Mandamus decisions / District of Maryland

Nosrat v. Blinken

District of MarylandLydia Kay GriggsbyDecided February 2, 2026No. 8:24-cv-03319

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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.

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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 Given this, the Court agrees with the Defendants that any further consideration of Mr. Nosrat’s visa application falls within the discretion of the State Department.
Form or filing	221(g) (consular refusal); DS-260 (immigrant visa) Read by a model Gholmahossein Nosrat attended their immigrant visa interviews on November 20, 2023. Id. at ¶ 6; ECF No. 1-6. After these interviews, Ms. Motamedi and Mr. Nosrat received letters stating that their visa had been refused under INA Section 221(g) and placed in administrative processing.
What the suit asked for	Finish 221(g) processing Read by a model And so, the Plaintiffs request that the Court, among other things, declare that the Defendants’ refusal to adjudicate Mr. Nosrat’s visa application violates the INA and APA and order the Defendants to adjudicate the application within a reasonable period of time.
Kind of order	A ruling on a motion or the petition Read by a model the Court: (1) GRANTS-in-PART the Defendants’ motion to dismiss (ECF No. 6) and (2) DISMISSES the complaint.
Motion decided	Motion to dismiss for lack of jurisdiction Read by a model The Defendants have moved to dismiss the complaint, pursuant to Fed. R. Civ. P. 12(b)(1) and 12(b)(6).
Whose motion	The government's motion Read by a model The Defendants have moved to dismiss the complaint, pursuant to Fed. R. Civ. P. 12(b)(1) and 12(b)(6).
Disposition	Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model (2) DISMISSES the complaint.
Prevailing party	Government Read by a model (2) DISMISSES the complaint.
The delay claim	Dismissed Read by a model the Court: (1) GRANTS-in-PART the Defendants’ motion to dismiss (ECF No. 6) and (2) DISMISSES the complaint.
Months pending	11.9 months from the application to the suit; 26.4 months from the application to the court's decision Read by a model Gholmahossein Nosrat attended their immigrant visa interviews on November 20, 2023.
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 Plaintiffs point to no statute or regulation that imposes a mandatory duty on the State Department to re-adjudicate the application, or that imposes a specific time frame for reconsidering a refused visa application.
Nationality	Iran Read by a model The Plaintiff Gholmahossein Nosrat is a citizen of Iran.
I-130 category	Immediate relative Read by a model Plaintiff Ali Nosrat filed two I-130 family-based immigrant visa petitions for his parents with the United States Citizenship and Immigration Services (“USCIS”).

How the case ended

Docket: No. 8:24-cv-03319
On the docket: This ruling (ECF 10)
Filed: November 17, 2024
Ended: March 2, 2026
Suit's filing to its end: 470 days
How it ended: Dismissed, ground not recorded
From the record: 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.

The ruling's entry is the docket's one order or judgment entered the day of the decision. Both come from CourtListener's copy of the docket; check them there.

Supreme Court and Fourth 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
Sesay v. United States, 984 F.3d 312

Fourth Circuit, January 5, 2021. Consular nonreviewability bars review of a relative's visa refusal; under Din and Trump v. Hawaii a valid statutory citation satisfies Mandel, and the court will not look behind it absent a particularized showing of bad faith.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 4 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.
Gonzalez v. Cuccinelli, 985 F.3d 357

Fourth Circuit, January 14, 2021. Courts may review delay in placing U-visa petitioners on the waitlist under the TRAC factors and should not dismiss such claims at the pleading stage, but lack jurisdiction over delay in pre-waitlist work-permit requests, a point on which the Sixth Circuit disagrees.

ImmCite: caution, adverse or limiting treatment found. Rejected in the Sixth Circuit by Barrios Garcia v. U.S. Department of Homeland Security, 25 F.4th 430 (2022).
Lovo v. Miller, 107 F.4th 199

Fourth Circuit, July 3, 2024. The 'decision or action' language of § 1182(a)(9)(B)(v), which the court treated as coextensive with § 1252(a)(2)(B)(ii), does not reach USCIS inaction, so a district court may hear a claim that USCIS unreasonably delayed a provisional unlawful-presence waiver.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 5 published decisions citing this case, as of 2026-11-07; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.