Bana v. U.S. Citizenship & Immigration Services

CourtDistrict Court, N.D. Illinois
DecidedJanuary 10, 2025
Docket1:24-cv-04391
StatusUnknown

This text of Bana v. U.S. Citizenship & Immigration Services (Bana v. U.S. Citizenship & Immigration Services) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bana v. U.S. Citizenship & Immigration Services, (N.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

SUMIT BANA and JYOTI SIROHI,

Plaintiffs,

v.

U.S. CITIZENSHIP & IMMIGRATION Case No. 24 CV 4391 SERVICES; UR M. JADDOU, in her official capacity as Director of U.S. Citizenship Hon. Georgia N. Alexakis and Immigration Services; and ALEJANDRO MAYORKAS, in his official capacity as Secretary of U.S. Department of Homeland Security,

Defendants.

MEMORANDUM OPINION AND ORDER Plaintiffs Sumit Bana and Jyoti Sirohi are citizens of India who applied to become lawful permanent residents of the United States. U.S. Citizenship & Immigration Services (“USCIS”) denied their applications, and they now challenge that finding—as well as the antecedent denial of Bana’s I-140 visa petition—as legally erroneous under the Administrative Procedure Act (“APA”). They also challenge the agency’s failure to timely adjudicate their I-290B motion seeking to reopen the petition. For the reasons discussed below, the Court lacks jurisdiction to hear this case. LEGAL STANDARD Article III of the United States Constitution limits federal courts to adjudication of “Cases” and “Controversies.” U.S. Const. art. III, § 2. “Standing to bring and maintain a suit is an essential component of this case-or-controversy requirement.” Scherr v. Marriott Int’l, Inc., 703 F.3d 1069, 1073 (7th Cir. 2013). To establish they have standing, plaintiffs must allege (1) they have suffered an “injury

in fact,” (2) there is a “causal connection between the injury and the conduct complained of,” and (3) “it must be likely, as opposed to merely speculative, that the injury will be redressed by a favorable decision.” Lujan v. Defs. of Wildlife, 504 U.S. 555, 560–61 (1992) (cleaned up). “[A]n actual controversy must exist not only at the time the complaint is filed, but through all stages of the litigation.” Ozinga v. Price, 855 F.3d 730, 734 (7th Cir. 2017) (quoting Kingdomware Techs., Inc. v. United States, 579 U.S. 162, 169 (2016)).

Although “[s]tanding is evaluated at the time suit is filed,” Milwaukee Police Ass’n v. Bd. of Fire & Police Comm’rs of City of Milwaukee, 708 F.3d 921, 928 (7th Cir. 2013), mootness precludes review “[w]hen a party with standing at the inception of the litigation loses it due to intervening events,” Parvati Corp. v. City of Oak Forest, 630 F.3d 512, 516 (7th Cir. 2010). The Court begins by accepting all well-pleaded factual allegations as true and

drawing all reasonable inferences in favor of the plaintiffs. See Sapperstein v. Hager, 188 F.3d 852, 855 (7th Cir. 1999) (citing Panaras v. Liquid Carbonic Indust. Corp., 74 F.3d 786, 791 (7th Cir. 1996)). Once the defendant proffers evidence calling the Court’s jurisdiction into question, however, “the presumption of correctness that we accord to a complaint’s allegations falls away and the plaintiff bears the burden of coming forward with competent proof that standing exists.” Apex Digital, Inc. v. Sears, Roebuck & Co., 572 F.3d 440, 444 (7th Cir. 2009) (cleaned up); see also Sapperstein, 188 F.3d at 856. BACKGROUND

A. Statutory Background The Immigration and Nationality Act (“INA”) provides a three-step process by which a lawfully present foreign national may become a lawful permanent resident of the United States. See Musunuru v. Lynch, 831 F.3d 880, 882 (7th Cir. 2016). “First, the employer must obtain a labor certificate from the Department of Labor that certifies that there are insufficient able, willing, qualified, and available workers, and that hiring the alien worker on a permanent basis will not adversely

affect the wages or working conditions of similarly employed U.S. workers.” Id. (citing 8 U.S.C. §§ 1153(b)(3)(C), 1182(a)(5)(A)(i)). “Second, the employer must file, and USCIS must approve, an immigrant visa petition that assigns the worker to one of the INA’s immigrant visa preference categories for employment-based permanent residency.” Id. at 882–83 (citing 8 U.S.C. §§ 1154(a)(1)(F), 1255(a)(2)). The form used to file this petition is called the Form I-140. Id. at 883 (citing 8 C.F.R. § 204.5(a)).

Third, a worker must “apply for, and be granted, an adjustment of status to permanent resident.” Id. (citing 8 U.S.C. § 1255(a)). The form a worker submits to apply for adjustment of status is called a Form I-485. Id. (citing 8 C.F.R. § 204.5(n)(1)). Some workers (including Bana) may file their Forms I-485 concurrently with their I-140 petitions, see 8 C.F.R. § 245.2(a)(2)(i), but a worker’s Form I-485 will not be adjudicated until their underlying I-140 petition has been approved, see 8 C.F.R. § 245.2(a)(5)(ii). Congress has also amended the INA to make I-140 petitions and labor

certifications “portable” to new employers for applications that have been pending for at least 180 days so long as “the new job is in the same or a similar occupational classification” as the prior job. 8 U.S.C. § 1154(j); 8 C.F.R. § 245.25(a) (federal regulations implementing § 1154(j)’s porting provision); see also Musunuru, 831 F.3d at 884. Workers can request job porting under § 1154(j) by completing a form called I-485 Supplement J. See 8 C.F.R. § 245.25(a). When a worker applies for porting while his or her I-140 petition is still

pending, the agency resolves the I-140 petition before addressing the portability request. See 81 Fed. Reg. 82,398, 82,418 (2016) (“In the final rule at 8 CFR 245.25(a)(2)(ii)(A) and (B), DHS reaffirms that a qualifying immigrant visa petition has to be approved before DHS examines a portability request under INA 204(j) and determines an individual’s eligibility or continued eligibility to adjust status based on the underlying visa petition.”). However, “just because an immigrant’s I-485

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Lujan v. National Wildlife Federation
497 U.S. 871 (Supreme Court, 1990)
Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Parvati Corp. v. City of Oak Forest, Ill.
630 F.3d 512 (Seventh Circuit, 2010)
In Re IFC Credit Corp.
663 F.3d 315 (Seventh Circuit, 2011)
Scherr v. Marriott International, Inc.
703 F.3d 1069 (Seventh Circuit, 2013)
Apex Digital, Inc. v. Sears, Roebuck & Co.
572 F.3d 440 (Seventh Circuit, 2009)
Kingdomware Technologies, Inc. v. United States
579 U.S. 162 (Supreme Court, 2016)
Srinivasa Musunuru v. Loretta E. Lynch
831 F.3d 880 (Seventh Circuit, 2016)
Schaefer v. Universal Scaffolding & Equipment, LLC
839 F.3d 599 (Seventh Circuit, 2016)
Timothy Ozinga v. Thomas E. Price
855 F.3d 730 (Seventh Circuit, 2017)
Patel v. Garland
596 U.S. 328 (Supreme Court, 2022)
Illya Britkovyy v. Alejandro Mayorkas
60 F.4th 1024 (Seventh Circuit, 2023)
Umeshkumar Soni v. Ur Jaddou
103 F.4th 1271 (Seventh Circuit, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
Bana v. U.S. Citizenship & Immigration Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bana-v-us-citizenship-immigration-services-ilnd-2025.