Aramnahad v. Blinken

CourtDistrict Court, District of Columbia
DecidedDecember 22, 2025
DocketCivil Action No. 2024-1817
StatusPublished

This text of Aramnahad v. Blinken (Aramnahad v. Blinken) 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
Aramnahad v. Blinken, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

MOHAMMAD ARAMNAHAD, et al.,

Plaintiffs,

v. No. 24-cv-1817-MAU

MARCO RUBIO, Secretary of State, et al., 1

Defendants.

MEMORANDUM OPINION

Plaintiffs Mohammad Aramnahad and his wife Meili Li (collectively “Plaintiffs”) seek

declaratory, injunctive, and mandamus relief to compel the United States Government

(“Defendants” or “the Government”) to adjudicate their immigrant visa application. ECF No. 1.2

Plaintiffs contend that the Government has unreasonably delayed and unlawfully withheld

adjudication of their visa application in violation of the Administrative Procedure Act (“APA”),

5 U.S.C. §§ 555(b), 701 et seq., and the Mandamus Act, 28 U.S.C. § 1361. Id. The Government

moves for summary judgment under Federal Rule of Civil Procedure 56 on all of Plaintiffs’

claims. ECF No. 29. For the reasons set forth below, the Government’s Motion for Summary

Judgment (“Motion”) is GRANTED.

FACTUAL SUMMARY

Because Plaintiffs have failed to file any opposing statement of facts specifically

disputing any of Defendants’ factual assertions, the Court deems Defendants’ statement of facts

1 The original Defendant has been substituted for his successor. Fed. R. Civ P. 25(d). 2 Citations are to the page numbers in the ECF headers. 1 conceded. See Fed. R. Civ. P. 56(e)(2); LCvR (h). In any event, the facts material to the

resolution of this Motion are undisputed. ECF No. 29-1.

Aramnahad is an Iranian national, and his wife Li is a Chinese national. ECF No. 29-1 ¶¶

1–2. They live in China. Id. Aramnahad is the beneficiary of an approved I-140 EB-3 petition

and the principal applicant for the immigrant visa. Id. ¶¶ 3–4. Li is the derivative applicant. Id.

¶ 5. Plaintiffs interviewed with a consular officer at the United States embassy in Guangzhou,

China on March 30, 2023. Id. ¶ 6. At the conclusion of the interview, the officer informed

Plaintiffs that the officer had refused their application under section 221(g) of the Immigration

and Nationality Act (“INA”), codified at 8 U.S.C. § 1201(g), and placed it in administrative

processing (the “221(g) Refusal”). Id. ¶ 7. Although Plaintiffs submitted additional

documentation upon request of the consular officer, Plaintiffs’ visa application “remain[ed]

refused while undergoing [administrative] processing.” ECF No. 19 ¶ 59.

By mid-2024, there had been no change in Plaintiffs’ status. On June 24, 2024, Plaintiffs

filed this Complaint to compel the Government to adjudicate their visa application. ECF No. 29-

1 ¶ 10. Plaintiffs assert three claims: 1) the Government violated § 706(2) of the APA by

withholding adjudication of Plaintiffs’ visa application (Count I); 2) the Government violated §§

555(b) and 706(1) of the APA by unreasonably delaying adjudication of their application (Count

II); and 3) this Court should issue a writ of mandamus to remedy the Government’s alleged

breach of its duty to adjudicate Plaintiffs’ application (Count III). ECF No. 1 ¶¶ 67–103.

On June 4, 2025, during the pendency of this litigation, President Donald J. Trump issued

Proclamation No. 10,949 (“the Presidential Proclamation”), in which he ordered the “full

suspension of entry of nationals” from certain countries of “Identified Concern,” including Iran.

Restricting the Entry of Foreign Nationals to Protect the United States from Foreign Terrorists

2 and Other National Security and Public Safety Threats, Proclamation No. 10,949, 90 Fed. Reg.

24497, 24498 (June 4, 2025). In the Presidential Proclamation, the President declared that the

“entry into the United States of nationals of Iran as immigrants and nonimmigrants is hereby

suspended.” Id. at 24500. The President, however, empowered the Government to grant an

exception to restricted nationals if their entry would serve a United States national interest. Id. at

24503.

On June 12, 2025, approximately one week after the Presidential Proclamation, a

consular officer refused Plaintiffs’ visa application under section 212(f) of the INA (the “212(f)

Refusal”), codified at 8 U.S.C. § 1182(f). The email from the officer to Plaintiffs stated:

This is to inform you that a consular officer found you ineligible for an immigrant visa under Section 212(f) of the Immigration and Nationality Act, pursuant to Presidential Proclamation “Restricting the Entry of foreign Nationals to Protect the United States from Foreign Terrorists and Other National Security and Public Safety Threats”. Today’s decision cannot be appealed.

Taking into account the provisions of the Proclamation, a National Interest Exception (NIE) will not be granted in your case.

ECF No. 29-2.

PROCEDURAL HISTORY

On August 21, 2024, Defendants moved to dismiss the Complaint, arguing that the

doctrine of consular nonreviewability barred Plaintiffs’ suit and that Plaintiffs failed to identify a

clear, nondiscretionary duty to act on the Government’s part. ECF No. 6. The Court denied

Defendants’ motion. ECF Nos. 17, 18. Defendants answered and subsequently moved for

judgment on the pleadings under Rule 12(c) based on the factors set forth in Telecommunications

Research & Action Center v. Federal Communications Commission, 750 F.2d 70, 80 (D.C. Cir.

1984) (“TRAC”). ECF Nos. 19, 20. Plaintiffs also moved to strike a response from Defendants’

3 Answer and to compel the production of the administrative record under LCvR 7(n). ECF No.

25. Defendants cross-moved for partial relief from LCvR 7(n) and to not produce the

administrative record. ECF No. 27. These motions are pending.

After Plaintiffs received the 212(f) Refusal, Defendants moved for summary judgment

based primarily on the argument that the case is now moot because Plaintiffs have obtained the

ultimate relief they seek in this case. ECF No. 29. The Court ordered the Parties to appear for a

status conference prepared to address whether the 212(f) Refusal mooted this case or required a

stay. Minute Order (July 15, 2025).

During that hearing, Plaintiffs argued that the 212(f) Refusal was unlawful and that they

were considering challenging the constitutionality of the Presidential Proclamation. ECF No. 32

at 4:13–5:24. Because such a challenge was not within the scope of Plaintiffs’ Complaint, the

Court instructed Plaintiffs to advise whether they intended to dismiss their case as moot or seek

leave to amend their Complaint to challenge the constitutionality of the Presidential

Proclamation. Id. at 10:15–19 (“The only thing I’m instructing you all to do is to let me know

whether the Plaintiffs [are] dismissing [their] case based on the travel ban or whether there is

going to be a request [] to amend [the Complaint].”). The Court made it clear to Plaintiffs that

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