Mandamus decisions / District of Columbia
ZELENSKAIA v. RUBIO
Read the decisionOriginal on CourtListener
2,917 written decisions from 2,664 cases in the whole mandamus and agency-delay group, the group's newest decided October 30, 2026. Updated November 3, 2026 at 7:07 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.
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
Plaintiffs bring this suit to compel the Secretary of State and the Acting Director of the National Vetting Center to promptly complete the administrative processing and adjudication of their visa applications. |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-160 (nonimmigrant visa)
Read by a model
Like all nonimmigrant visa applicants, once an F-1 or J-1 applicant is found to meet the eligibility requirements for their respective visa , they are required to submit Form DS -160, a nonimmigrant visa application. |
| What the suit asked for |
Finish 221(g) processing
Read by a model
Plaintiffs bring this suit to compel the Secretary of State and the Acting Director of the National Vetting Center to promptly complete the administrative processing and adjudication of their visa applications. |
| Kind of order |
A ruling on a motion or the petition
Read by a model
For the reasons stated, the Court will grant Defendants’ motion to dismiss. |
| Motion decided |
Motion to dismiss for failure to state a claim
Read by a model
Accordingly, the Court will follow Karimova’s lead on that point as well, and grant Defendants’ motion to dismiss for failure to state a claim |
| Whose motion |
The government's motion
Read by a model
For the reasons stated, the Court will grant Defendants’ motion to dismiss. |
| Disposition |
Dismissed
The case or every delay claim was dismissed for a reason other than mootness.
Read by a model
A separate Order dismissing the complaint will issue. |
| Prevailing party |
Government
Read by a model
For the reasons stated, the Court will grant Defendants’ motion to dismiss. |
| The delay claim |
Dismissed
Read by a model
Accordingly, the Court will follow Karimova’s lead on that point as well, and grant Defendants’ motion to dismiss for failure to state a claim. |
| Months pending | Not stated Read by a model |
| 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
Plaintiffs have failed to establish that Defendants have a crystal-clear, nondiscretionary duty to take further action on their visa applications that have been placed in administrative processing following their refusal under Section 221(g). |
| Nationality |
Russia
Read by a model
are Russian and Belarusian nationals seeking either F -1 or J -1 nonimmigrant visas. |
How the case ended
- Docket
- No. 1:25-cv-04315
- Filed
- December 12, 2025
- Ended
- June 3, 2026
- Suit's filing to its end
- 173 days
- How it ended
- Ended, outcome not recorded
- From the record
- idb disp 6 (judgment: motion before trial), judgment for unknown
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 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.
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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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Saavedra Bruno v. Albright, 197 F.3d 1153
D.C. Circuit, December 3, 1999. Consular visa decisions are not subject to judicial review absent an express statutory grant, and the APA does not displace that doctrine.
ImmCite: treatment available, history exists, not clearance
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Baan Rao Thai Restaurant v. Pompeo, 985 F.3d 1020
D.C. Circuit, January 22, 2021. Consular nonreviewability bars a federal court from second-guessing a consular officer's decision to issue or withhold a visa, and dismissal on that ground is a merits ruling rather than a jurisdictional one.
ImmCite: treatment available, history exists, not clearance. ImmCite has read all 3 published decisions citing this case, as of 2026-10-29; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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Pietersen v. Department of State, 138 F.4th 552
D.C. Circuit, May 30, 2025. Consular nonreviewability does not bar a forward-looking APA challenge to generally applicable State Department guidance, as distinct from review of an individual visa refusal.
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 24 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.
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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
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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
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Karimova v. Abate, No. 23-5178 (D.C. Cir. July 24, 2024) (unpublished judgment)
D.C. Circuit, July 24, 2024, nonprecedential. Neither § 555(b) nor any other law imposes a clear, nondiscretionary duty on a consular officer to re-adjudicate a visa application that was officially refused under § 1201(g) and placed in administrative processing, so mandamus and § 706(1) relief are unavailable.
ImmCite: not applicable, outside the precedential ImmCite corpus