Armah v. United States Department of State

CourtDistrict Court, District of Columbia
DecidedMay 28, 2024
DocketCivil Action No. 2022-1714
StatusPublished

This text of Armah v. United States Department of State (Armah 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
Armah v. United States Department of State, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

MARGARET ARMAH,

Plaintiff,

v. Civil Action No. 22-1714 (BAH)

UNITED STATES DEPARTMENT OF Judge Beryl A. Howell STATE, et al.,

Defendants.

MEMORANDUM OPINION

Plaintiff Margaret Armah, a citizen of the United States, seeks to compel defendants, U.S.

Department of State; U.S. Embassy in Accra, Ghana; and Antony Blinken, Secretary of the U.S.

Department of State, and Virginia E. Palmer, U.S. Ambassador of the U.S. Embassy in Accra,

Ghana, in their official capacities (collectively, “Defendants”), to adjudicate the visa petition of

her daughter, Tracey E. Baiden, which petition was pending before defendants without decision

for nearly two years at the time she initiated this lawsuit. Compl. ¶¶ 1–6, 10, 16–17, ECF No. 1.

Plaintiff claims that defendants have unreasonably delayed adjudication of her daughter’s visa

application, in violation of the Administrative Procedure Act (“APA”), 5 U.S.C. § 706(1), and the

Mandamus Act, 28 U.S.C. § 1361, id. ¶¶ 7, 21–22, and have done so intentionally by applying the

policies of the Controlled Application Review and Resolution Program (“CARRP”) to their review

of the visa application, id. ¶¶ 24–30, in violation of the Immigration and Nationality Act (“INA”),

8 U.S.C. § 1101 et seq., id. ¶ 31. Plaintiff also alleges violation of her due process rights under

the Fifth Amendment. Id. ¶¶ 34–37. Defendants now move to dismiss for lack of jurisdiction

under Federal Rule of Civil Procedure 12(b)(1), or, in the alternative, for failure to state a claim

1 under Rule 12(b)(6). Defs.’ Mot. Dismiss (“Defs.’ Mot.”) at 1, ECF No. 16. For the reasons

explained below, defendants’ motion is granted.

I. BACKGROUND

A review of the statutory and regulatory background underlying the claims is below,

followed by a summary of the factual and procedural history of this case.

A. Statutory and Regulatory Background

The INA allows for the issuance of immigrant visas, including for relatives of U.S. citizens.

See 8 U.S.C. § 1154; 8 C.F.R. § 204.1(a)(1), (b). A U.S. citizen seeking permanent resident status

for an adult child or other family member may fill out a Form I-130, Petition for Alien Relative,

with the Department of Homeland Security’s U.S. Citizenship and Immigration Services

(“USCIS”). See 8 U.S.C. § 1154; 8 C.F.R. § 204.1(a)(1); see also 8 U.S.C. § 1151(b)(2)(A)(i)

(defining an “immediate relative[]” as including “children . . . of a citizen of the United States” for

purposes of Form I-130 petitioners). If USCIS approves the petition, the case is forwarded to the

National Visa Center (“NVC”) for processing. 8 C.F.R. § 204.2(d)(3)(1). NVC serves as the visa

application processing center for the U.S. Department of State (“State Department”). Id.

Following approval of the petition, the foreign relative must submit paperwork and

processing fees to NVC. See 22 C.F.R. § 42.67 (outlining application fees and additional

documentation that an applicant must submit to NVC to complete their application). After

processing the requisite materials, NVC schedules a consular interview for the applicant at the

embassy with jurisdiction over the applicant’s residence. Id. § 42.62. The consular officer must

issue or refuse the visa following the interview. Id. § 42.81(a).

B. Factual Background

On March 31, 2015, plaintiff filed an I-130 visa petition with USCIS on behalf of her

daughter, Tracey E. Baiden. See Compl. ¶¶ 10, 13. Plaintiff intended to secure lawful permanent

2 resident status for Ms. Baiden, who currently resides in Ghana, to enable her to join plaintiff in the

United States. See id. ¶¶ 2, 11. On May 4, 2015, USCIS approved plaintiff’s visa petition and

transferred the petition to NVC. See id. ¶¶ 15–16. On June 17, 2020, NVC indicated that the visa

petition for Ms. Baiden was “documentarily qualified” and awaiting scheduling for an interview.

Pl.’s Opp’n Defs.’ Mot. Dismiss (“Pl.’s Opp’n”) at 6, ECF No. 17 (citing Pl.’s Opp’n, Ex. A,

Affidavit of Margaret Armah (“Armah Aff.”) ¶ 6, ECF No. 17-1).

Since June 2020, when the petition was documentarily qualified, however, NVC “has

refused . . . to conduct an interview,” despite plaintiff’s multiple efforts to contact the State

Department about the matter. See id. at 2 (citing Compl. ¶¶ 17–18). 1 Plaintiff alleges that, as a

result, she and her daughter have been “irrevocably harmed” by the family separation, Compl. ¶

37, particularly since April 2021, when plaintiff underwent lung mass surgery, Pl.’s Opp’n at 2–3.

Two years after the procedure, plaintiff continues to require her daughter’s “help with daily

activities” and “care and emotional support,” and to ensure that plaintiff receives “proper medical

care.” Id. (citing Armah Aff. ¶ 11).

C. Procedural History

On June 14, 2022, roughly twenty-four months after NVC’s last notification stating that

the visa petition for Ms. Baiden was “documentarily qualified,” plaintiff filed the instant petition

with two causes of action, seeking, among other requested relief, an order “compelling Defendants

to adjudicate a long-delayed immediate relative visa application.” Compl. at 2; see also id. at 7–

8 (Request for Relief). Plaintiff maintains that defendants retain jurisdiction over her daughter’s

visa application and have a “non-discretionary duty to conclude agency matters” within a

1 Defendants state that “technically, the last Government action on” plaintiff’s daughter’s visa application “was in July 2020,” when the “priority date of the visa . . . bec[ame] current,” but they nevertheless identify June 17, 2020, as the date of the last action taken by the government on plaintiff’s daughter’s visa application. See Defs.’ Mot. at 3 & n.2.

3 “reasonable time,” which duty she seeks to enforce with relief under the APA and the Mandamus

Act. Id. ¶¶ 7, 20–21 (citations omitted). She also claims that defendants have unlawfully delayed

her daughter’s visa application pursuant to CARRP, a Department of Homeland Security program,

which allegedly “intentionally delays the applications of applicants . . . from a predominantly

Muslim country” “due to security concerns,” in violation of the INA. Id. ¶¶ 24–25, 31. As a result

of the delay, plaintiff further claims she has suffered deprivation of her due process rights under

the Fifth Amendment. Id. ¶¶ 35–36.

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