suit's filing to its end
- 335 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 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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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. ImmCite has read all 18 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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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 2026-11-13; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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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. ImmCite has read all 11 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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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