Mandamus decisions / District of Columbia

Haapaniemi v. Garland

District of ColumbiaCarl J. NicholsDecided November 7, 2024

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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 Justice Read by a model Fourth, the decision to initiate removal proceedings is left to the Attorney General, not a federal district judge.
Form or filing	None named Read by a model
What the suit asked for	Some other action Read by a model In this action, which the Court construes as a petition for a writ of mandamus, petitioner demands that the Attorney General “order [a] removal eligibility hearing via immigration judge.”
Kind of order	A ruling on a motion or the petition Read by a model The Court dismisses the petition for the following reasons.
Motion decided	None Read by a model
Whose motion	The plaintiff's motion Read by a model In this action, which the Court construes as a petition for a writ of mandamus, petitioner demands that the Attorney General “order [a] removal eligibility hearing via immigration judge.”
Disposition	Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model The Court dismisses the petition for the following reasons.
Prevailing party	Government Read by a model The Court dismisses the petition for the following reasons.
The delay claim	Dismissed Read by a model The Court dismisses the petition for the following reasons.
Months pending	Not stated 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
Nationality	British Virgin Islands Read by a model Petitioner, who allegedly was born in Norway and is a citizen of the British Virgin Islands

How the case ended

This decision is not linked to a docket in the docket record yet, so how the case ended is not shown.

Supreme Court and D.C. 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.

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
Telecommunications Research & Action Center v. FCC, 750 F.2d 70

D.C. Circuit, October 24, 1984. Whether agency delay is unreasonable turns on six factors: a rule of reason, any statutory timetable, the human welfare interests at stake, the effect of expediting on competing priorities, the interests prejudiced by delay, and no need to find impropriety.

ImmCite: treatment available, history exists, not clearance
Mashpee Wampanoag Tribal Council, Inc. v. Norton, 336 F.3d 1094

D.C. Circuit, August 8, 2003. A claim that an agency has unreasonably delayed a matter arises under the APA and § 1331, and the TRAC factors decide whether the delay is unreasonable.

ImmCite: treatment available, history exists, not clearance
In re Core Communications, Inc., 531 F.3d 849

D.C. Circuit, July 8, 2008. Mandamus to compel unreasonably delayed agency action is an extraordinary remedy guided by the TRAC factors, granted here after years of unexplained delay.

ImmCite: treatment available, history exists, not clearance
Da Costa v. Immigration Investor Program Office, 80 F.4th 330

D.C. Circuit, August 18, 2023. EB-5 petition delays of roughly four years were not unreasonable under TRAC where USCIS adjudicates in a rule-of-reason order and expediting the plaintiffs would only move them ahead of others in the queue.

ImmCite: treatment available, history exists, not clearance
American Hospital Ass'n v. Burwell, 812 F.3d 183

D.C. Circuit, February 9, 2016. A delay claim under the Mandamus Act requires a clear duty, a clear right and no adequate alternative remedy, and the TRAC factors then decide whether the delay warrants relief, with a statutory deadline weighing heavily.

ImmCite: treatment available, history exists, not clearance
Afghan and Iraqi Allies v. Blinken, 103 F.4th 807

D.C. Circuit, June 7, 2024. TRAC governs visa-processing delay claims in district court, a court that finds unreasonable delay may set adjudication deadlines, and expediting a whole class in queue order is not line-jumping.

ImmCite: unchecked, treatment not confirmed yet, not evidence either way. ImmCite has found no published decision citing this case as of 2026-10-28; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 49 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.