Mandamus decisions / Western District of Washington

Kiyaroudi v. Blinken

Western District of WashingtonJames L. RobartDecided May 19, 2025No. 2:25-cv-00091

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What the decision decided

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Agency	Department of State Read by a model Mr. Kiyaroudi has since received three responses from the United States Consulate, most recently in February 2025, informing him that his case was still undergoing administrative processing.
Form or filing	221(g) (consular refusal); DS-160 (nonimmigrant visa) Read by a model applicant completes an Online Nonimmigrant Visa Application (Form DS-160)
What the suit asked for	Finish 221(g) processing Read by a model He seeks 7 expedited processing of his visa application.
Kind of order	A ruling on a motion or the petition Read by a model the court GRANTS Defendants’ motion to dismiss.
Motion decided	Motion to dismiss for failure to state a claim; Other motion to dismiss Read by a model Defendants now move to dismiss Mr. Kiyaroudi’s complaint under Federal Rules 9 of Civil Procedure 12(b)(3) and 12(b)(6).
Whose motion	The government's motion Read by a model Defendants now move to dismiss Mr. Kiyaroudi’s complaint under Federal Rules 9 of Civil Procedure 12(b)(3) and 12(b)(6).
Disposition	Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model The court DISMISSES Mr. Kiyaroudi’s complaint, and this action, with 10 prejudice.
Prevailing party	Government Read by a model the court GRANTS Defendants’ motion to dismiss.
The delay claim	Dismissed Read by a model The court DISMISSES Mr. Kiyaroudi’s complaint, and this action, with 10 prejudice.
The other claims	Dismissed Read by a model The court DISMISSES Mr. Kiyaroudi’s complaint, and this action, with 10 prejudice.
Months pending	9.1 months from the application to the suit; 13.2 months from the application to the court's decision Read by a model On April 11, 2024, Mr. Kiyaroudi and his family attended a visa interview at the United States Consulate in Auckland, New Zealand.
TRAC factors	The court did not weigh the TRAC factors Read by a model
Threshold rulings	No duty to re-adjudicate a 221(g) refusal Read by a model The court agrees that Mr. Kiyaroudi has not identified a 20 mandatory, nondiscretionary duty that Defendants failed to perform.
Nationality	Australia Read by a model Mr. Kiyaroudi, an Australian citizen

How the case ended

Docket: No. 2:25-cv-00091
Filed: January 14, 2025
Ended: May 19, 2025
Suit's filing to its end: 125 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 Ninth 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.

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
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
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
Allen v. Milas, 896 F.3d 1094

Ninth Circuit, July 24, 2018. The APA provides no avenue for review of a consular visa refusal beyond Mandel's facially-legitimate-and-bona-fide inquiry, and consular nonreviewability is not a jurisdictional bar.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 8 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.
Sanchez Gonzalez v. United States Department of State, No. 23-4205 (9th Cir. Apr. 30, 2026)

Ninth Circuit, April 30, 2026. After Muñoz, a citizen spouse's own First Amendment interest triggered Mandel review, which a facially legitimate and bona fide reason satisfied absent a showing of bad faith.

ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-10-18; it checks for new citing decisions daily. That is not a determination that the case is good law.
Independence Mining Co. v. Babbitt, 105 F.3d 502

Ninth Circuit, January 23, 1997. Mandamus and APA § 706(1) claims to compel delayed agency action are analyzed alike under the TRAC factors.

ImmCite: treatment available, history exists, not clearance
Vaz v. Neal, 33 F.4th 1131

Ninth Circuit, May 9, 2022. Section 706(1) compels only a clear, mandatory and discrete duty that has been unreasonably delayed under TRAC, and the APA's prerequisites go to the merits while § 1331 supplies jurisdiction.

ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-11-03; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 144 other decisions citing it, none a Supreme Court, BIA or Attorney General precedent or a published circuit opinion; ImmCite's status does not review them.