Mandamus decisions / District of Maryland

Aghamohammadi v. Blinken

District of MarylandDeborah K. ChasanowDecided September 19, 2025No. 8:24-cv-02801

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What the decision decided

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Agency	Department of State Read by a model On November 2, 2023, Plaintiffs Mokhtar and Batool were interviewed together by a consular officer at the U.S. Embassy in Yerevan, Armenia.
Form or filing	221(g) (consular refusal); DS-260 (immigrant visa) Read by a model This case concerns a particular type of visa, the immediate-relative immigrant visa.
What the suit asked for	Finish 221(g) processing Read by a model In Count Two, Plaintiffs seek an order compelling Defendants to adjudicate Plaintiffs’ visa applications under the Mandamus Act, 28 U.S.C § 1361.
Kind of order	A ruling on a motion or the petition Read by a model Defendants’ motion to dismiss for lack of subject matter jurisdiction, (ECF No. 9), will be granted
Motion decided	Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim Read by a model Defendants’ motion to dismiss for lack of subject matter jurisdiction, (ECF No. 9), will be granted; and Defendants’ motion to dismiss for failure to state a claim, (Id.), will be denied as moot.
Whose motion	The government's motion Read by a model Defendants’ motion to dismiss for lack of subject matter jurisdiction, (ECF No. 9), will be granted
Disposition	Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model Defendants’ motion to dismiss for lack of subject matter jurisdiction, (ECF No. 9), will be granted;
Prevailing party	Government Read by a model Defendants are correct that the court lacks subject matter jurisdiction over both counts in Plaintiffs’ complaint.
The delay claim	Dismissed Read by a model Defendants’ motion to dismiss for lack of subject matter jurisdiction, (ECF No. 9), will be granted
The other claims	Dismissed Read by a model Plaintiffs’ unlawful withholding claims under § 706(1) and § 706(2) are thus dismissed.
Months pending	10.9 months from the application to the suit; 22.6 months from the application to the court's decision Read by a model On November 2, 2023, Plaintiffs Mokhtar and Batool were interviewed together by a consular officer at the U.S. Embassy in Yerevan, Armenia.
TRAC factors	The court weighed the TRAC factors 1. Rule of reasonnot reached 2. Congressional timetablenot reached 3. Human health and welfarefavors the applicant 4. Competing prioritiesfavors the government 5. Interests prejudicedfavors the applicant 6. No impropriety neededneutral Read by a model factors three and five would favor Plaintiffs
Threshold rulings	No duty to re-adjudicate a 221(g) refusal; APA adequate-remedy bar applied (mandamus claim fails) Read by a model But § 42.81(a) mandates nothing after the consular officer initially refuses a visa under 221(g).
Nationality	Iran Read by a model Plaintiffs are Mahdi Aghamohammadi, a United States Citizen, and his parents, Mokhtar Aghamohammadi and Batool Panji, who are Iranian nationals.
I-130 category	Immediate relative Read by a model Plaintiffs are Mahdi Aghamohammadi, a United States Citizen, and his parents, Mokhtar Aghamohammadi and Batool Panji, who are Iranian nationals.

How the case ended

Docket: No. 8:24-cv-02801
Filed: September 30, 2024
Ended: September 19, 2025
Suit's filing to its end: 354 days
How it ended: Dismissed on jurisdiction or the merits
From the record: idb disp 3 (dismissed: lack of jurisdiction)

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 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 3, 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 2026-10-30; 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 2026-10-29; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.