Bangert v. U.S. Embassy In Ethiopia, Consular Section

CourtDistrict Court, N.D. Illinois
DecidedJuly 8, 2025
Docket3:24-cv-50272
StatusUnknown

This text of Bangert v. U.S. Embassy In Ethiopia, Consular Section (Bangert v. U.S. Embassy In Ethiopia, Consular Section) 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
Bangert v. U.S. Embassy In Ethiopia, Consular Section, (N.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

DYLAN BANGERT, ) ) Plaintiff, ) ) v. ) No. 3:24 C 50272 ) U.S. EMBASSY IN ETHIOPIA, CONSULAR ) Judge Rebecca R. Pallmeyer SECTION, NATIONAL VISA CENTER, ) UNITED STATES CITIZEN AND ) IMMIGRATION SERVICES, )

Defendants.

MEMORANDUM OPINION AND ORDER Dylan Bangert’s wife, Afomiya Animaw, is a citizen and resident of Ethiopia. Bangert has filed this pro se complaint seeking an order that would direct Defendants—the United States Citizen and Immigration Services (“USCIS”), the United States Embassy in Addis Ababa, Ethiopia (“the Embassy”), and the National Visa Center (“NVC”)—to schedule a visa interview for Animaw, and then to approve her immediate-relative visa application. The visa would enable Animaw to apply for a Green Card in the United States and escape the grave risk of violence, abduction, and sex trafficking that Bangert alleges she faces in Ethiopia. As the court understands Bangert’s pleadings, he asserts that Defendants owe him and/or his wife Animaw a duty to schedule Animaw’s visa interview and to approve her visa application. Bangert suggests that the source of this duty is an unenumerated right under the Fifth or Ninth Amendments of the Constitution, or the Immigration and Nationality Act (“INA”). Bangert seeks a writ of mandamus, or other injunctive relief, pursuant to 42 U.S.C. §§ 1983, 1985, or 1986, the Administrative Procedure Act (“APA”), or a common law negligence theory. In response to Defendants’ motion to dismiss [16], Bangert confirms that he does not seek an award of damages. Bangert’s complaint suggests that he believes the NVC is a rogue organization within the government that has been lawlessly interfering with Animaw’s visa case. As the court explains below, that is not true: the United States Department of State (“State Department”) is tasked by statute with adjudicating Animaw’s immediate-relative visa application, and the NVC is the entity within the State Department that handles these applications. Although Bangert urges that USCIS, which is part of the Department of Homeland Security, should process Animaw’s application, USCIS’s only role in the immediate-relative visa application process is to verify that the noncitizen applicant is, in fact, the spouse, child, or parent of the citizen. USCIS then forwards that information to the NVC and becomes involved again in processing the noncitizen’s Green Card application only if the visa is approved. Bangert’s contention that USCIS is responsible to act now is a non-starter, and all claims against USCIS are dismissed with prejudice. Similarly, because the court has no authority to order either the NVC or the Embassy to approve Animaw’s visa application regardless of what facts Bangert might allege, his claims are dismissed with prejudice to the extent they seek such an order. Finally, while Bangert may have a basis to bring a claim against the NVC and the Embassy for unreasonable delay in adjudicating Animaw’s visa application, the allegations of Bangert’s initial complaint do not sustain that claim, and it is dismissed without prejudice. As explained below, any unreasonable delay claim would have to be asserted pursuant to the APA: Bangert has no constitutionally protected interest in Animaw’s visa application and the court lacks jurisdiction to consider claims for injunctive relief against the federal government based on a negligence theory. Should Bangert choose to pursue the APA claim in an amended complaint, he is warned that the new complaint should consist of a list of numbered paragraphs containing a short and plain statement of his allegations and his claims for relief. The initial complaint Bangert submitted is insufficient, as it presents little more than emails attached to a form complaint. Further, to state a claim for unreasonable delay, Bangert must allege, at a minimum, the date by which Animaw’s visa application with the NVC became “documentarily complete”—that is, the date by which Animaw and Bangert had submitted all the necessary forms and fees associated with the application. 1 BACKGROUND This dispute concerns the application of Bangert’s wife, Afomiya Animaw, for an immediate-relative immigrant visa. The court reviews the process by which these visas are issued before describing the allegations in Bangert’s complaint. I. Statutory and Regulatory Background Under the INA, noncitizens who are the “immediate relatives” of a United States citizen— the citizen’s spouse, children, and, if the citizen is at least 21 years old, parents—may apply for lawful permanent resident status, also known as a “Green Card.” See 8 U.S.C. §§ 1186a(a)(1), h(1); § 1151(b)(2)(A)(i); Green Card for Immediate Relatives of U.S. Citizen, USCIS, https://www.uscis.gov/green-card/green-card-eligibility/green-card-for-immediate-relatives-of-us- citizen (last visited July 3, 2025). Noncitizens may not apply for a Green Card, however, until an immigrant visa is available for them. See I-485, Application to Register Permanent Residence or Adjust Status, USCIS, https://www.uscis.gov/i-485 (last visited July 3, 2025). The number of visas available each year for some categories of immigrants are capped by the INA, but for other categories—including immediate relatives of citizens—there is no numerical limit. Compare 8 U.S.C. §§ 1151(a), 1152(a) with § 1151(b). But there are also no guarantees, and noncitizen spouses are not always granted this visa. The process of obtaining an immediate-relative visa consists of two steps. First, the U.S. citizen who seeks to claim an applicant as an immediate relative must petition the United States Attorney General to have their relative classified as such. 8 U.S.C. §§ 1154(a)(1)(A)(i), (b); 8

1 If he chooses to submit a proposed amended complaint, Bangert is encouraged to contact the court’s Pro Se Help Desk. See U.S. DIST. CT. N.D. ILL., Pro Se / Representing Yourself, https://www.coop.ilnd.uscourts.gov/LandingPage.php?page=pro_se; U.S. DIST. CT. N.D. ILL., Hibbler Federal Court Help Desk, https://hibbler-memorial-pro-se-assistance- program.appointlet.com. C.F.R. § 204.1(a)(1). This petition is submitted to USCIS via Form I-130. Form I-130: Petition for Alien Relative, USCIS, https://www.uscis.gov/i-130 (last visited July 3, 2025). Form I-130 simply requests classification as an immediate relative; it does not itself qualify as an application for a visa or Green Card.2 8 U.S.C. § 1154(b); I-485, Application to Register Permanent Residence or Adjust Status, USCIS, https://www.uscis.gov/i-485 (last visited July 3, 2025). I-130 petitioners may request that USCIS expedite its review process; USCIS considers such requests on a case- by-case basis. Expedite Requests, USCIS, https://www.uscis.gov/forms/filing-guidance/ expedite-requests (last visited July 3, 2025). In deciding whether to expedite review of a petition, USCIS considers a number of criteria, including “[e]mergencies or urgent humanitarian situations.” Id. If USCIS finds that the noncitizen qualifies as an immediate relative of the petitioner, USCIS then approves the I-130 petition and forwards it to the NVC, an organ of the State Department. 8 U.S.C. § 1154(b); Immigrant Visa Process, Step 2: Begin National Visa Center Processing, U.S.

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Bangert v. U.S. Embassy In Ethiopia, Consular Section, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bangert-v-us-embassy-in-ethiopia-consular-section-ilnd-2025.