Mandamus decisions / District of Columbia
Jafarzadeh v. Duke
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
The United States Citizenship and Immigration Service (USCIS), the agency within the Department of Homeland Security (DHS) that adjudicates these applications, granted her application but denied his. |
|---|---|
| Form or filing |
I-130 (relative petition); I-485 (adjustment of status)
Read by a model
Razeyeh filed a Petition for Alien Relative (Form I-130) and Manouchehr filed a concurrent Application to Register Permanent Residence or Adjust Status (Form I-485). |
| What the suit asked for |
Decide the application
Read by a model
The suit, styled as one for mandamus relief, seeks an order under the Immigration and Nationality Act (INA) and the Administrative Procedure Act (APA) requiring USCIS to adjudicate the applications after six years of delay (Counts I, II, and III). |
| Kind of order |
A ruling on a motion or the petition
Read by a model
The government’s motion to dismiss 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
The government has moved to dismiss for lack of subject matter jurisdiction and failure to state a claim. See Fed. R. Civ. P. 12(b)(1), (b)(6). |
| Whose motion |
The government's motion
Read by a model
The government has moved to dismiss for lack of subject matter jurisdiction and failure to state a claim. |
| 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
Hence, Count I will be dismissed as moot in its entirety. Counts II and III will be dismissed as moot only insofar as they request that USCIS adjudicate plaintiffs’ applications. |
| Prevailing party |
Each side in part
Read by a model
Hence, Count I will be dismissed as moot in its entirety. Counts II and III will be dismissed as moot only insofar as they request that USCIS adjudicate plaintiffs’ applications. |
| The delay claim |
Moot: the agency acted
Read by a model
Hence, Count I will be dismissed as moot in its entirety. Counts II and III will be dismissed as moot only insofar as they request that USCIS adjudicate plaintiffs’ applications. |
| The other claims |
Some dismissed, some go on
Read by a model
The government’s motion to dismiss is granted in part and denied in part. |
| Months pending |
77 months from the application to the suit; 84.9 months from the application to the agency's action
Read by a model
But on February 10, 2017, USCIS denied Manouchehr’s application for adjustment of status. |
| TRAC factors | The court did not weigh the TRAC factors Read by a model |
| Threshold rulings |
Section 1252(a)(2)(B) bar rejected; Held moot; Mootness argument rejected
Read by a model
Likewise, the INA’s provisions limiting judicial review of the immigration judge’s and the Board of Immigration Appeals’ decision to the circuit court, and prohibiting judicial review of discretionary decisions, are also not relevant. |
| Nationality |
Iran
Read by a model
Plaintiff Manouchehr is a citizen of Iran who has lawfully resided in the United States since 1979. |
| I-130 category |
Immediate relative
Read by a model
His U.S. citizen daughter, Razeyeh Jafardzadeh, filed the corresponding application for Manouchehr to become a lawful permanent resident as an immediate relative of a U.S. citizen. |
How the case ended
This decision is not linked to a docket in the docket record yet, so how the case ended is not shown.
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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Kucana v. Holder, 558 U.S. 233
Supreme Court, January 20, 2010. Section 1252(a)(2)(B)(ii) bars review only of decisions whose discretionary character is specified by statute, not discretion the agency gives itself by regulation.
ImmCite: treatment available, history exists, not clearance
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Patel v. Garland, 596 U.S. 328
Supreme Court, May 16, 2022. Section 1252(a)(2)(B)(i) bars review of any judgment regarding the granting of the listed forms of relief, including the factual findings on which a denial of adjustment rests.
ImmCite: treatment available, history exists, not clearance
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Bouarfa v. Mayorkas, 604 U.S. 6
Supreme Court, December 10, 2024. Revoking an approved visa petition under § 1155 is a discretionary decision or action that § 1252(a)(2)(B)(ii) places beyond judicial review.
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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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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In re Core Communications, Inc., 531 F.3d 849
D.C. Circuit, July 8, 2008. Mandamus to compel unreasonably delayed agency action is an extraordinary remedy guided by the TRAC factors, granted here after years of unexplained delay.
ImmCite: treatment available, history exists, not clearance
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Da Costa v. Immigration Investor Program Office, 80 F.4th 330
D.C. Circuit, August 18, 2023. EB-5 petition delays of roughly four years were not unreasonable under TRAC where USCIS adjudicates in a rule-of-reason order and expediting the plaintiffs would only move them ahead of others in the queue.
ImmCite: treatment available, history exists, not clearance
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American Hospital Ass'n v. Burwell, 812 F.3d 183
D.C. Circuit, February 9, 2016. A delay claim under the Mandamus Act requires a clear duty, a clear right and no adequate alternative remedy, and the TRAC factors then decide whether the delay warrants relief, with a statutory deadline weighing heavily.
ImmCite: treatment available, history exists, not clearance
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Afghan and Iraqi Allies v. Blinken, 103 F.4th 807
D.C. Circuit, June 7, 2024. TRAC governs visa-processing delay claims in district court, a court that finds unreasonable delay may set adjudication deadlines, and expediting a whole class in queue order is not line-jumping.
ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-10-28; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 49 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.