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Mandamus decisions / Northern District of Illinois

Patel v. Sanders

Northern District of IllinoisSara L. EllisDecided April 7, 2025No. 1:24-cv-08386

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.

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What the decision decided

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Agency Department of State Read by a model
On January 22, 2024, a consular officer at the U.S. Consulate General in Montreal, Canada, interviewed Mr. Patel in connection with the Application.
Form or filing 221(g) (consular refusal); DS-260 (immigrant visa) Read by a model
Form DS-260 (“Application for Immigrant Visa and Alien Registration”)
What the suit asked for Finish 221(g) processing Read by a model
Reframing this dispute as one of standing, the key question is whether Ms. Patel has suffered the injury of which she complains, namely not receiving a final determination on the Application, such that this Court could order Defendants to provide a final determination.
Kind of order A ruling on a motion or the petition Read by a model
For the foregoing reasons, the Court grants in part and denies in part Defendants’ motion to dismiss [10].
Motion decided Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim Read by a model
Defendants move to dismiss Ms. Patel’s complaint, arguing that the Court lacks subject matter jurisdiction over Ms. Patel’s claims and that Ms. Patel has failed to state a claim upon which relief can be granted under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6).
Whose motion The government's motion Read by a model
For the foregoing reasons, the Court grants in part and denies in part Defendants’ motion to dismiss [10].
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
The Court dismisses Ms. Patel’s Mandamus Act and Fifth Amendment Due Process claims, while allowing her APA claim to proceed.
Prevailing party Each side in part Read by a model
The Court dismisses Ms. Patel’s Mandamus Act and Fifth Amendment Due Process claims, while allowing her APA claim to proceed.
The delay claim The delay claim goes on Read by a model
The Court dismisses Ms. Patel’s Mandamus Act and Fifth Amendment Due Process claims, while allowing her APA claim to proceed.
The other claims Dismissed Read by a model
The Court, therefore, grants Defendants’ motion to dismiss Ms. Patel’s due process claim.
Months pending 14.5 months from the application to the court's decision Read by a model
On January 22, 2024, a consular officer at the U.S. Consulate General in Montreal, Canada, interviewed Mr. Patel in connection with the Application.
TRAC factors The court weighed the TRAC factors
  • 1. Rule of reasonfavors the applicant
  • 2. Congressional timetablefavors the government
  • 3. Human health and welfarefavors the applicant
  • 4. Competing prioritiesneutral
  • 5. Interests prejudicedfavors the applicant
  • 6. No impropriety neededneutral
Read by a model
Altogether, taking the evidence in the light most favorable to the plaintiff, the first factor weighs in favor of Ms. Patel.
The government's delay arguments First-in, first-out processing rejected; Line-jumping found neutral Read by a model
Altogether, taking the evidence in the light most favorable to the plaintiff, the first factor weighs in favor of Ms. Patel.
Threshold rulings Consular nonreviewability rejected; Mootness argument rejected; Duty to re-adjudicate a 221(g) refusal found; APA adequate-remedy bar applied (mandamus claim fails) Read by a model
This Court joins with the majority and finds that consular nonreviewability does not apply
Nationality Canada Read by a model
On March 5, 2024, Mr. Patel became a Canadian citizen.
I-130 category Immediate relative Read by a model
Ms. Patel is a U.S. citizen residing in Illinois. In October 2021, Ms. Patel filed an I-130 visa petition for her husband, Utsavbhai Jashvantbhai Patel (“Mr. Patel”), with USCIS.

How the case ended

Docket
No. 1:24-cv-08386
Filed
September 13, 2024
Ended
April 24, 2025
Suit's filing to its end
223 days
How it ended
Ended once the agency acted
From the record
idb disp 12 (dismissed: voluntarily)

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 Seventh 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.