Mandamus decisions / Middle District of Tennessee
Ebrahimi v. Bitter
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 |
Department of State
Read by a model
The plaintiff asks the court to enter an order compelling the State Department to adjudicate his wife’s pending visa application under either the Administrative Procedures Act or the Mandamus Act. |
|---|---|
| Form or filing |
DS-260 (immigrant visa)
Read by a model
Regulations require that a beneficiary then complete a Form DS-260 Electronic Application for Immigrant Visa and Alien Registration and appear before a consular officer abroad for the execution of the application and an interview. |
| What the suit asked for |
Decide the application
Read by a model
The plaintiff asks the court to enter an order compelling the State Department to adjudicate his wife’s pending visa application under either the Administrative Procedures Act or the Mandamus Act. |
| Kind of order |
A ruling on a motion or the petition
Read by a model
For the reasons set forth herein, the defendant’s Motion to Dismiss, construed as a summary judgment motion, will be granted, and this case will be dismissed. |
| Motion decided |
Summary judgment
Read by a model
For the reasons set forth herein, the defendant’s Motion to Dismiss, construed as a summary judgment motion, will be granted, and this case will be dismissed. |
| Whose motion |
The government's motion
Read by a model
the defendant’s Motion to Dismiss, construed as a summary judgment motion, will be granted |
| Disposition |
Dismissed
The case or every delay claim was dismissed for a reason other than mootness.
Read by a model
For the reasons set forth herein, the defendant’s Motion to Dismiss, construed as a summary judgment motion, will be granted, and this case will be dismissed. |
| Prevailing party |
Government
Read by a model
Because the plaintiff cannot show that the delay at issue here was unreasonable, the defendant is entitled to judgment on the APA claim. |
| The delay claim |
Relief denied
Read by a model
Because the plaintiff cannot show that the delay at issue here was unreasonable, the defendant is entitled to judgment on the APA claim. Because the APA claim fails, the mandamus action alleging unreasonable delay necessarily fails as well. |
| Months pending |
18 months from the application to the court's decision
Read by a model
just under eighteen months (dating from December 14, 2021) to date |
| TRAC factors |
The court weighed the TRAC factors
The first-in, first-out rationale satisfies the rule of reason, and the plaintiff does not allege any facts suggesting that that rule is not being applied to Malekzadeh’s application. |
| The government's delay arguments |
First-in, first-out processing accepted; Line-jumping accepted
Read by a model
The first-in, first-out rationale satisfies the rule of reason, and the plaintiff does not allege any facts suggesting that that rule is not being applied to Malekzadeh’s application. |
| Threshold rulings | None Read by a model |
| I-130 category |
Immediate relative
Read by a model
Ebrahimi is a United States citizen who lives in Tennessee. (Doc. No. 20-1, Ebrahimi Decl. ¶¶ 2–3.) His wife, Mahdiyeh Malekzadeh, lives in Iran. |
How the case ended
- Docket
- No. 3:22-cv-00788
- Filed
- October 5, 2022
- Ended
- June 6, 2023
- Suit's filing to its end
- 244 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 Sixth 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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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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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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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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Baaghil v. Miller, 1 F.4th 427
Sixth Circuit, June 14, 2021. Visa denials stood where the consulate gave a facially legitimate and bona fide reason, and a citizen's asserted liberty interest in a relative's admission adds no further process.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 3 published decisions citing this case, as of 2026-11-10; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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Barrios Garcia v. U.S. Department of Homeland Security, 25 F.4th 430
Sixth Circuit, February 10, 2022. Courts may review and compel unreasonably delayed U-visa waitlist placement and bona fide determinations under TRAC, though not discretionary pre-waitlist work authorization, disagreeing in part with the Fourth Circuit's Gonzalez.
ImmCite: unchecked, treatment not confirmed yet, not evidence either way. No verified adverse treatment has been found so far. All 2 precedential decisions citing this case have been reviewed as of 2026-11-13.