Mandamus decisions / District of Maryland

Sakhi v. Blinken

District of MarylandDeborah L. BoardmanDecided March 25, 2025No. 8:24-cv-01376

Read the decision Original 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 Immediately afterwards, the Department of State refused Arefi’s visa application pursuant to 8 U.S.C. § 1201(g) and placed his application in administrative processing.
Form or filing	221(g) (consular refusal); DS-160 (nonimmigrant visa) Read by a model Arefi promptly submitted his Form DS-160.
What the suit asked for	Finish 221(g) processing Read by a model Arefi and Sakhi filed suit under the Administrative Procedure Act (“APA”), 5 U.S.C. § 706(1), to compel the Department of State (“State Department”) to remove Arefi’s application from administrative processing and issue a final adjudication on the application.
Kind of order	A ruling on a motion or the petition Read by a model The defendants’ motion to dismiss under Federal Rule of Civil Procedure 12(b)(1) is granted.
Motion decided	Motion to dismiss for lack of jurisdiction Read by a model The defendants’ motion to dismiss under Federal Rule of Civil Procedure 12(b)(1) is granted.
Whose motion	The government's motion Read by a model The defendants’ motion to dismiss under Federal Rule of Civil Procedure 12(b)(1) is granted.
Disposition	Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model The Court grants the motion and dismisses the complaint for lack of subject matter jurisdiction.
Prevailing party	Government Read by a model The Court grants the motion and dismisses the complaint for lack of subject matter jurisdiction.
The delay claim	Dismissed Read by a model Because the defendants did not fail to take a discrete action they were required to take, the Court does not have subject matter jurisdiction over the plaintiffs’ APA claim. The claim is dismissed without prejudice.
Months pending	6.5 months from the application to the suit; 17 months from the application to the court's decision Read by a model On October 24, 2023, Arefi was interviewed by a consular officer at the U.S. embassy in Islamabad.
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 The consular officer has no duty to readjudicate a refused visa application, even if the officer has chosen, in their discretion, to receive additional information and place the application in a period of administrative processing.
Nationality	Afghanistan Read by a model Arefi is an Afghan national residing in Afghanistan.

How the case ended

Docket: No. 8:24-cv-01376
On the docket: This ruling (ECF 24)
Filed: May 10, 2024
Ended: March 25, 2025
Suit's filing to its end: 319 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 Fourth 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
Sesay v. United States, 984 F.3d 312

Fourth Circuit, January 5, 2021. Consular nonreviewability bars review of a relative's visa refusal; under Din and Trump v. Hawaii a valid statutory citation satisfies Mandel, and the court will not look behind it absent a particularized showing of bad faith.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 4 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.
Gonzalez v. Cuccinelli, 985 F.3d 357

Fourth Circuit, January 14, 2021. Courts may review delay in placing U-visa petitioners on the waitlist under the TRAC factors and should not dismiss such claims at the pleading stage, but lack jurisdiction over delay in pre-waitlist work-permit requests, a point on which the Sixth Circuit disagrees.

ImmCite: caution, adverse or limiting treatment found. Rejected in the Sixth Circuit by Barrios Garcia v. U.S. Department of Homeland Security, 25 F.4th 430 (2022).
Lovo v. Miller, 107 F.4th 199

Fourth Circuit, July 3, 2024. The 'decision or action' language of § 1182(a)(9)(B)(v), which the court treated as coextensive with § 1252(a)(2)(B)(ii), does not reach USCIS inaction, so a district court may hear a claim that USCIS unreasonably delayed a provisional unlawful-presence waiver.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 5 published decisions citing this case, as of 2026-11-07; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.