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Mandamus decisions / Northern District of Illinois

Patel v. Noem

Northern District of IllinoisElaine E. BuckloDecided June 26, 2025No. 1:25-cv-00657

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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 USCIS Read by a model
Specifically, Patel wants USCIS to make what is known as a “bona fide determination,” decide whether he should be placed on a waiting list for a U-Visa, or decide whether he is otherwise entitled to receive work authorization while his petition is pending.
Form or filing I-918 (U visa) Read by a model
He submitted his U- Visa petition in June 2023, but to date no decision has been made.
What the suit asked for Decide the application Read by a model
At points in his response brief, Patel suggests that USCIS must adjudicate his U-Visa application as a whole.
Kind of order A ruling on a motion or the petition Read by a model
For the foregoing reasons, USCIS’s motion to dismiss is granted on Rule 12(b)(6) grounds with respect to Patel’s claim that he is entitled to a waitlist determination; it is otherwise granted under Rule 12(b)(1).
Motion decided Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim Read by a model
For the foregoing reasons, USCIS’s motion to dismiss is granted on Rule 12(b)(6) grounds with respect to Patel’s claim that he is entitled to a waitlist determination; it is otherwise granted under Rule 12(b)(1).
Whose motion The government's motion Read by a model
USCIS moves to dismiss the complaint for lack of subjectmatter jurisdiction and for failure to state a claim under Rules 12(b)(1) and 12(b)(6).
Disposition Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model
For the foregoing reasons, USCIS’s motion to dismiss is granted on Rule 12(b)(6) grounds with respect to Patel’s claim that he is entitled to a waitlist determination; it is otherwise granted under Rule 12(b)(1).
Prevailing party Government Read by a model
For the foregoing reasons, USCIS’s motion to dismiss is granted on Rule 12(b)(6) grounds with respect to Patel’s claim that he is entitled to a waitlist determination; it is otherwise granted under Rule 12(b)(1).
The delay claim Dismissed Read by a model
For the foregoing reasons, USCIS’s motion to dismiss is granted on Rule 12(b)(6) grounds with respect to Patel’s claim that he is entitled to a waitlist determination; it is otherwise granted under Rule 12(b)(1).
Months pending 24.4 months from the application to the court's decision Read by a model
Here, Patel alleges he submitted his application on June 13, 2023.
TRAC factors The court weighed the TRAC factors
  • 1. Rule of reasonfavors the government
  • 2. Congressional timetablefavors the government
  • 3. Human health and welfarefavors the applicant
  • 4. Competing prioritiesfavors the government
  • 5. Interests prejudicedfavors the applicant
  • 6. No impropriety neededneutral
Read by a model
Thus, the first factor favors USCIS.
The government's delay arguments First-in, first-out processing accepted; Line-jumping accepted Read by a model
A standard ‘first-in, first-out’ process has been recognized as logical and reasonable under the TRAC analysis.
Threshold rulings Section 1252(a)(2)(B) bar applied; Section 1252(a)(2)(B) bar rejected Read by a model
The use of the word “may” triggers § 1252(a)(2)(B)(ii)’s denial of jurisdiction.
U visa claims Final decision: dismissed; Bona fide determination: dismissed under 1252(a)(2)(b); Work permit: dismissed under 1252(a)(2)(b); Waiting list: dismissed Read by a model
Therefore, the discussion and disposition below with respect to Patel’s waitlist determination demand applies with equal force to his demand that USCIS adjudicate his U-Visa application.
Nationality India Read by a model
Ronakkumar Patel, a citizen of India, applied for a U-Visa

How the case ended

Docket
No. 1:25-cv-00657
Filed
January 20, 2025
Ended
June 26, 2025
Suit's filing to its end
157 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 Seventh 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.