Mandamus decisions / District of Columbia

Lozada Colon v. US Dept. of State

District of ColumbiaDecided April 23, 1998No. 1:97-cv-01831

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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.

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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 Thus in August of 1997, Plaintiff filed a Petition for a Writ of Mandamus asking this Court to compel the State Department to make a decision as to Plaintiff's renunciation of citizenship.
Form or filing	None named Read by a model
What the suit asked for	Decide the application Read by a model In August of 1997, Plaintiff filed a Petition for a Writ of Mandamus to compel a decision by the Department of State on his application for a Certificate of Loss of Nationality ("CLN").
Kind of order	A ruling on a motion or the petition Read by a model Accordingly, it is hereby ORDERED that Defendants' Motion to Dismiss is GRANTED.
Motion decided	Other motion to dismiss Read by a model This matter comes before the Court on Defendants' Motion to Dismiss.
Whose motion	The government's motion Read by a model This matter comes before the Court on Defendants' Motion to Dismiss.
Disposition	Dismissed The case or every delay claim was dismissed for a reason other than mootness. Read by a model Accordingly, it is hereby ORDERED that Defendants' Motion to Dismiss is GRANTED.
Prevailing party	Government Read by a model Accordingly, it is hereby ORDERED that Defendants' Motion to Dismiss is GRANTED.
The delay claim	Moot: the agency acted Read by a model Thus, the Department contends that the case has become moot; there no longer remains any action to be taken by the State Department as requested by Plaintiff in his Petition before this Court.
The other claims	Dismissed Read by a model The approval, or disapproval, of the issuance of certification is committed by statute to the discretion of the Secretary and thus not subject to this Court's mandamus jurisdiction.
Months pending	16.1 months from the application to the agency's action Read by a model On January 27, 1998, the Secretary of State disapproved Plaintiff's renunciation and declined to issue a Certificate of Loss of Nationality.
TRAC factors	The court did not weigh the TRAC factors Read by a model
Threshold rulings	None Read by a model
Nationality	United States Read by a model Plaintiff, a United States Citizen born in Puerto Rico

How the case ended

Docket: No. 1:97-cv-01831
Filed: August 13, 1997
Ended: April 20, 1998
Suit's filing to its end: 250 days
How it ended: Dismissed on jurisdiction or the merits
From the record: idb disp 3 (dismissed: lack of jurisdiction)

A voluntary or stipulated dismissal is how most suits end once the agency acts; the docket rarely says why.

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 14, 2026. Check the current status before relying on one.

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
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
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
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
Saavedra Bruno v. Albright, 197 F.3d 1153

D.C. Circuit, December 3, 1999. Consular visa decisions are not subject to judicial review absent an express statutory grant, and the APA does not displace that doctrine.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 18 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.
Baan Rao Thai Restaurant v. Pompeo, 985 F.3d 1020

D.C. Circuit, January 22, 2021. Consular nonreviewability bars a federal court from second-guessing a consular officer's decision to issue or withhold a visa, and dismissal on that ground is a merits ruling rather than a jurisdictional one.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 3 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.
Pietersen v. Department of State, 138 F.4th 552

D.C. Circuit, May 30, 2025. Consular nonreviewability does not bar a forward-looking APA challenge to generally applicable State Department guidance, as distinct from review of an individual visa refusal.

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 24 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.
Telecommunications Research & Action Center v. FCC, 750 F.2d 70

D.C. Circuit, October 24, 1984. Whether agency delay is unreasonable turns on six factors: a rule of reason, any statutory timetable, the human welfare interests at stake, the effect of expediting on competing priorities, the interests prejudiced by delay, and no need to find impropriety.

ImmCite: treatment available, history exists, not clearance
Mashpee Wampanoag Tribal Council, Inc. v. Norton, 336 F.3d 1094

D.C. Circuit, August 8, 2003. A claim that an agency has unreasonably delayed a matter arises under the APA and § 1331, and the TRAC factors decide whether the delay is unreasonable.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 11 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.
In re Core Communications, Inc., 531 F.3d 849

D.C. Circuit, July 8, 2008. Mandamus to compel unreasonably delayed agency action is an extraordinary remedy guided by the TRAC factors, granted here after years of unexplained delay.

ImmCite: treatment available, history exists, not clearance. ImmCite has read all 9 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.