Passim

Mandamus decisions / District of Massachusetts

Manshadi v. Laitinen

District of MassachusettsAllison D. BurroughsDecided February 18, 2025No. 1:24-cv-10118

Read the decisionOriginal on CourtListener

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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 State Read by a model
Assuming that the father provided the requested information, the plain terms of the regulation suggest that the Department of State has a duty to reconsider.
Form or filing 221(g) (consular refusal); DS-260 (immigrant visa) Read by a model
Plaintiff brings the instant suit against Defendants for failure to adjudicate her father’s visa application within a reasonable time.
What the suit asked for Finish 221(g) processing Read by a model
At issue here, however, is not whether the Court can review a final visa adjudication, but rather whether the Court can compel Defendants to adjudicate a visa application during administrative processing.
Kind of order A ruling on a motion or the petition Read by a model
For the following reasons, Defendants’ motion to dismiss, [ECF No. 12], is GRANTED.
Motion decided Motion to dismiss for failure to state a claim Read by a model
In a motion to dismiss under Rule 12(b)(6), the Court must accept as true all well-pleaded facts, analyze those facts in the light most favorable to the plaintiff, and draw all reasonable factual inferences in favor of the plaintiff.
Whose motion The government's motion Read by a model
Defendants moved to dismiss Plaintiff’s Complaint on April 5, 2024
Disposition Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model
In sum, the Court concludes that Plaintiff has failed to state a claim for unreasonable delay under the APA (Count I) and the MVA (Count II). Accordingly, Counts I and II are dismissed.
Prevailing party Government Read by a model
For the following reasons, Defendants’ motion to dismiss, [ECF No. 12], is GRANTED.
The delay claim Dismissed Read by a model
Accordingly, Counts I and II are dismissed.
The other claims Dismissed Read by a model
Plaintiff’s due process claim (Count III) is thus dismissed.
Months pending 10.5 months from the application to the suit; 24.1 months from the application to the court's decision Read by a model
in February 2023, the father had a consular interview at the U.S. Embassy in Armenia.
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 government
  • 4. Competing prioritiesfavors the government
  • 5. Interests prejudicedfavors the government
  • 6. No impropriety neededneutral
Read by a model
Neither factor supports a finding of unreasonable delay here.
The government's delay arguments First-in, first-out processing accepted; Line-jumping accepted Read by a model
As to the first factor, for visa applications, courts have generally found that an agency’s process is governed by a “rule of reason,” namely adjudicating them “in the order they were filed.”
Threshold rulings None Read by a model
Nationality Iran Read by a model
her father, Seyyed Mahdi Hosseini Khah Manshadi (“father”), an Iranian citizen
I-130 category Immediate relative Read by a model
Plaintiff is a U.S. citizen and resides in Westwood, Massachusetts. [Compl. ¶ 11]. In December 2019, she filed an I-130 visa petition on behalf of her father

How the case ended

Docket
No. 1:24-cv-10118
Filed
January 15, 2024
Ended
February 19, 2025
Suit's filing to its end
401 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.