Ali v. Frazier

575 F. Supp. 2d 1084, 2008 U.S. Dist. LEXIS 78591, 2008 WL 4180265
CourtDistrict Court, D. Minnesota
DecidedSeptember 11, 2008
Docket0:07-cv-02894
StatusPublished
Cited by13 cases

This text of 575 F. Supp. 2d 1084 (Ali v. Frazier) is published on Counsel Stack Legal Research, covering District Court, D. Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ali v. Frazier, 575 F. Supp. 2d 1084, 2008 U.S. Dist. LEXIS 78591, 2008 WL 4180265 (mnd 2008).

Opinion

MEMORANDUM OPINION AND ORDER

PATRICK J. SCHILTZ, District Judge.

Plaintiffs applied to the United States Citizenship and Immigration Services (“CIS”) to become naturalized citizens of the United States. After growing unhappy with the pace of CIS’s processing of their applications, plaintiffs brought this suit against CIS officials and the director of the Federal Bureau of Investigation (“FBI”), asking this Court to order CIS and the FBI to speed things up. Plaintiffs made claims under the Mandamus Act, 28 U.S.C. § 1361, and under the Administrative Procedure Act (“APA”), 5 U.S.C. § 706(1).

Since this suit was filed, CIS has approved six of the seven plaintiffs’ applications. Those six plaintiffs, who are now naturalized citizens, concede that their claims are moot, and the Court therefore dismisses their claims. 1 See PL Mem. Resp. Def. Mot. Dism. & Remand at 1 (“Pl.Opp.Mem.”) [Docket No. 19]; Letter of PL Counsel to Court, July 16, 2008 [Docket No. 25],

This leaves one remaining plaintiff, Nasser Al-Selham. The government moves to dismiss Al-Selham’s claims, arguing that this Court does not have subject-matter jurisdiction over this action and that, on the merits, Al-Selham’s complaint should be dismissed because he is not entitled to relief under either the Mandamus Act or the APA. For the reasons that follow, the Court holds that it does indeed have subject-matter jurisdiction over this action. On the merits, the Court dismisses all claims against the FBI and the mandamus claims against CIS; the Court does not, however, dismiss the APA claims against CIS. 2

*1087 I. BACKGROUND

The naturalization process begins when a non-citizen files with CIS an application for naturalization (Form N-400). By regulation, CIS must then “complete an investigation” of the applicant. 8 C.F.R. § 335.1. Further, the applicant must “appear in person before a[CIS] officer” for an “examination” — that is, an in-person interview. 8 C.F.R. § 335.2(a); see also Walji v. Gonzales, 500 F.3d 432, 435 & n. 5 (5th Cir.2007) (observing that most courts have held that an “examination”' under 8 U.S.C. § 1447(b) is “a discrete event — the agency’s initial interview of the applicant”). CIS must then grant or deny the application within 120 days of the interview. 8 C.F.R. § 335.3.

The interview, however, can be scheduled “only after the Service has received a definitive response from the Federal Bureau of Investigation that a full criminal background check of an applicant has been completed.” 8 C.F.R. § 335.2(b) (emphasis added). The FBI background check referred to in 8 C.F.R. § 335.2(b) is commonly called a “name check.”

In sum, the naturalization process involves four steps, which must be completed in order. In step 1, the applicant files a Form N-400. In step 2, the FBI completes a name check at CIS’s request. In step 3, CIS interviews the applicant. Finally, in step 4, CIS adjudicates the application on the merits.

The second step has become a bottleneck because the FBI has large numbers of pending name-check requests and limited resources to complete them. As a result, a new genre of case has proliferated in the past few years: name-check litigation.

This case exemplifies the genre. Al-Selham, who is originally from Saudi Arabia, applied to become a naturalized United States citizen by filing Form N-400 with CIS in June 2006. Compl. ¶ 11. He has not yet been interviewed. Id. CIS will not schedule his interview because the FBI has not completed his name check. Id. Al-Selham contends that he meets all of the statutory requirements for naturalization. Id. ¶ 16-17. He seeks an order compelling CIS and the FBI to complete all required background checks and to adjudicate his application for naturalization. Id. ¶ 1 (second).

II. ANALYSIS

1. Subjedy-Matter Jurisdiction

Al-Selham asserts in the complaint that the Court has subject-matter jurisdiction under 28 U.S.C. §§ 1331 and 1361. Compl. ¶ 2. Under § 1331, the federal-question statute, federal district courts “have original jurisdiction of any civil actions arising under the Constitution, laws, or treaties of the United States.” 28 U.S.C. § 1331. Under § 1361, the Mandamus Act, federal district courts “have original jurisdiction of any action in the nature of mandamus to compel an officer or employee of the United States or any agency thereof to perform a duty owed to plaintiff.” 28 U.S.C. § 1361.

On its face, the complaint establishes a basis for mandamus jurisdiction under § 1361. Specifically, the complaint names as defendants three federal officials, two from CIS and one from the FBI. The complaint further asserts that CIS owes a duty to Al-Selham to adjudicate his naturalization application in a reasonable time. Compl. ¶ 22. And the complaint asks the Court to order all defendants, including the FBI, “to perform their duty to complete the required background checks and *1088 security clearances and to adjudicate Plaintiffs’ applications for naturaliza-tion____” Compl. ¶ 1 (second).

The complaint also seems to establish a basis for federal-question jurisdiction under § 1331. In particular, the complaint asserts that it is based on the Administrative Procedure Act (“APA”). Compl. 112. The APA provides, as a general matter, that “[w]ith due regard for the convenience and necessity of the parties or their representatives and within a reasonable time, each agency shall proceed to conclude a matter presented to it.” 5 U.S.C. § 555(b). The APA also provides that federal courts “shall ... compel agency action unlawfully withheld or unreasonably delayed. ...” 5 U.S.C. § 706(1).

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Bluebook (online)
575 F. Supp. 2d 1084, 2008 U.S. Dist. LEXIS 78591, 2008 WL 4180265, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ali-v-frazier-mnd-2008.