Mandamus decisions / Western District of Washington
Bloomberg v. Rubio
Read the decisionOriginal on CourtListener
2,914 written decisions from 2,661 cases in the whole mandamus and agency-delay group, the group's newest decided October 30, 2026. Updated November 3, 2026 at 1:24 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 1,606 public decisions since January 1, 2025 that a CourtListener and GovInfo search for mandamus and agency delay finds, Passim holds 1,371 (85%), measured November 3, 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
Ms. Bloomberg filed her complaint on July 29, 2025, approximately 18 months after the U.S. Embassy placed her father’s application into administrative processing. |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-260 (immigrant visa)
Read by a model
This action arises from Defendants’ refusal of Ms. Bloomberg’s father’s application for an IR-5 immigrant visa. |
| What the suit asked for |
Finish 221(g) processing
Read by a model
Defendants assert that Ms. Bloomberg cannot state a claim under the APA because she has failed to identify a mandatory, nondiscretionary duty that requires Defendants to readjudicate her father’s refused nonimmigrant visa application after placing it into administrative processing. |
| Kind of order |
A ruling on a motion or the petition
Read by a model
For the foregoing reasons, the court GRANTS Defendants’ motion to dismiss (Dkt. # 11). |
| Motion decided |
Motion to dismiss for failure to state a claim
Read by a model
Before the court is Defendants’ motion to dismiss Plaintiff Lida Bloomberg’s complaint for writ of mandamus. |
| Whose motion |
The government's motion
Read by a model
Before the court is Defendants’ motion to dismiss Plaintiff Lida Bloomberg’s complaint for writ of mandamus. |
| Disposition |
Dismissed
The case or every delay claim was dismissed for a reason other than mootness.
Read by a model
Ms. Bloomberg’s complaint, and this action, are DISMISSED with prejudice. |
| Prevailing party |
Government
Read by a model
For the foregoing reasons, the court GRANTS Defendants’ motion to dismiss (Dkt. # 11). |
| The delay claim |
Dismissed
Read by a model
Ms. Bloomberg’s complaint, and this action, are DISMISSED with prejudice. |
| Months pending |
17.4 months from the application to the suit; 21.7 months from the application to the court's decision
Read by a model
Ms. Bloomberg’s father, Mohammadreza Zeinali, completed his immigrant visa interview with a consular officer at the U.S. Embassy in Yerevan, Armenia in February 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
The court concludes that amendment would be futile because the Government does not, as a matter of law, have a mandatory duty to readjudicate a refused visa application. |
| Nationality |
Iran
Read by a model
Ms. Bloomberg began the process of applying for visas for her parents, who are Iranian nationals, in January 2021. |
| I-130 category |
Immediate relative
Read by a model
This action arises from Defendants’ refusal of Ms. Bloomberg’s father’s application for an IR-5 immigrant visa. |
How the case ended
- Docket
- No. 2:25-cv-01420
- Filed
- July 29, 2025
- Ended
- December 8, 2025
- Suit's filing to its end
- 132 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 3, 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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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 2026-10-31; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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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.
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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
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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 2026-11-03; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 144 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.