Passim

Mandamus decisions / Eastern District of New York

Adebayo v. United States Department of State

Eastern District of New YorkLaShann DeArcy HallDecided March 31, 2025No. 1:24-cv-02523

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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
The Consulate has not held Plaintiff’s children’s visa interviews yet, nor has a final decision been issued on Plaintiff’s petitions.
Form or filing DS-260 (immigrant visa) Read by a model
Plaintiff seeks a writ of mandamus compelling Defendants to adjudicate the pending visa applications.
What the suit asked for Decide the application Read by a model
Plaintiff seeks a writ of mandamus compelling Defendants to adjudicate the pending visa applications.
Kind of order A ruling on a motion or the petition Read by a model
For the foregoing reasons, Defendants’ motion to dismiss the complaint is GRANTED.
Motion decided Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim Read by a model
Defendants move pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6) to dismiss the complaint for lack of subject matter jurisdiction and failure to state a claim.
Whose motion The government's motion Read by a model
Defendants move pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6) to dismiss the complaint for lack of subject matter jurisdiction and failure to state a claim.
Disposition Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model
For the foregoing reasons, Defendants’ motion to dismiss the complaint is GRANTED.
Prevailing party Government Read by a model
For the foregoing reasons, Defendants’ motion to dismiss the complaint is GRANTED.
The delay claim Dismissed Read by a model
Accordingly, Plaintiff’s APA claim for unreasonable delay must be dismissed.
The other claims Dismissed Read by a model
Therefore, Plaintiff’s Fifth Amendment due process claim must also be dismissed.
Months pending 54.5 months from the application to the court's decision Read by a model
the Court should instead calculate the time that the visa petitions have been pending from the date of their initial filings on September 14, 2020.
TRAC factors The court weighed the TRAC factors
  • 1. Rule of reasonnot reached
  • 2. Congressional timetablenot reached
  • 3. Human health and welfarenot reached
  • 4. Competing prioritiesfavors the government
  • 5. Interests prejudicednot reached
  • 6. No impropriety needednot reached
Read by a model
Thus, an order directing Defendants to immediately adjudicate Plaintiff’s visa petitions would simply push Plaintiff’s petitions to the front of the line, at the expense of similarly situated visa applicants.
The government's delay arguments Line-jumping accepted Read by a model
Thus, an order directing Defendants to immediately adjudicate Plaintiff’s visa petitions would simply push Plaintiff’s petitions to the front of the line, at the expense of similarly situated visa applicants.
Threshold rulings APA adequate-remedy bar applied (mandamus claim fails) Read by a model
The availability of an APA claim, even if Plaintiff’s APA claim fails on the merits, precludes mandamus relief.
I-130 category Immediate relative Read by a model
Plaintiff Blessing Adebayo, a United States citizen, filed I-130 visa petitions on behalf of his three minor children, O.El.A., O.F.A., and O.Em.A., who currently reside in Nigeria, on September 14, 2020.

How the case ended

Docket
No. 1:24-cv-02523
Filed
April 4, 2024
Ended
March 31, 2025
Suit's filing to its end
361 days
How it ended
Dismissed on jurisdiction or the merits
From the record
order 2025-03-31 dismisses for want of jurisdiction; 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 Second 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.