A.R.R. v. Rubio

CourtDistrict Court, District of Columbia
DecidedJune 24, 2026
DocketCivil Action No. 2026-1921
StatusPublished

This text of A.R.R. v. Rubio (A.R.R. v. Rubio) 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
A.R.R. v. Rubio, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

A.R.R., et al.,

Plaintiffs, v. Civil Action No. 26-1921 MARCO RUBIO, et al.,

Defendants.

MEMORANDUM OPINION AND ORDER

Plaintiffs in this case — six unrelated Afghan asylees residing in Colorado and their

respective wives and children stuck in the country they fled — commence this lawsuit as part of

their efforts to finally reunite. See ECF No. 1 (Compl.), ¶¶ 1–7, 13, 17, 27, 29, 36, 40. Securing

asylum status in 2023, the asylees successfully applied for Form I-730 “Asylee Relative

Petitions” for their (collectively) 24 immediate family members in Afghanistan, who did their

part by verifying their requisite familial relationships in consular interviews in Islamabad,

Pakistan. Id., ¶¶ 2–3, 51–97. Their efforts, however, have been stalled. In the first year of his

current administration, the President issued two proclamations fully suspending entry from

initially twelve and later twenty countries, Afghanistan among them. Id., ¶¶ 110, 116; see also

Proclamation No. 10949, 90 Fed. Reg. 24497 (June 4, 2025); Proclamation No. 10998, 90 Fed.

Reg. 59717 (Dec. 16, 2025). The State Department, in turn, disseminated a series of “cables”

directing consular officers on how to implement the new policy, including processes for granting

narrow “National Interest Exceptions.” Id., ¶¶ 113–15, 117–18. So instead of issuing the I-730-

holding relatives documents for travel to the U.S., the American Embassy in Islamabad issued

1 letters deeming them ineligible for entry and unqualified for a National Interest Exception. Id.,

¶¶ 57, 65, 72, 79, 86, 93.

Plaintiffs now sue the Secretary of State and the Department he leads under the

Administrative Procedure Act, arguing that the cables amount to a nationality-based entry ban

that is arbitrary and capricious, exceeds statutory authority, violates the Department’s own rules

for adjudicating cases individually, and flouts notice-and-comment requirements. Id., ¶¶ 119–

61. They also contend that State has unreasonably delayed the ultimate adjudication of the I-730

petitions. Id., ¶¶ 162–69. All this Plaintiffs seek to do pseudonymously, citing concerns for the

safety of those among them still in Afghanistan. See ECF Nos. 2 (Mot.) at 1–2; 2-1 (Memo.) at

1–2. The Court will grant their Motion to Proceed Under Pseudonym, subject to any further

consideration by the United States District Judge to whom this case is randomly assigned. See

LCvR 40.7(f) (providing that Chief Judge shall “hear and determine . . . motion[s] to seal the

complaint and motion[s] to file a pseudonymous complaint . . . .”).

I. Legal Standard

Complaints must typically identify a plaintiff. See Fed. R. Civ. P. 10(a); LCvR 5.1(c)(1).

This identification requirement reflects the “presumption in favor of disclosure [of litigants’

identities], which stems from the ‘general public interest in the openness of governmental

processes,’ and, more specifically, from the tradition of open judicial proceedings.” In re Sealed

Case, 931 F.3d 92, 96 (D.C. Cir. 2019) (quoting Washington Legal Found. v. U.S. Sentencing

Comm’n, 89 F.3d 897, 899 (D.C. Cir. 1996)). A party moving to proceed pseudonymously thus

“bears the weighty burden of both demonstrating a concrete need for such secrecy[] and

identifying the consequences that would likely befall it if forced to proceed in its own name.” In

re Sealed Case, 971 F.3d 324, 326 (D.C. Cir. 2020). As a result, the court must “‘balance the

2 litigant’s legitimate interest in anonymity against countervailing interests in full disclosure’” by

applying a “flexible and fact driven” balancing test. Id. (quoting In re Sealed Case, 931 F.3d at

96). That test assesses “five non-exhaustive factors”:

(1) whether the justification asserted by the requesting party is merely to avoid the annoyance and criticism that may attend any litigation or is to preserve privacy in a matter of a sensitive and highly personal nature; (2) whether identification poses a risk of retaliatory physical or mental harm to the requesting party or, even more critically, to innocent non- parties; (3) the ages of the persons whose privacy interests are sought to be protected; (4) whether the action is against a governmental or private party; and relatedly, (5) the risk of unfairness to the opposing party from allowing an action against it to proceed anonymously.

Id. at 326–27 (quoting In re Sealed Case, 931 F.3d at 97) (cleaned up).

II. Analysis

Plaintiffs have met their burden to overcome the presumption in favor of disclosing their

identities. The Court will address the factors in turn.

A. Factors One and Two

The first two factors, taken together, support pseudonymity. Plaintiffs do not seek to go

unnamed “merely to avoid the annoyance and criticism that may attend any litigation,” but to

“preserve privacy in a matter of [a] sensitive and highly personal nature.” Id. at 326 (quoting In

re Sealed Case, 931 F.3d at 97) (alteration in original). Such matters can include “maintaining

their and their family members’ safety.” Sponsor v. Mayorkas, 2023 WL 2598685, at *2

(D.D.C. Mar. 22, 2023). Although Plaintiffs’ filings in this case — even the sealed ones — are

short on detail, they express fear of Taliban policies restricting women’s rights and conscripting

young men, see Compl., ¶¶ 58, 66, 73, 80, 87, 94, and “fear [of] any further retribution should

their names be tied to a lawsuit seeking to leave Afghanistan.” Memo. at 5. More specifically,

3 one Plaintiff-family belonging to a racial and religious minority group expresses fears over

ongoing ethnic cleansing of that group in Afghanistan. See Compl., ¶ 58. These fears,

furthermore, come in the specific context of asylum, which this Court has indicated warrants

particular sensitivity. See, e.g., J.G.G. v. Trump, 2025 WL 1352316, at *2 (D.D.C. May 8,

2025) (agreeing with plaintiff that federal regulations “provide for the confidentiality of asylum

applicants” in part given risk of retaliation) (quoting plaintiffs’ motion and citing Anim v.

Mukasey, 535 F.3d 243, 253 (4th Cir. 2008)); Doe v. U.S. Immigr. & Customs Enf’t, 2024 WL

5483092, at *2 (D.D.C. Mar. 8, 2024) (acknowledging risks if home government learned of

plaintiff’s identity and asylum claim).

Plaintiffs’ filings are generalized almost to a fault, and the Court’s prior

acknowledgements of the particular sensitivities of asylum have generally benefited from

detailed documentation of the abuses that underlay those plaintiffs’ asylum claims. See, e.g.,

J.Z. v. U.S. Dep’t of Homeland Sec., 2026 WL 1470530, at * 2 (D.D.C. May 26, 2026); Coal. for

Humane Immigrant Rights v. Mullin, 2026 WL 936034, at *1–2 (D.D.C. Apr. 7, 2026); Molina

v. U.S. Dep’t of Homeland Sec., 2025 WL 2800807, at *1 (D.D.C. Oct. 1, 2025); J.G.G, 2025

WL 1352316, at *2; Sponsor, 2023 WL 2598685, at *2. The Court finds, however, that the

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Related

Anim v. Mukasey
535 F.3d 243 (Fourth Circuit, 2008)
In re: Sealed Case
931 F.3d 92 (D.C. Circuit, 2019)
In re: Sealed Case
971 F.3d 324 (D.C. Circuit, 2020)

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