Mandamus decisions / Central District of California
Zahra Qubadi v. Rena Bitter
Read the decisionOriginal on CourtListener
2,996 written decisions from 2,731 cases in the whole mandamus and agency-delay group, the group's newest decided November 12, 2026. Updated November 14, 2026 at 1:17 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 1,617 public decisions since January 1, 2025 that a CourtListener and GovInfo search for mandamus and agency delay finds, Passim holds 1,406 (87%), 1,039 of them in this group, measured November 14, 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
On multiple occasions since his interview, the Embassy has requested that Beneficiary submit an Administrative Processing Questionnaire(the “Questionnaire”). |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-260 (immigrant visa)
Read by a model
This action arises from Plaintiff’s claims for declaratory relief and a writ of mandamus seeking an order for Defendants to adjudicate her spouse Mohammad Reza Hosseini’s (“Beneficiary”) Form I-130 immigrant visa application. |
| What the suit asked for |
Finish 221(g) processing
Read by a model
Here, as Plaintiff clarifies, she is not challenging a consular officer’s decision, but rather asking the Court to require Defendants to render a final decision. |
| Kind of order |
A ruling on a motion or the petition
Read by a model
Having considered the papers, the Court DENIES Defendants’ motion to dismiss. |
| Motion decided |
Motion to dismiss for lack of jurisdiction; Motion to dismiss for failure to state a claim
Read by a model
Defendants now move to dismiss the action under to Federal Rules of Civil Procedure (“Rule”) 12(b)(1) and 12(b)(6). |
| Whose motion |
The government's motion
Read by a model
Proceedings: (In Chambers) Order DENYING Defendants’ motion to dismiss (Dkt. 28) |
| Disposition |
Government's motion denied; the case goes on
The government's motion (to dismiss, or for summary judgment) was denied, so the case goes on. Counted as the applicant's ruling; a later decision in the case can still go either way.
Read by a model
For the foregoing reasons, the Court DENIES Defendants’ motion to dismiss. |
| Prevailing party |
Applicant
Read by a model
For the foregoing reasons, the Court DENIES Defendants’ motion to dismiss. |
| The delay claim |
The delay claim goes on
Read by a model
For the foregoing reasons, the Court DENIES Defendants’ motion to dismiss. |
| Months pending |
3 months from the application to the suit; 8.8 months from the application to the court's decision
Read by a model
On August 22, 2024, Beneficiary was noticed of his consular interview in Oman on October 22, 2024, for which he appeared. |
| TRAC factors | The court did not weigh the TRAC factors Read by a model |
| Threshold rulings |
Consular nonreviewability rejected; Duty to re-adjudicate a 221(g) refusal found
Read by a model
Accordingly, as alleged in the complaint, the doctrine of consular nonreviewability is not triggered as the consular officer has not fully adjudicated Beneficiary’s visa application. |
| Nationality |
Iran
Read by a model
for Beneficiary, an Iranian national. |
| I-130 category |
Immediate relative
Read by a model
her spouse Mohammad Reza Hosseini’s (“Beneficiary”) Form I-130 immigrant visa application. See Dkt. # 1 (“Compl.”). The complaint alleges as follows On March 15, 2022, Plaintiff, a United States Citizen, |
How the case ended
- Docket
- No. 2:25-cv-00500
- Filed
- January 20, 2025
- Ended
- November 24, 2025
- Suit's filing to its end
- 308 days
- How it ended
- Ended once the agency acted
- From the record
- stipulated dismissal 2025-11-24; idb disp 12 (dismissed: voluntarily)
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 14, 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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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 2026-11-13; none treats it adversely. That describes those decisions; it is not a determination that the case is good law.
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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.
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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
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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 2026-11-10; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 145 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.