Mandamus decisions / District of Massachusetts

Liberty Church Assemblies of God v. Pompeo

District of MassachusettsTimothy S HillmanDecided July 1, 2020No. 4:20-cv-10274

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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	Department of State Read by a model When he sought an R-1 visa from the U.S. Consulate General, however, the consular officer found him ineligible for R status and denied his application.
Form or filing	DS-160 (nonimmigrant visa) Read by a model On December 5, a consular officer again found him ineligible and denied his application for an R-1 visa.
What the suit asked for	Not recorded Read by a model
Kind of order	A ruling on a motion or the petition Read by a model For the reasons stated above, the Court grants Defendants’ motion and dismisses all claims against them.
Motion decided	Other motion to dismiss Read by a model Defendants move to dismiss under the doctrine of consular nonreviewability.
Whose motion	The government's motion Read by a model Defendants moved to dismiss on April 14, 2020, arguing that the doctrine of consular nonreviewability bars the instant action.
Disposition	Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model For the reasons stated above, the Court grants Defendants’ motion and dismisses all claims against them.
Prevailing party	Government Read by a model For the reasons stated above, the Court grants Defendants’ motion and dismisses all claims against them.
The other claims	Dismissed Read by a model For the reasons stated above, the Court grants Defendants’ motion and dismisses all claims against them.
Months pending	1.9 months from the application to the suit; 0 months from the application to the agency's action Read by a model December 2019 to file a new visa application providing additional evidence of his ties to Brazil. On December 5, a consular officer again found him ineligible and denied his application for an R-1 visa. Two weeks later, a different consular officer denied Mr. Rocha’s application
TRAC factors	The court did not weigh the TRAC factors Read by a model
Threshold rulings	Consular nonreviewability applied Read by a model the Court agrees with the D.C. Circuit that consular nonreviewability stands as an exception to judicial review under 5 U.S.C. § 702.
Nationality	Brazil Read by a model Samuel Rocha, a citizen of Brazil, is one of its members.

How the case ended

Docket: No. 4:20-cv-10274
Filed: February 12, 2020
Ended: July 1, 2020
Suit's filing to its end: 140 days
How it ended: Dismissed on jurisdiction or the merits
From the record: idb disp 3 (dismissed: lack of jurisdiction)

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.

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 2026-11-13; 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. 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).