Mandamus decisions / Eastern District of Michigan
Mohafel v.US Secretary of State
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.
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
They seek to compel the Secretary of State and other federal officials to direct a consular officer to further adjudicate Galabi’s immigration visa application. |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-260 (immigrant visa)
Read by a model
The consular officer refused Galabi’s immigration visa application after the interview. |
| What the suit asked for |
Finish 221(g) processing
Read by a model
They seek to compel the Secretary of State and other federal officials to direct a consular officer to further adjudicate Galabi’s immigration visa application. |
| Kind of order |
A ruling on a motion or the petition
Read by a model
IT IS ORDERED that the government’s motion to dismiss the complaint (ECF No. 5) is granted. |
| Motion decided |
Motion to dismiss for lack of jurisdiction
Read by a model
The government now moves to dismiss the complaint on the ground that, among other things, Mohafel and Galabi lack Article III standing to maintain this action. |
| Whose motion |
The government's motion
Read by a model
Before the Court is the government’s motion to dismiss the complaint. |
| Disposition |
Dismissed
The case or every delay claim was dismissed for a reason other than mootness.
Read by a model
IT IS ORDERED that the government’s motion to dismiss the complaint (ECF No. 5) is granted. |
| Prevailing party |
Government
Read by a model
IT IS ORDERED that the government’s motion to dismiss the complaint (ECF No. 5) is granted. |
| The delay claim |
Dismissed
Read by a model
IT IS ORDERED that the government’s motion to dismiss the complaint (ECF No. 5) is granted. |
| Months pending |
14.9 months from the application to the court's decision
Read by a model
Galabi attended a consular interview at the United States Embassy in Kuala Lumpur, Malaysia on August 27, 2024. |
| 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
Whether the consular officer or some other State Department official is authorized to later “reconsider this refusal is immaterial, when no statute, regulation, or other source imposes a duty to reconsider it.” |
| Nationality |
Syria
Read by a model
His mother, Galabi, is a displaced Syrian national currently living in Malaysia. |
| I-130 category |
Immediate relative
Read by a model
Mohafel is a United States citizen. (ECF No. 1, PageID.4, ¶ 11). His mother, Galabi, is a displaced Syrian national currently living in Malaysia. |
How the case ended
- Docket
- No. 2:25-cv-11061
- Filed
- April 14, 2025
- Ended
- November 25, 2025
- Suit's filing to its end
- 225 days
- How it ended
- Dismissed on jurisdiction or the merits
- From the record
- order 2025-11-25 for the defendants, ground not stated; 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.
Supreme Court and Sixth 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.
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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
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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
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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
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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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Baaghil v. Miller, 1 F.4th 427
Sixth Circuit, June 14, 2021. Visa denials stood where the consulate gave a facially legitimate and bona fide reason, and a citizen's asserted liberty interest in a relative's admission adds no further process.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 3 published decisions citing this case, as of 2026-11-10; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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Barrios Garcia v. U.S. Department of Homeland Security, 25 F.4th 430
Sixth Circuit, February 10, 2022. Courts may review and compel unreasonably delayed U-visa waitlist placement and bona fide determinations under TRAC, though not discretionary pre-waitlist work authorization, disagreeing in part with the Fourth Circuit's Gonzalez.
ImmCite: unchecked, treatment not confirmed yet, not evidence either way. No verified adverse treatment has been found so far. All 2 precedential decisions citing this case have been reviewed as of 2026-11-13.