Passim

Mandamus decisions / District of Massachusetts

Ghannad-Rezaie v. Laitinen

District of MassachusettsPatti B. SarisDecided November 21, 2024No. 1:24-cv-11665

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What the decision decided

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Agency Department of State Read by a model
Plaintiff Mostafa Ghannad-Rezaie brings this petition for a writ of mandamus to compel the Department of State (“DOS”) to act on the immigrant visa applications of his parents who are citizens of Iran.
Form or filing 221(g) (consular refusal); DS-260 (immigrant visa) Read by a model
Plaintiff Mostafa Ghannad-Rezaie brings this petition for a writ of mandamus to compel the Department of State (“DOS”) to act on the immigrant visa applications of his parents who are citizens of Iran.
What the suit asked for Finish 221(g) processing Read by a model
Rather, he alleges that the DOS must re-adjudicate the applications following administrative processing and has unreasonably delayed doing so.
Kind of order A ruling on a motion or the petition Read by a model
After hearing, the Court ALLOWS the DOS’s motion to dismiss (Dkt. 9).
Motion decided Motion to dismiss for failure to state a claim Read by a model
To survive a Rule 12(b)(6) motion to dismiss for failure to state a claim, a complaint must allege “a plausible entitlement to relief.”
Whose motion The government's motion Read by a model
The DOS moves to dismiss the complaint under Federal Rules of Civil Procedure 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
After hearing, the Court ALLOWS the DOS’s motion to dismiss (Dkt. 9).
Prevailing party Government Read by a model
After hearing, the Court ALLOWS the DOS’s motion to dismiss (Dkt. 9).
The delay claim Dismissed Read by a model
For this reason, the Court dismisses Ghannad- Rezaie’s claims under the APA and the MVA (Counts I and II).
The other claims Dismissed Read by a model
Ghannad-Rezaie’s due process claim (Count III) is therefore dismissed.
Months pending 13.9 months from the application to the court's decision Read by a model
On September 25, 2023, a consular officer interviewed the parents, refused their applications under INA § 221(g), and placed the applications into administrative processing.
TRAC factors The court weighed the TRAC factors
  • 1. Rule of reasonfavors the government
  • 2. Congressional timetablefavors the applicant
  • 3. Human health and welfarefavors the applicant
  • 4. Competing prioritiesneutral
  • 5. Interests prejudicedfavors the applicant
  • 6. No impropriety neededfavors the government
Read by a model
Courts have held at this stage that delays of similar length following a refusal under INA § 221(g) do not support a plausible claim for relief.
Threshold rulings Consular nonreviewability rejected; Duty to re-adjudicate a 221(g) refusal found Read by a model
The Court holds that the doctrine of consular nonreviewability does not preclude claims to compel the DOS to adjudicate a visa application when it has a nondiscretionary duty to do so because a claim of unreasonable delay does not seek judicial review of a consular decision to deny a visa.
Nationality Iran Read by a model
Plaintiff Mostafa Ghannad-Rezaie brings this petition for a writ of mandamus to compel the Department of State (“DOS”) to act on the immigrant visa applications of his parents who are citizens of Iran.
I-130 category Immediate relative Read by a model
In January 2021, Ghannad-Rezaie, a U.S. citizen, petitioned USCIS to classify his Iranian citizen parents as qualifying relatives.

How the case ended

Docket
No. 1:24-cv-11665
Filed
June 27, 2024
Ended
November 22, 2024
Suit's filing to its end
148 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 First 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.