Alam v. Blinken

CourtDistrict Court, E.D. California
DecidedNovember 15, 2024
Docket2:24-cv-01103
StatusUnknown

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

Bluebook
Alam v. Blinken, (E.D. Cal. 2024).

Opinion

8 UNITED STATES DISTRICT COURT

9 FOR THE EASTERN DISTRICT OF CALIFORNIA

11 MUHAMMAD WAJAHAT ALAM, et al., No. 2:24-cv-01103-DJC-CKD

12 Plaintiffs,

13 v. ORDER

14 ANTHONY BLINKEN, et al.,

15 Defendants.

18 Defendants move for dismissal or, in the alternative, summary judgment on

19 Plaintiffs’ claims that Defendants have unreasonably delayed adjudication of Plaintiffs’

20 immigrant visa application. Defendants argue that Plaintiffs’ claims are unreviewable

21 because the application was already reviewed and refused by a consular officer under

22 8 U.S.C. § 1201(g ), which was a final adjudication, and judicial review of final consular 23 decisions is precluded under the doctrine of consular nonreviewability. Defendants 24 also argue that, even if the refusal was not a final decision, it has only been fourteen 25 months since the visa application was refused which does not constitute an 26 unreasonable delay. 27 The Court finds that there has been no unreasonable delay in adjudicating 28 Plaintiffs’ visa application. Accordingly, the Court will grant Defendants’ motion. 1 BACKGROUND

2 Plaintiff Muhammad Wajahat Alam (“M. Alam”) is a United States (“U.S.”) citizen.

3 (Compl. (ECF No. 1) ¶ 58.) Plaintiff Shakila Wajahat Alam (“S. Alam”), Plaintiff M.

4 Alam’s wife, is a Pakistani national currently residing in Pakistan. (Id. ¶ 59.)

5 Under the Immigration and Nationality Act (“INA”), consular officers may issue

6 immigrant and nonimmigrant visas to foreign nationals who are eligible for those visas

7 and who are admissible to the U.S. (Id. ¶ 26 (citing 8 U.S.C. § 1201; 22 C.F.R.

8 § 42.71).) One of the methods by which foreign nationals may immigrate to the U.S. is

9 via their familial relationship with a U.S. citizen or lawful permanent resident. (Id. ¶ 27.)

10 Under the INA, family-sponsored visas may be issued to, inter alia, the spouses of U.S.

11 citizens. (Id. (citing 8 U.S.C. § 1153(a)(1)–(4)).)

12 A family-based immigrant visa application is initiated when a U.S. citizen or

13 legal permanent resident files a Form I-130 with United States Citizenship and

14 Immigration Services (“USCIS”). (Id. ¶ 28 (citing 8 U.S.C. § 1154).) USCIS verifies that

15 the petitioner is a U.S. citizen or legal permanent resident and that a qualifying

16 relationship exists between the petitioner and the beneficiary. (Id. (citing 8 C.F.R. §

17 204.1(a)(1)).) Upon a Form I-130 approval, if the beneficiary of the immigrant visa

18 petition is residing outside of the U.S., the petition is then sent to the National Visa

19 Center (“NVC”) for pre-processing, and the beneficiary is able to begin the process of

20 formally applying for an immigrant visa by submitting a Form DS-260. (Id. ¶ 29.)

21 After completing the Form DS-260, and submitting fees, forms, and supporting

22 documentation to the NVC for review, the application is then sent to the U.S. Embassy

23 having jurisdiction over the noncitizen’s place of residence for an interview. (Id. ¶ 30.)

24 After completing a medical examination, and paying applicable fees, the beneficiary is

25 interviewed by a consular officer at the beneficiary’s applicable U.S. Embassy or

26 Consulate. (Id. ¶ 35.) At the end of a beneficiary’s immigrant visa interview at the U.S.

27 Embassy or Consulate, the consular officer informs the applicant whether their visa

28 application is approved or denied. (Id. ¶ 37.) The consular officer “must issue the visa 1 or refuse the visa under INA 212(a) or 221(g) or other applicable law.” (Id. ¶ 39

2 (quoting 22 C.F.R. § 42.81(a)).) If the consular officer determines that the visa should

3 be refused, the officer must inform the beneficiary of the provision of law or

4 implementing regulation under which the refusal is based. (Id. ¶¶ 44–48.)

5 Before a visa is issued, consular officers must perform a check of automated

6 lookout systems, which are used to help officers identify visa applicants about whom

7 the U.S. government may have information that indicates a possible basis of visa

8 ineligibility. (Compl., Ex A. (ECF No. 1-1) ¶ 10.) If, during the visa interview, allegedly

9 derogatory information exists about an applicant or someone with a similar name to

10 the applicant, the consular officer will receive a “red-light” response to one of the

11 automated lookout systems. (Compl. ¶ 31.) When a consular officer encounters a

12 “red light,” the consular officer will request the applicant complete and return a Form

13 DS-5535, “Supplemental Questions for Visa Applicants.” (Id.) The consular officer will

14 then use the Form DS-5535 to submit a Security Advisory Opinion (“SAO”) request,

15 which are handled by the Office of Screening, Analysis, and Coordination (“SAC”).

16 (Id.) In any case in which a SAO is required, a consular officer must wait for a response

17 from the SAC, which will provide a recommendation on whether sufficient information

18 exists to support a security-related ineligibility finding. (Compl., Ex A. ¶ 19.)

19 On October 7, 2019, Plaintiff M. Alam began the process of bringing his wife

20 Plaintiff S. Alam to the United States by filing a Form I-130. (Compl. ¶ 60.) Plaintiffs’

21 Form I-130 was approved on April 14, 2021, and forwarded to NVC for pre-

22 processing. (Id. ¶ 61.) Plaintiffs paid the required immigrant visa processing fees and,

23 on April 28, 2021, timely submitted the Form DS-260 along with supporting

24 documentation to the NVC. (Id. ¶ 63.) On June 4, 2021, Plaintiffs were found to be

25 documentarily qualified. (Id.) Accordingly, on April 19, 2023, Plaintiff S. Alam was

26 interviewed by a consular officer at the U.S. Embassy in Islamabad, Pakistan. (Id. ¶ 64.)

27 After the interview, the consular officer refused Plaintiffs’ application under

28 section 221(g) of the INA, 8 U.S.C. § 1201(g). (Id. ¶ 65.) Plaintiff S. Alam was informed 1 her visa application would require further administrative processing and was asked to

2 complete a Form DS-5535 to conduct additional security screening, as well as submit

3 her passport, resume, and master’s research topic and thesis. (Id.; Compl., Ex. B (ECF

4 No. 1-2); Defs.’ Statement of Undisputed Facts (ECF No. 10-1) ¶¶ 7–8.) Plaintiff S.

5 Alam provided all requested information on April 25, 2023. (Compl. ¶ 66; Compl., Ex.

6 D (ECF No. 1-4).) However, to date, Plaintiff S. Alam’s application is still being

7 processed, and her application status is shown as “Refused” on the State Department

8 website. (Compl. ¶¶ 67–68.) Plaintiff S. Alam has not received any substantial updates

9 as to when she will receive another decision on her application. (Id. ¶ 69.)

10 Plaintiff S. Alam gave birth while awaiting a decision on her visa application and

11 is raising the child in Pakistan without the benefit of her husband’s support. (Id. ¶¶ 68,

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