Mandamus decisions / Western District of Washington
Ahmed v. United States Department of State
Read the decisionOriginal on CourtListener
2,917 written decisions from 2,664 cases in the whole mandamus and agency-delay group, the group's newest decided October 30, 2026. Updated November 3, 2026 at 7:07 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 1,606 public decisions since January 1, 2025 that a CourtListener and GovInfo search for mandamus and agency delay finds, Passim holds 1,371 (85%), measured November 3, 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
Plaintiffs also seek to compel the State Department to issue a final decision on certain of the Plaintiffs’ visa applications, which Plaintiffs claim have been stuck in administrative limbo for an unreasonable time. |
|---|---|
| Form or filing |
221(g) (consular refusal); DS-260 (immigrant visa)
Read by a model
Each is seeking a family-based immigrant visa, either for themselves or their immediate relative. |
| What the suit asked for |
Finish 221(g) processing
Read by a model
Plaintiffs’ first two causes of action challenge the State Department’s allegedly unreasonable delay in processing their visa cases and seek relief under the APA and Mandamus Act compelling a final decision on the applications. |
| Kind of order |
A ruling on a motion or the petition
Read by a model
The Government’s motion to dismiss (Dkt. No. 9) is GRANTED in part and DENIED in part. |
| Motion decided |
Motion to dismiss for failure to state a claim
Read by a model
In evaluating a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) |
| Whose motion |
The government's motion
Read by a model
The Government’s motion to dismiss (Dkt. No. 9) is GRANTED in part and DENIED in part. |
| Disposition |
Dismissed in part; some claims go on
The government's motion to dismiss was granted in part: some claims were dismissed and others go on.
Read by a model
Counts I and II of the Complaint are DISMISSED without prejudice and without leave to amend. |
| Prevailing party |
Each side in part
Read by a model
Counts I and II of the Complaint are DISMISSED without prejudice and without leave to amend. |
| The delay claim |
Dismissed
Read by a model
Counts I and II of the Complaint are DISMISSED without prejudice and without leave to amend. |
| The other claims |
Some dismissed, some go on
Read by a model
Count V of the Complaint is DISMISSED without prejudice and with leave to amend. (3) The motion is otherwise DENIED. |
| Months pending |
38 months from the application to the suit; 46.3 months from the application to the court's decision
Read by a model
attended a visa interview on November 1, 2022, at the U.S. embassy in Addis Ababa. |
| TRAC factors |
The court weighed the TRAC factors
At this point, the State Department’s delay has been between eleven and fifteen months since its most recent action in each case, and this length of time is generally not found to be unreasonable. |
| Threshold rulings |
Consular nonreviewability rejected; Duty to re-adjudicate a 221(g) refusal found
Read by a model
Accordingly, Plaintiffs’ APA and mandamus claims challenging the allegedly unreasonable delay in adjudicating their visas are not subject to consular nonreviewability. |
| Nationality |
Somalia
Read by a model
a Somali national residing in Ethiopia. |
| 212(f) proclamation |
Proclamation 10998
Read by a model
Then, in March 2026, Hussein received an email refusing his visa application on the ground that he is ineligible for a visa under Proclamation 10998 and Section 212(f) of the INA. |
| I-130 category |
Immediate relative
Read by a model
Each is seeking a family-based immigrant visa, either for themselves or their immediate relative. |
How the case ended
- Docket
- No. 2:25-cv-02754
- Filed
- December 31, 2025
- 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 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 3, 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 2026-10-31; 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 2026-11-03; it checks for new citing decisions daily. That is not a determination that the case is good law. The citation index lists 144 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.