Passim

Mandamus decisions / District of Columbia

ADAN v. BURNS

District of ColumbiaJames E. BoasbergDecided August 13, 2026No. 1:26-cv-00864

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
Still, because the State Department is subject to the APA, its officers cannot drag their feet forever; they must “conclude a matter presented to” them “within a reasonable time.”
Form or filing 221(g) (consular refusal); DS-260 (immigrant visa) Read by a model
Plaintiff Mohamud Abdow Adan is a Kenyan citizen residing in Nairobi who seeks an immigrant visa so that he may join his U.S.-citizen wife, Hibo Abdirahman Mohamed, in the United States as a lawful permanent resident.
What the suit asked for Finish 221(g) processing Read by a model
Adan’s claim under § 706(1) of the APA seeks to “compel agency action” — here, finishing administrative processing — that has been “unreasonably delayed.”
Kind of order A ruling on a motion or the petition Read by a model
The Court will therefore grant Defendants’ Motion to Dismiss.
Motion decided Motion to dismiss for failure to state a claim Read by a model
Defendants’ Motion invokes the legal standards for dismissal under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6).
Whose motion The government's motion Read by a model
Defendants have now moved to dismiss, which Motion the Court will grant.
Disposition Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model
The Court will therefore grant Defendants’ Motion to Dismiss.
Prevailing party Government Read by a model
The Court will therefore grant Defendants’ Motion to Dismiss.
The delay claim Dismissed Read by a model
The Court will therefore grant Defendants’ Motion to Dismiss.
Months pending 28.1 months from the application to the court's decision Read by a model
he completed his visa interview on April 9, 2024, at the U.S. Embassy in Kenya.
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
The first two factors thus favor Defendants.
The government's delay arguments Line-jumping accepted Read by a model
While factors (3) and (5) tilt toward Plaintiff, they cannot overcome the fact that the length of delay is reasonable as a matter of law and that letting Adan jump the line would simply push others back.
Threshold rulings Consular nonreviewability rejected Read by a model
For the same reasons that this Court rejected those arguments in Dib mere months ago, they fail here, too. See 2026 WL 1578859, at *3. The Court may therefore proceed to the merits.
Nationality Kenya Read by a model
Plaintiff Mohamud Abdow Adan is a Kenyan citizen residing in Nairobi
I-130 category Immediate relative Read by a model
Plaintiff Mohamud Abdow Adan is a Kenyan citizen residing in Nairobi who seeks an immigrant visa so that he may join his U.S.-citizen wife, Hibo Abdirahman Mohamed, in the United States as a lawful permanent resident.

How the case ended

Docket
No. 1:26-cv-00864
Filed
March 12, 2026
Status
Pending as of the last docket check

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.