Mandamus decisions / Western District of Washington

Beygi v. United States Department of State

Western District of WashingtonThomas S. ZillyDecided November 22, 2024No. 2:24-cv-00504

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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 On September 28, 2023, the United States Department of State (“State 3 Department”) interviewed Haghighi and Ahmadbeigi.
Form or filing	221(g) (consular refusal); DS-260 (immigrant visa) Read by a model immigration visas have been unlawfully withheld and unreasonably delayed, and 9 requesting this Court compel Defendants to complete all administrative processing of the 10 visa applications
What the suit asked for	Finish 221(g) processing Read by a model requesting this Court compel Defendants to complete all administrative processing of the 10 visa applications within sixty (“60”) days
Kind of order	A ruling on a motion or the petition Read by a model The Defendants’ Motion to Dismiss pursuant to FRCP 12(b)(6), docket no. 11, is 18 GRANTED. Plaintiff’s complaint is DISMISSED with prejudice.
Motion decided	Motion to dismiss for failure to state a claim Read by a model The Defendants’ Motion to Dismiss pursuant to FRCP 12(b)(6), docket no. 11, is 18 GRANTED.
Whose motion	The government's motion Read by a model The Defendants’ Motion to Dismiss pursuant to FRCP 12(b)(6), docket no. 11, is 18 GRANTED.
Disposition	Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model Plaintiff’s complaint is DISMISSED with prejudice.
Prevailing party	Government Read by a model Plaintiff’s complaint is DISMISSED with prejudice.
The delay claim	Dismissed Read by a model Plaintiff’s unreasonable delay claim must be dismissed with 11 prejudice
The other claims	Dismissed Read by a model Plaintiff’s due process claim must be dismissed with 14 prejudice because he does not have a liberty interest in his parents’ visa applications.
Months pending	6.6 months from the application to the suit; 13.8 months from the application to the court's decision Read by a model On September 28, 2023, the United States Department of State (“State 3 Department”) interviewed Haghighi and Ahmadbeigi.
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 prioritiesnot reached 5. Interests prejudicednot reached 6. No impropriety needednot reached Read by a model
Threshold rulings	No duty to re-adjudicate a 221(g) refusal Read by a model both visa applications 17 have already been adjudicated when they were refused on September 28, 2023, and there 18 is no mandatory, nondiscretionary duty to readjudicate them.
Nationality	Iran Read by a model his parents, Iranian nationals

How the case ended

Docket: No. 2:24-cv-00504
Filed: April 15, 2024
Ended: November 22, 2024
Suit's filing to its end: 221 days
How it ended: Dismissed on jurisdiction or the merits
From the record: 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 Ninth 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
Allen v. Milas, 896 F.3d 1094

Ninth Circuit, July 24, 2018. The APA provides no avenue for review of a consular visa refusal beyond Mandel's facially-legitimate-and-bona-fide inquiry, and consular nonreviewability is not a jurisdictional bar.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 8 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.
Sanchez Gonzalez v. United States Department of State, No. 23-4205 (9th Cir. Apr. 30, 2026)

Ninth Circuit, April 30, 2026. After Muñoz, a citizen spouse's own First Amendment interest triggered Mandel review, which a facially legitimate and bona fide reason satisfied absent a showing of bad faith.

ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-10-18; it checks for new citing decisions daily. That is not a determination that the case is good law.
Independence Mining Co. v. Babbitt, 105 F.3d 502

Ninth Circuit, January 23, 1997. Mandamus and APA § 706(1) claims to compel delayed agency action are analyzed alike under the TRAC factors.

ImmCite: treatment available, history exists, not clearance
Vaz v. Neal, 33 F.4th 1131

Ninth Circuit, May 9, 2022. Section 706(1) compels only a clear, mandatory and discrete duty that has been unreasonably delayed under TRAC, and the APA's prerequisites go to the merits while § 1331 supplies jurisdiction.

ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-11-10; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 145 other decisions citing it, none a Supreme Court, BIA or Attorney General precedent or a published circuit opinion; ImmCite's status does not review them.