Mandamus decisions / District of Massachusetts

Bonagwa v. Nielsen

District of MassachusettsGeorge A. OToole, JrDecided December 31, 2019No. 1:19-cv-10177

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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.

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 a model The matter is remanded to USCIS to decide the plaintiff’s application within sixty days of this Order.
Form or filing	N-400 (naturalization) Read by a model USCIS shall render a decision on plaintiff’s naturalization application within 15 days of plaintiff’s response.
What the suit asked for	Naturalization hearing or remand (1447(b)) Read by a model has brought suit pursuant to 8 U.S.C. § 1447(b) to have his pending application for naturalization considered and granted by this Court instead of by the agency.
Kind of order	A ruling on a motion or the petition Read by a model Accordingly, the defendant’s Motion to Remand to Agency (dkt. no. 9) is GRANTED.
Motion decided	Remand under 1447(b) Read by a model Accordingly, the defendant’s Motion to Remand to Agency (dkt. no. 9) is GRANTED.
Whose motion	The government's motion Read by a model Defendants have moved to remand the matter to USCIS.
Disposition	Remanded to the agency Sent back to the agency, with or without instructions. Read by a model The matter is remanded to USCIS to decide the plaintiff’s application within sixty days of this Order.
Prevailing party	Applicant Read by a model The matter is remanded to USCIS to decide the plaintiff’s application within sixty days of this Order.
The delay claim	Remanded to the agency Read by a model The matter is remanded to USCIS to decide the plaintiff’s application within sixty days of this Order.
Months pending	Not stated A section 1447(b) suit: these months run from the naturalization application. The statute's 120 days run from the interview, which they do not measure. Read by a model
TRAC factors	The court did not weigh the TRAC factors Read by a model
Threshold rulings	None Read by a model

How the case ended

Docket: No. 1:19-cv-10177
Filed: January 27, 2019
Ended: January 2, 2020
Suit's filing to its end: 340 days
How it ended: Remanded to the agency
From the record: idb disp 11 (remanded to U.S. agency)

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.

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
Aronov v. Napolitano, 562 F.3d 84

First Circuit, April 13, 2009. A § 1447(b) remand order directing USCIS to naturalize the applicant was not a consent decree that made him a prevailing party, and the government's delay for an FBI name check was substantially justified.

ImmCite: treatment available, history exists, not clearance
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.
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).