Al Awbathani v. United States Consulate Toronto

CourtDistrict Court, E.D. Michigan
DecidedSeptember 18, 2025
Docket2:24-cv-11838
StatusUnknown

This text of Al Awbathani v. United States Consulate Toronto (Al Awbathani v. United States Consulate Toronto) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Al Awbathani v. United States Consulate Toronto, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

MAREAI SALEM AL AWBATHANI,

Plaintiff, Case No. 24-11838 v. HON. JONATHAN J.C. GREY

UNITED STATES DEPARTMENT OF STATE, et al.,

Defendants. _______________________________/ OPINION AND ORDER GRANTING DEFENDANTS’ MOTION TO DISMISS WITHOUT PREJUDICE (ECF No. 8)

I. INTRODUCTION On July 17, 2024, Plaintiff Mareai Salem Al Awbathani, a Lawrence Technological University international student, filed a complaint against the U.S. Department of State and U.S. Consulate in Toronto. (ECF No. 1.) Al Awbathani alleges that defendants have unreasonably delayed the adjudication of his F-1 student visa application and interrupted his graduate studies. (Id.) He seeks an order compelling defendants to promptly adjudicate his application pursuant to the Administrative Procedure Act (“APA”) and Mandamus Act. (Id.) Defendants move to dismiss Al Awbathani’s: (1) APA claim, under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim upon

which relief can be granted; and (2) mandamus claim, under Rule 12(b)(1) for lack of subject matter jurisdiction. (ECF No. 8.) The parties fully briefed the motion (ECF Nos. 8–10), and Al Awbathani filed a sur-reply

(ECF No. 11), which the Court has also considered. After reviewing the parties’ briefs, the Court finds that oral argument would not aid the Court; so, the Court decides the motion to dismiss on the record before it.

See E.D. Mich. L.R. 7.1(f)(2). For the following reasons, the Court GRANTS the motion to dismiss WITHOUT PREJUDICE. II. BACKGROUND

The Court begins with an overview of the F-1 visa process and then turns to the factual background and procedural history of the case. A. F-1 Visas

An F-1 visa is a nonimmigrant “student” visa that allows a foreign citizen to travel to the United States to study. 8 U.S.C. § 1101(a)(15)(F). To obtain an F-1 visa, an applicant must first apply to a

school approved by the U.S. Department of Homeland Security’s Student and Exchange Visitor Program (“SEVP-approved school”). See U.S. Dep’t of State, Student Visa, https://travel.state.gov/content/travel/en/us- visas/study/student-visa.html [https://perma.cc/Q4D5-RWSR] (last

visited Sept. 17, 2025). Upon acceptance to an SEVP-approved school, the applicant may apply for an F-1 visa by completing a Form DS-160 (the Online Nonimmigrant Visa Application), submitting biometric data, and

attending an interview with a consular officer. Id.; 8 U.S.C. § 1202(h). Following these steps, the consular officer must issue or refuse the visa. 22 C.F.R. § 41.121(a). An officer, however, can make an initial

determination and temporarily refuse to issue a visa under Section 221(g) of the Immigration and Nationality Act (“INA”), 8 U.S.C. § 1201(g), to allow for further administrative processing if the officer needs more

information or time to determine eligibility. See, e.g., Omar v. Blinken, 756 F. Supp. 3d 520, 531 (S.D. Ohio 2024) (finding jurisdiction over plaintiffs’ “lawsuit to compel the consul to make a decision on their visa

applications” after a Section 221(g) denial); Sawahreh v. U.S. Dep’t of State, 630 F. Supp. 3d 155, 157 (D.D.C. 2022) (explaining that a consular officer can “temporarily refuse to issue a visa” under INA § 221(g)); U.S.

Dep’t of State, Administrative Processing Information, https://travel.state.gov/content/travel/en/us-visas/visa-information- resources/administrative-processing-information.html [https://perma.cc/GYP2-H9MR] (last visited Sept. 17, 2025).

B. Plaintiff’s Application Al Awbathani is a Yemeni citizen and Canadian permanent resident. (ECF No. 1, PageID.1.) In December 2022, Al Awbathani was

issued an F-1 student visa to pursue a master’s degree at Lawrence Technological University in Southfield, Michigan. (Id.) During his time there, Al Awbathani excelled in his studies and earned recognition for his

academic achievements. (Id. at PageID.2, 12.) In April 2024, Al Awbathani applied for a renewal of his F-1 visa, and he appeared for an interview at the U.S. Consulate in Toronto on

April 10, 2024. (Id. at PageID.2, 13.) That same day, his visa application was refused “under section 221g of the Immigration and Nationality Act . . . for a legally mandated administrative review.” (Id. at PageID.15.) Al

Awbathani alleges that he submitted the supplemental questions requested by the U.S. Department of State (see id.), but his application has remained under administrative processing. (Id. at PageID.14; ECF

No. 12, PageID.129 (the government notified the Court in August 2025 that Al Awbathani’s visa application “remains refused under 8 U.S.C. § 1201(g), and additional security screening is ongoing”).) Al Awbathani planned to return to Lawrence Technological

University for the semester scheduled to begin on August 21, 2024, but he has been unable to return due to the ongoing administrative processing. (ECF No. 1, PageID.2.) On July 17, 2024, just over three

months after his interview and Section 221(g) denial, Al Awbathani filed this lawsuit. (See ECF No.1.) He raises an APA claim for unreasonable delay and seeks a writ of mandamus compelling defendants to promptly

adjudicate his F-1 student visa application. (Id. at PageID.2.) He has now missed three semesters since he filed his complaint. Al Awbathani alleges that the “unjustified” and “unwarranted” delay has “put [his] academic

progress at severe risk,” “placed [his] educational goals and future career at risk,” “caused significant personal and professional hardship,” and caused him to experience “increased depression, anxiety, and stress.” (Id.

at PageID.1–3.) He also alleges that his “severe chronic pain and mental health issues” have worsened after he had to halt treatment at the end of 2023 “due to border issues.” (Id. at PageID.2.)

III. LEGAL STANDARD

A. Rule 12(b)(1) A motion under 12(b)(1) challenges a court’s subject matter jurisdiction over the claims presented. Fed. R. Civ. P. 12(b)(1). Such a

motion attacks jurisdiction either facially or factually. United States v. Ritchie, 15 F.3d 592, 598 (6th Cir. 1994). “A facial attack is a challenge to the sufficiency of the pleading itself,” and the court “take[s] the

material allegations of the petition as true and construed in the light most favorable to the nonmoving party.” Id. A factual attack is “a challenge to the factual existence of subject matter jurisdiction” and “no

presumptive truthfulness applies to the factual allegations.” Id. Defendants characterize their jurisdictional challenge as a factual attack. (ECF No. 8, PageID.59.) The Court disagrees. Because defendants

challenge the legal sufficiency of Al Awbathani’s claim and do not appear to dispute any factual allegations in the complaint or rely on any extrinsic evidence in arguing that the Court lacks jurisdiction, the motion is a

facial attack on jurisdiction. See Ritchie, 15 F.3d at 598; Igal v. U.S. Consulate Gen.

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Al Awbathani v. United States Consulate Toronto, Counsel Stack Legal Research, https://law.counselstack.com/opinion/al-awbathani-v-united-states-consulate-toronto-mied-2025.