Mandamus decisions / District of Maryland
Dhimar v. Blinken
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
Plaintiff Mihir Dhimar, an Indian national currently located overseas, has sued U.S. officials for what he alleges is unreasonable delay by U.S. consulates in processing his visa. |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-160 (nonimmigrant visa)
Read by a model
On January 7, 2022, Dhimar, located in India as of that time, applied to a U.S. consulate there for an H-1B visa, which permits foreign nationals to temporarily work in the U.S. His application was denied pending administrative processing and remains unresolved. |
| What the suit asked for |
Finish 221(g) processing
Read by a model
He brought this mandamus action in August 2022 with the goal of compelling □ Defendants to rule on his visa application. |
| Kind of order |
A transfer order
Read by a model
This case SHALL be TRANSFERRED to the United States District Court for the District of Columbia. |
| Motion decided |
Other motion to dismiss; Transfer
Read by a model
1. This case SHALL be TRANSFERRED to the United States District Court for the District of Columbia. 2 Defendants’ Motion to Dismiss (ECF No. 4) is DENIED AS MOOT. |
| Whose motion |
The government's motion
Read by a model
the Court GRANTS Defendants’ Motion to Transfer |
| Disposition |
Transferred to another court
An order moving the case to another court. It decides where the suit is heard, not who wins, so it is not counted as either side's win.
Read by a model
This case SHALL be TRANSFERRED to the United States District Court for the District of Columbia. |
| Prevailing party |
Neither side
Read by a model
This case SHALL be TRANSFERRED to the United States District Court for the District of Columbia. |
| The delay claim |
Not decided here
Read by a model
This case SHALL be TRANSFERRED to the United States District Court for the District of Columbia. |
| Months pending |
7.2 months from the application to the suit; 11 months from the application to the court's decision
Read by a model
On January 7, 2022, Dhimar, located in India as of that time, applied to a U.S. consulate there for an H-1B visa, which permits foreign nationals to temporarily work in the U.S. |
| TRAC factors | The court did not weigh the TRAC factors Read by a model |
| Threshold rulings | None Read by a model |
| Nationality |
India
Read by a model
Plaintiff Mihir Dhimar, an Indian national currently located overseas |
How the case ended
- Docket
- No. 1:22-cv-02175
- Filed
- August 27, 2022
- Ended
- December 8, 2022
- Suit's filing to its end
- 103 days
- How it ended
- Transferred
- From the record
- idb disp 0 (transferred to another district)
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 Fourth 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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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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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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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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Sesay v. United States, 984 F.3d 312
Fourth Circuit, January 5, 2021. Consular nonreviewability bars review of a relative's visa refusal; under Din and Trump v. Hawaii a valid statutory citation satisfies Mandel, and the court will not look behind it absent a particularized showing of bad faith.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 4 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.
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Gonzalez v. Cuccinelli, 985 F.3d 357
Fourth Circuit, January 14, 2021. Courts may review delay in placing U-visa petitioners on the waitlist under the TRAC factors and should not dismiss such claims at the pleading stage, but lack jurisdiction over delay in pre-waitlist work-permit requests, a point on which the Sixth Circuit disagrees.
ImmCite: caution, adverse or limiting treatment found. Rejected in the Sixth Circuit by Barrios Garcia v. U.S. Department of Homeland Security, 25 F.4th 430 (2022).
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Lovo v. Miller, 107 F.4th 199
Fourth Circuit, July 3, 2024. The 'decision or action' language of § 1182(a)(9)(B)(v), which the court treated as coextensive with § 1252(a)(2)(B)(ii), does not reach USCIS inaction, so a district court may hear a claim that USCIS unreasonably delayed a provisional unlawful-presence waiver.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 5 published decisions citing this case, as of 2026-11-07; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.