Aswin Subramaniam Krishnan, et al. v. United States Department of Homeland Security

CourtDistrict Court, N.D. Indiana
DecidedJanuary 14, 2026
Docket3:24-cv-00481
StatusUnknown

This text of Aswin Subramaniam Krishnan, et al. v. United States Department of Homeland Security (Aswin Subramaniam Krishnan, et al. v. United States Department of Homeland Security) is published on Counsel Stack Legal Research, covering District Court, N.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aswin Subramaniam Krishnan, et al. v. United States Department of Homeland Security, (N.D. Ind. 2026).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

ASWIN SUBRAMANIAM KRISHNAN, et al.,

Plaintiffs,

v. Case No. 3:24-CV-481-CCB-SJF

UNITED STATES DEPARTMENT OF HOMELAND SECURITY,

Defendant.

OPINION AND ORDER Before the Court is Defendant Department of Homeland Security’s (“DHS”) Motion to Dismiss Plaintiffs’ Complaint. (ECF 10). Plaintiffs here are nineteen foreign nationals who formerly held F-1 student visas. (ECF 1 ¶¶ 1–20). Each plaintiff was determined inadmissible to the United States by DHS. (ECF 1 at 1). In their complaint, they raised three claims under the Administrative Procedure Act (“APA”): (1) DHS incorrectly interpreted federal immigration law, (2) DHS’s determinations that each plaintiff was inadmissible were arbitrary, capricious, and unlawful; and (3) DHS’s decision process was procedurally deficient and irregular. (ECF 1 ¶¶ 172–207). DHS asks the Court to dismiss the entire complaint. For the reasons below, the Court GRANTS DHS’s motion to dismiss and DISMISSES this case. I. RELEVANT BACKGROUND The Court begins by summarizing the allegations in the Complaint. (ECF 1). Plaintiffs are nineteen foreign nationals who obtained F-1 student visas to study in the United States. Generally, F-1 visa holders must exit the United States at the end of their educational program. An F-1 student may, however, extend her stay after graduation

by participating in a practical training program directly related to her course of study. Plaintiffs took advantage of this opportunity by joining the Operational Practical Training program (“OPT”). As required by the program, Plaintiffs sought and secured offers of employment from information technology staffing companies (“the OPT Companies”). The OPT Companies were verified as OPT employers by the United States Citizenship and Immigration Services. These companies promised to provide

Plaintiffs with training services, networking opportunities, and internships. Before beginning work, however, the OPT Companies required Plaintiffs to receive additional training. This training was provided by the OPT Companies in exchange for a fee. Believing the OPT Companies to be legitimate employers, Plaintiffs paid the fee and participated in the training. But after Plaintiffs completed the training, the OPT

Companies did not follow through on their promises to market Plaintiffs to employers and help them secure internships. As DHS later discovered, the OPT Companies were illegitimate companies perpetrating a fraud on the United States and foreign students. Because Plaintiffs contracted with the OPT Companies, DHS treated them as knowing co-conspirators and sanctioned them with inadmissibility determinations that barred all

Plaintiffs from admission to the United States. But DHS did not notify Plaintiffs of these sanctions. Nor did it provide Plaintiffs an opportunity to defend themselves or contest their inadmissibility. Instead, DHS entered the inadmissibility determinations in databases accessible by DHS and the Department of State. Plaintiffs only became aware of these determinations when the Department of State informed them of their inadmissible status. In this suit, they seek vacatur of DHS’s interpretation of the

definition of fraud in 8 U.S.C. § 1182(a)(6)(C)(i) as applied to their inadmissibility determinations, vacatur of their inadmissibility determinations, an injunction barring DHS from adjudicating Plaintiffs inadmissible based on its interpretation of 8 U.S.C. § 1182(a)(6)(C)(i), and orders directing DHS to provide Plaintiffs with an opportunity to be heard on their inadmissibility determinations and reinstating Plaintiffs’ lawful status in the United States. They also seek fees under the Equal Access to Justice Act.

II. ANALYSIS DHS argues that (1) Plaintiffs are improperly joined, (2) they have not demonstrated Article III justiciability, and (3) they fail to state a claim upon which relief may be granted. (ECF 12 at 1–2). a. Severance and Dismissal for Improper Joinder

DHS first asks the Court to sever and dismiss or transfer all plaintiffs except Plaintiff Krishnan. In support, it argues that the facts underlying each plaintiff’s claim are too diffuse to constitute the same “series of transactions or occurrences” required by FRCP 20 for proper joinder. Fed. R. Civ. P. 20(a). It points out that the complaint contains no common timeframe within which these events occurred, and notes that

Plaintiffs do not allege that they worked for the same company, attended the same school, or were found inadmissible under similar circumstances. Plaintiffs respond that their suit does not attack the substance of any single inadmissibility decision but rather objects that DHS denied all plaintiffs due process. Accordingly, Plaintiffs argue that they need only allege the same due process violation by DHS to satisfy the requirements of Rule 20 joinder.

This Court has significant discretion to determine whether Rule 20 joinder is proper. See Cont’l Indem. Co. v. BII, Inc., 104 F.4th 630, 645 (7th Cir. 2024) (“As for permissive joinder, under Rule 20, district courts have discretion, with considerable flexibility in managing and structuring civil litigation for fair and efficient resolution of complex disputes.”). Plaintiffs have alleged that DHS’s procedure in each of their inadmissibility determinations violated due process. Those violations are the “series of

transactions or occurrences” on which they base their argument for joinder. These alleged procedural violations are sufficient to permit joinder under the permissive standard of Rule 20. See Dubey v. United States Dep’t of Homeland Sec., 2025 WL 371780, at *3 (N.D. Ill. Feb. 3, 2025). The Court will not sever and dismiss all plaintiffs besides Plaintiff Krishnan for improper joinder.

b. Article III Justiciability DHS next asks the Court to dismiss the complaint due to lack of Article III justiciability. In support, DHS raises four arguments: (1) six plaintiffs departed the United States without alleging an intention to return, rendering their injury speculative; (2) five plaintiffs have been admitted to the United States notwithstanding their alleged

inadmissibility determination, rendering their claims moot; (3) five plaintiffs were denied visas by State Department consular officers, rendering their inadmissibility unreviewable and therefore not redressable by this Court; and (4) the remaining plaintiffs are currently within the United States, negating any claim of injury in fact. The Court will first address the question of injury in fact, second the question of redressability, and last the question of mootness. i. Injury in Fact

To establish standing under Article III, a plaintiff must show that he “(1) suffered an injury in fact, (2) that is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be redressed by a favorable judicial decision.” Lujan v. Defenders of Wildlife, 504 U.S. 555, 560 (1992). An injury in fact must be a “concrete and particularized, actual or imminent invasion of a legally protected interest.” Id. at 555.

The Seventh Circuit has recognized that the loss of opportunity to become a permanent resident may be an injury in fact for Article III standing purposes. Musunuru v.

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Aswin Subramaniam Krishnan, et al. v. United States Department of Homeland Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aswin-subramaniam-krishnan-et-al-v-united-states-department-of-homeland-innd-2026.