Akrayi v. United States Department of State

CourtDistrict Court, District of Columbia
DecidedMarch 9, 2023
DocketCivil Action No. 2022-1289
StatusPublished

This text of Akrayi v. United States Department of State (Akrayi v. United States Department of State) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Akrayi v. United States Department of State, (D.D.C. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

ARI AKRAYI,

Plaintiff,

v. Case No. 22-cv-1289 (CRC)

UNITED STATES DEPARTMENT OF STATE et. al.,

Defendants.

MEMORANDUM OPINION

Plaintiff Ari Akrayi, a United States citizen, has been waiting nearly three years for the

government to adjudicate his Iraqi wife’s U.S. visa application. Claiming unreasonable delay

under the Administrative Procedure Act (“APA”), he filed this suit to compel the State

Department to do so. Akrayi also challenges an internal Department of Homeland Security

(“DHS”) initiative—the Controlled Application Review and Resolution Program (“CARRP”)—

that applies heightened screening to visa applications with potential national security concerns.

Because Akrayi has not met his burden to plausibly allege an unreasonable delay, a violation of

his due process rights, or a concrete injury due to CARRP, the Court will grant the government’s

motion to dismiss the complaint.

I. Background

Mr. Akrayi filed an I-130 visa petition in April 2019 to obtain lawful permanent resident

status for his wife, Zhala Ibrahim Jameel, an Iraqi citizen. Compl. ¶¶ 2, 11, 13–15. Almost a

year later, in March 2020, the United States Citizenship and Immigration Services (“USCIS”)

approved the petition. Id. ¶ 15. Akrayi’s petition was then processed by the National Visa

Center (“NVC”), which forwarded the case to the U.S. Embassy in Abu Dhabi. Id. ¶ 16. Jameel has yet to be interviewed by the Embassy. See id. ¶¶ 17–18. Akrayi has repeatedly attempted to

obtain a decision from USCIS, including contacting the NVC numerous times. Id. ¶ 19. But to

no avail. Id.

Akrayi further alleges “[o]n information and belief” that the government is intentionally

delaying a response to Jameel’s visa application through CARRP. Compl. ¶¶ 25–30. The

complaint describes CARRP as an internal DHS policy that flags visa applications that present

potential national security concerns and directs field officers to deny the applications or at least

delay their adjudication. Id. ¶¶ 25, 28. But by casting too wide a net, Akrayi claims, the CARRP

policy errs by labeling “innocent, law-abiding” residents, like Jameel, as “national security

concerns.” Id. ¶ 29. Akrayi also asserts that CARRP targets applications from predominantly

Muslim countries. See id. ¶¶ 26, 30.

In May 2022, Akrayi brought suit against several government officials and agencies

under the APA’s unreasonable delay provision, 5 U.S.C. § 706(1), and the Mandamus Act, 28

U.S.C. § 1361. He requests an order directing the government to process Jameel’s visa

application within sixty days and issue her an immigrant visa, and seeks declaratory and

injunctive relief as to CARRP. The government moved to dismiss the complaint for failure to

state a claim under Federal Rule of Civil Procedure 12(b)(6).

II. Legal Standards

To survive a Rule 12(b)(6) motion, “a complaint must contain sufficient factual matter,

accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ramirez v. Blinken, 594

F. Supp. 3d 76, 85 (D.D.C. 2022) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). At this

stage, courts must “accept all the well-pleaded factual allegations of the complaint as true and

draw all reasonable inferences from those allegations in the plaintiff’s favor.” Banneker

2 Ventures, LLC v. Graham, 798 F.3d 1119, 1129 (D.C. Cir. 2015). But a court need not accept a

plaintiff’s legal conclusions. Browning v. Clinton, 292 F.3d 235, 242 (D.C. Cir. 2002). “In

determining whether a complaint fails to state a claim, [a court] may consider only the facts

alleged in the complaint, any documents either attached to or incorporated in the complaint and

matters of which [the court] may take judicial notice.” EEOC v. St. Francis Xavier Parochial

Sch., 117 F.3d 621, 624 (D.C. Cir. 1997).

III. Analysis

The government contends first that all of Akrayi’s claims are barred by the doctrine of

consular non-reviewability. After rejecting this contention, the Court will turn to each claim:

(1) unreasonable delay under the APA and Mandamus Act, (2) violation of due process, and (3)

the challenge to CARRP.

A. Consular Non-Reviewability

The doctrine of consular non-reviewability “shields a consular official’s decision to issue

or withhold a visa from judicial review, at least unless Congress says otherwise.” Baan Rao Thai

Rest. v. Pompeo, 985 F.3d 1020, 1024 (D.C. Cir. 2021) (quoting Saavedra Bruno v. Albright,

197 F.3d 1153, 1159 (D.C. Cir. 1999)). As recently clarified by the D.C. Circuit, dismissal

pursuant to the consular non-reviewability doctrine “is a merits disposition under [Rule]

12(b)(6).” Id. at 1027. While the doctrine “clearly applies to final visa determinations,” it “does

not apply to challenges regarding decisions that are not yet final.” Joorabi v. Pompeo, 464 F.

Supp. 3d 93, 100 (D.D.C. 2020).

This Court has consistently held that the doctrine of consular non-reviewability does not

bar claims that the “Government has unreasonably delayed rendering a decision.” Didban v.

Pompeo, 435 F. Supp. 3d 168, 174 (D.D.C. 2020) (Cooper, J.) (holding that consular non-

3 reviewability does not bar review of the government’s failure to decide an application); see also

Giliana v. Blinken, 596 F. Supp. 3d 13, 18 (D.D.C. 2022) (Cooper, J.) (“[C]laims alleging

unreasonable delay . . . are not barred by the doctrine of consular nonreviewability.” (cleaned

up)). This case is no different. Akrayi challenges USCIS’s delay in rendering a decision, and

“not an actual final decision made by a consular officer.” Id. at 19.

The government nonetheless contends that the D.C. Circuit’s decision in Baan Rao Thai

Rest. v. Pompeo bars review here. 985 F.3d at 1024. Not so. Baan Rao held that the doctrine of

consular non-reviewability prevents judicial review of a consular office’s decision to “issue or

withhold” a visa. Id. at 1024–25. Challenging a delay in processing a visa is distinguishable

from challenging a decision to “withhold a visa.” While Baan Rao bars review of the latter, it is

silent as to the former. See Al-Gharawy v. U.S. Dep’t of Homeland Sec., No. 21-1521, 2022

WL 2966333, at *8 (D.D.C. July 27, 2022) (noting that the word “withhold” can imply an active

or passive state of affairs, but that Baan Rao concerned an active visa denial rather than a

“temporary or passive refusal”); Sawahreh v. U.S. Dep’t of State, No. 22-1456, 2022 WL

4365746, at *3–4 (D.D.C. Sept. 21, 2022) (rejecting argument that Baan Rao’s use of the word

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