Mandamus decisions / District of Massachusetts

Sadeghi v.Michael Pompeo

District of MassachusettsRichard G. StearnsDecided July 26, 2018No. 1:18-cv-11540

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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.

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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 The Complaint generally alleges that the Department of State has failed to timely adjudicate Biglary’s visa waiver application as required by the implementing regulations of the Immigration and Nationality Act (INA)
Form or filing	I-129F (fiancé(e) petition) Read by a model With Sadeghi’s sponsorship, Biglary has filed an I- 129F visa petition (the fiancé visa), seeking to immigrate to the United States.
What the suit asked for	Decide the application Read by a model Petitioners’ first request is that the court issue a Writ of Mandamus directing the State Department to expedite the approval process of Biglary’s waiver and to issue her a visa no later than August 1, 2018.
Kind of order	A ruling on a motion or the petition Read by a model The Petition for a Writ of Mandamus is DENIED. The motion for emergency and injunctive relief is DENIED without prejudice.
Motion decided	Preliminary injunction or TRO Read by a model The motion for emergency and injunctive relief is DENIED without prejudice.
Whose motion	The plaintiff's motion Read by a model Sadeghi and Biglary now seek relief in this court, by way of the instant Motion for a Writ of Mandamus and Complaint for Emergency Injunctive and Declaratory Relief.
Disposition	Denied in the government's favor The principal motion was denied in full: a motion to dismiss denied so the case goes on, or relief denied on the merits. Read by a model The Petition for a Writ of Mandamus is DENIED. The motion for emergency and injunctive relief is DENIED without prejudice.
Prevailing party	Government Read by a model The Petition for a Writ of Mandamus is DENIED. The motion for emergency and injunctive relief is DENIED without prejudice.
The delay claim	Relief denied Read by a model The Petition for a Writ of Mandamus is DENIED. The motion for emergency and injunctive relief is DENIED without prejudice.
Months pending	Not stated Read by a model
TRAC factors	The court did not weigh the TRAC factors Read by a model
The government's delay arguments	Line-jumping accepted Read by a model an order from a federal district court to consider petitioners’ applications first before considering those of others, many of whom presumably are equally frustrated by the same delays.
Threshold rulings	APA adequate-remedy bar applied (mandamus claim fails) Read by a model Because the petitioners have failed to show “why mandamus should be considered in the face of this conventional review mechanism,” In Re Fall River, 470 F.3d at 33, the Petition for a Writ of Mandamus will be denied.
Nationality	Iran Read by a model His fiancée, Narges Biglary, is an Iranian citizen currently living in Tehran, Iran.
212(f) proclamation	Proclamation 9645 Read by a model However, because Iranian nationals are subject to the edicts of Presidential Proclamation No. 9645

How the case ended

Docket: No. 1:18-cv-11540
Filed: July 24, 2018
Ended: March 25, 2019
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 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 3, 2026. Check the current status before relying on one.

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
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
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
Adams v. Baker, 909 F.2d 643

First Circuit, July 26, 1990. A visa denial stands under Mandel where the government states a facially legitimate and bona fide reason, and the court will not weigh the evidence behind it.

ImmCite: caution, adverse or limiting treatment found. Clarified (jurisdictional description superseded by Muñoz), as recognized in Teles De Menezes v. Rubio, 156 F.4th 1 (2025).
Teles De Menezes v. Rubio, 156 F.4th 1

First Circuit, September 18, 2025. After Muñoz, consular nonreviewability is a merits defense rather than a jurisdictional bar, and it does not reach a challenge to the State Department's reclassification of an approved petition as opposed to a visa refusal.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 2 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.
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
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).