Aceves Lobatos v. Noem

CourtDistrict Court, N.D. Illinois
DecidedJune 11, 2025
Docket1:25-cv-01223
StatusUnknown

This text of Aceves Lobatos v. Noem (Aceves Lobatos v. Noem) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aceves Lobatos v. Noem, (N.D. Ill. 2025).

Opinion

THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION JOSEPH ACEVES LOBATOS, et al. ) ) ) No. 25 C 01223 Plaintiffs, ) ) Chief Judge Virginia M. Kendall v. ) ) ) KRISTI NOEM, in her official capacity as ) Secretary of Homeland Security, et al. ) ) Defendants. )

MEMORANDUM OPINION & ORDER Plaintiffs Jose Aceves Lobatos and Angeles Sanchez Rubio brought these claims against Defendants Kristi Noem, Secretary of Homeland Security, and Andrew Davidson, Deputy Director, U.S. Citizenship Immigration Services (“USCIS”), in their official capacities, under the Administrative Procedure Act, 5 U.S.C. § 706(1), and the Mandamus Act, 28 U.S.C. § 1361. Plaintiffs request that the Court direct USCIS to adjudicate Lobatos’s I-918 Petition for U Nonimmigrant status and Rubio’s Form I-918A derivative petition. Defendants move to dismiss, arguing that the Court lacks subject matter jurisdiction and, alternatively, that Plaintiffs fail to state a claim. For the following reason, the Court grants Defendants’ Motion. [6]. BACKGROUND I. Statutory Scheme: U Visa Petitions In 2000, Congress created the “U nonimmigrant status” visa classification (“U Visa”) for noncitizen victims of qualifying crimes who cooperate with law enforcement investigations of those crimes. 8 U.S.C. § 1101(a)(15)(U). Acquiring a U Visa enables the noncitizen victim and qualifying family members to receive temporary immigration benefits. U.S. Citizenship & Immigra. Servs., Victims of Criminal Activity: U Nonimmigrant Status, https://www.uscis.gov/humanitarian/victims-of-criminal-activity-u-nonimmigrant-status. When DHS grants a noncitizen U Visa nonimmigrant status, it provides the person with employment

authorization documents (“EADs”) pursuant to 8 U.S.C. § 1184(p)(3)(B). See also 8 C.F.R. § 214.14(c)(7). Congress limited the number of U Visas that can be awarded to 10,000 per fiscal year. 8 U.S.C. § 1184(p)(2). Individuals who, due solely to the 10,000-visa cap, are not granted a U Visa are placed on a waiting list. 8 C.F.R. § 214.14(d)(2). Petitioners on the waiting list receive final adjudication for their U visas in future years in accordance with the statutory cap, with the oldest petitions receiving priority. Id.; U.S. Citizenship & Immigr. Servs., Policy Manual Vol. 3, Part C, Ch. 7. While a petitioner is on the waiting list, “USCIS will grant deferred action or parole” to such petitioner and “in its discretion, may authorize employment” for such petitioner. 8 C.F.R. § 214.14(d)(2). Separately, since June 2021, the Secretary of Homeland Security “may grant work authorization to any alien who has a pending, bona fide [U Visa petition]” via a two-step process.1

8 U.S.C. § 1184(p)(6); U.S. Citizenship & Immigr. Servs., Policy Manual, Volume 3, Part C, Chapter 5 – Bona Fide Determination Process, https://www.uscis.gov/policy-manual/volume-3- part-c-chapter-5 (hereinafter USCIS Policy Manuel Ch. 5). At step one, DHS makes a “Bona Fide Determination” (BFD) regarding the petitioner’s U Visa status. At step two, DHS then assesses “whether the petitioner poses a risk to national security or public safety and otherwise merits a

1 According to the USCIS website, “[t]he bona fide determination process was created with the goal of conducting initial reviews of U nonimmigrant status petitions more efficiently and providing eligible victims of qualifying crimes with employment authorization and deferred action while they await a final adjudication of their petition for U nonimmigrant status under the annual statutory cap.” https://www.uscis.gov/records/electronic-reading- room/national-engagement-u-visa-and-bona-fide-determination-process-frequently-asked-questions. favorable exercise of discretion.” USCIS Policy Manuel Ch. 5. If DHS makes a favorable determination at this second step, then it will provide the petitioner EAD and deferred action. Id. This two-step process is known as the BFD Process. Id. II. Facts of Lobatos’s Petition

Plaintiffs seek to compel DHS to (1) adjudicate the Petition, (2) complete the BFD Process or, alternatively, (3) place Plaintiffs on the waiting list. The relevant facts, taken from Plaintiffs’ Complaint, are as follows: In October 2023, Plaintiff Jose Aceves Lobatos was a victim of felonious assault and armed robbery in Chicago, Illinois. (Dkt. 1 ¶ 24). He was driving with a coworker when two unknown men approached his vehicle with guns and demanded money. (Id.) Lobatos obtained law enforcement certification from the police department in Chicago, Illinois that he cooperated with law enforcement to the best of his ability. (Id. ¶ 25). On February 26, 2024, Lobatos filed Form I-918, Petition for U Nonimmigrant Status with the U.S. Department of Homeland Security and U.S. Citizenship & Immigration Services (USCIS). (Id. ¶ 26). He included his wife, Plaintiff Angeles Sanchez Rubio

as a derivative (Form I-918A), qualifying family member in his Petition. (Id.) Lobatos’s U Visa Petition was accorded receipt number EAC2412550205. (Id. ¶ 27). His Petition has been pending for 14 months. (Id. ¶ 26). Since submitting the Petition for U nonimmigrant status, Lobatos has inquired multiple times regarding its adjudication status. (Id. ¶ 27). To date, Lobatos and Rubio have been informed only that their case is still being processed or under further review. (Id. ¶ 28). Plaintiffs have received no communication regarding final adjudication of the petition, nor have they been instructed to provide any further information or documentation to USCIS. (Id. ¶ 30). Lobatos and Rubio request that the Court compel Defendants and those acting under them to perform their duty or duties to adjudicate the Petition for U Nonimmigrant Status or else place them on deferred action. (Dkt. 1 at 9). Lobatos and Rubio also request the Court to compel Defendants to perform their duties to adjudicate the applications for work authorization. (Id. at 9–

10). DISCUSSION Secretary Noem makes three discrete arguments in her Motion to Dismiss. (Dkt. 7). First, the Secretary argues that the Court lacks subject-matter jurisdiction under the Immigration & Nationality Act (“INA”) to review U Visa Petitions. (Id. at 6). Second, the Secretary contends that even if the Court has jurisdiction, Plaintiffs fail to meet the “unreasonable delay” standard under the APA. (Id. at 8). Finally, she claims that Lobatos and Rubio’s mandamus claim also fails because Plaintiffs have no right to adjudication within a certain timeframe. (Id. at 11). I. Subject Matter Jurisdiction Over Adjudicating U Visa Petition a. The Parties’ Positions

The Secretary first argues that the Court should dismiss Plaintiffs’ request for the USCIS to expedite its decision over whether to grant them work authorization, which would include completing the BFD Process, because the Court lacks subject-matter jurisdiction. (Id. at 6). Rule 12(b)(1) requires the Court to dismiss a claim if it does not have subject-matter jurisdiction. Fed. R. Civ. P.

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Aceves Lobatos v. Noem, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aceves-lobatos-v-noem-ilnd-2025.