Mandamus decisions / District of Columbia

Dehshiri v. Blinken

District of ColumbiaG. Michael HarveyDecided July 7, 2025No. 1:24-cv-03098

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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 All Plaintiffs submitted visa applications and were interviewed by consular officers at various U.S. embassies.
Form or filing	221(g) (consular refusal); DS-160 (nonimmigrant visa) Read by a model All Plaintiffs’ applications were refused under Section 221(g) of the Immigration and Nationality Act (“INA”) and subject to “administrative processing.”
What the suit asked for	Finish 221(g) processing Read by a model Plaintiffs bring this suit to compel the Secretary of State and the Director of the National Vetting Center of the Department of Homeland Security to promptly complete the administrative processing and adjudication of their visa applications.
Kind of order	A ruling on a motion or the petition Read by a model For the reasons stated, the Court will grant Defendants’ motion to dismiss.
Motion decided	Motion to dismiss for failure to state a claim Read by a model Defendants filed a motion to dismiss under Rules 12(b)(1) and 12(b)(6) of the Federal Rules of Civil Procedure
Whose motion	The government's motion Read by a model Defendants filed a motion to dismiss under Rules 12(b)(1) and 12(b)(6) of the Federal Rules of Civil Procedure
Disposition	Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model A separate Order dismissing the complaint will issue.
Prevailing party	Government Read by a model For the reasons stated, the Court will grant Defendants’ motion to dismiss.
The delay claim	Dismissed Read by a model For the reasons stated, the Court will grant Defendants’ motion to dismiss.
Months pending	Not stated Read by a model
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 Because Plaintiffs have failed to identify any clear, nondiscretionary duty for the consular officer to do anything more with respect to their visa applications, the motion to dismiss will be granted.
Nationality	Iran Read by a model Plaintiffs are 13 Iranian national students

How the case ended

Docket: No. 1:24-cv-03098
Filed: October 31, 2024
Ended: July 7, 2025
Suit's filing to its end: 244 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 D.C. 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.

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
Saavedra Bruno v. Albright, 197 F.3d 1153

D.C. Circuit, December 3, 1999. Consular visa decisions are not subject to judicial review absent an express statutory grant, and the APA does not displace that doctrine.

ImmCite: treatment available, history exists, not clearance
Baan Rao Thai Restaurant v. Pompeo, 985 F.3d 1020

D.C. Circuit, January 22, 2021. Consular nonreviewability bars a federal court from second-guessing a consular officer's decision to issue or withhold a visa, and dismissal on that ground is a merits ruling rather than a jurisdictional one.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 3 published decisions citing this case, as of 2026-10-29; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
Pietersen v. Department of State, 138 F.4th 552

D.C. Circuit, May 30, 2025. Consular nonreviewability does not bar a forward-looking APA challenge to generally applicable State Department guidance, as distinct from review of an individual visa refusal.

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 24 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.
Telecommunications Research & Action Center v. FCC, 750 F.2d 70

D.C. Circuit, October 24, 1984. Whether agency delay is unreasonable turns on six factors: a rule of reason, any statutory timetable, the human welfare interests at stake, the effect of expediting on competing priorities, the interests prejudiced by delay, and no need to find impropriety.

ImmCite: treatment available, history exists, not clearance
Mashpee Wampanoag Tribal Council, Inc. v. Norton, 336 F.3d 1094

D.C. Circuit, August 8, 2003. A claim that an agency has unreasonably delayed a matter arises under the APA and § 1331, and the TRAC factors decide whether the delay is unreasonable.

ImmCite: treatment available, history exists, not clearance
Karimova v. Abate, No. 23-5178 (D.C. Cir. July 24, 2024) (unpublished judgment)

D.C. Circuit, July 24, 2024, nonprecedential. Neither § 555(b) nor any other law imposes a clear, nondiscretionary duty on a consular officer to re-adjudicate a visa application that was officially refused under § 1201(g) and placed in administrative processing, so mandamus and § 706(1) relief are unavailable.

ImmCite: not applicable, outside the precedential ImmCite corpus