Mandamus decisions / District of Massachusetts
Patel v. Director of U.S. Citizenship and Immigration Services
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 |
USCIS
Read by rule
defendant Director of the United States Citizenship and Immigration Services has unreasonably delayed making a bona fide determination (“BFD”) on his petition for U nonimmigrant status, also known |
|---|---|
| Form or filing |
I-918 (U visa)
Read by rule
status, called a U visa, by submitting Form I-918, Petition for U Nonimmigration Status (known as a U Visa Petition)”). Of note, there is no indication that the plaintiff has served the |
| Disposition | Magistrate judge's recommendation A magistrate judge's report and recommendation. The district judge decides whether to adopt it, so it is not counted as either side's win. Read by rule |
| Prevailing party | Neither side Read by rule |
How the case ended
- Docket
- No. 1:25-cv-11837
- Filed
- June 26, 2025
- Ended
- February 3, 2026
- Suit's filing to its end
- 222 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.
Supreme Court and First 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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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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Towns of Wellesley, Concord & Norwood v. FERC, 829 F.2d 275
First Circuit, September 25, 1987. The First Circuit applies the TRAC factors when asked to compel agency action that has been unreasonably delayed.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 5 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.
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Patel v. Jaddou, 118 F.4th 475
First Circuit, October 16, 2024. Assuming statutory jurisdiction, § 1255(a) does not forbid USCIS from holding adjustment applications until a visa number is immediately available, so no § 706(1) claim lies against the abeyance policy; the Fourth Circuit rejects deciding the merits before the § 1252(a)(2)(B) question.
ImmCite: caution, adverse or limiting treatment found. Reasoning rejected in the Fourth Circuit by Lolakshi Kale v. Angelica Alfonso-Royals, 139 F.4th 329 (2025).