Bekkam v. United States Department of Homeland Security

CourtDistrict Court, District of Columbia
DecidedOctober 10, 2025
DocketCivil Action No. 2025-2010
StatusPublished

This text of Bekkam v. United States Department of Homeland Security (Bekkam v. United States Department of Homeland Security) 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
Bekkam v. United States Department of Homeland Security, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

RAKESH BEKKAM,

Plaintiff,

v. Civil Action No. 25 - 2010 (LLA) UNITED STATES DEPARTMENT OF HOMELAND SECURITY,

Defendant.

MEMORANDUM OPINION

Plaintiff Rakesh Bekkam, a citizen of India, challenges the revocations of his H-1B visa

and H-1B cap number by the U.S. Department of Homeland Security (“DHS”). ECF No. 1. DHS

has moved to transfer this action to the District of Maryland and to extend the time to respond to

the complaint until twenty-one days after the action is docketed there. ECF No. 6, at 1.

Mr. Bekkam consents to the motion. Id. For the reasons explained below, the court will grant

DHS’s motion.

I. FACTUAL BACKGROUND AND PROCEDURAL HISTORY

The court takes the allegations in Mr. Bekkam’s complaint as true for the purposes of

deciding the pending motion. Louis v. Hagel, 177 F. Supp. 3d 401, 403 (D.D.C. 2016). The

Immigration and Nationality Act (“INA”) allows employers to petition for H-1B nonimmigrant

visas on behalf of noncitizen beneficiaries. 8 U.S.C. § 1184(c)(1); see 8 C.F.R. § 214.2(h)(2), (4)

(2025); Taylor Made Software, Inc. v. Cuccinelli, 453 F. Supp. 3d 237, 240-41 (D.D.C. 2020).

Access to H-1B visas is limited. With some exceptions, the INA caps the number of H-1B visa

petitions that may be granted each fiscal year at 65,000. 8 U.S.C. § 1184(g). Mr. Bekkam is a citizen of India who resides in Hyderabad. ECF No. 1 ¶ 1. In

August 2022, the U.S. Customs and Immigration Services (“USCIS”) approved an H-1B visa

petition that Mr. Bekkam’s prospective employer had filed on his behalf. Id. ¶¶ 120-121. When

Mr. Bekkam’s H-1B petition was approved, Mr. Bekkam was counted against the annual H-1B

cap and assigned a “cap number.” Id. ¶ 70. Persons with an H-1B cap number have the right to

transfer employers and potentially exceed the traditional six-year limit on H-1B status. Id. ¶ 169.

In July 2023, another prospective employer filed a transfer visa petition on Mr. Bekkam’s behalf.

Id. ¶ 123.

In February 2025, Mr. Bekkam traveled to India, which required him to update his H-1B

visa. Id. ¶ 124-125. He dropped his materials off at the U.S. Consulate in Chennai, India, and the

Consulate thereafter notified him that his visa had been refused and requested that he attend an

in-person interview. Id. ¶¶ 125-127. At the interview, Mr. Bekkam was told that “DHS-USCIS

determined he was inadmissible for providing false or misleading statement[s]” and that, as a

result, his visa had been “refused under INA [§] 212(a)(6)(C)(i).” Id. ¶ 128; see 8 U.S.C.

§ 1182(a)(6)(C)(i) (“Any alien who, by fraud or willfully misrepresenting a material fact, seeks to

procure (or has sought to procure or has procured) a visa, other documentation, or admission into

the United States or other benefit provided under this [Act] is inadmissible.”). Mr. Bekkam

challenged the refusal and sought to correct his records, but he was unsuccessful. ECF No. 1

¶ 129. The USCIS also revoked Mr. Bekkam’s H-1B cap number. Id. ¶ 131.

Mr. Bekkam filed this action in June 2025, challenging the revocations of his H-1B visa

and his H-1B cap number. ECF No. 1. Mr. Bekkam argues that DHS found him inadmissible for

making false or misleading statements without notice or a hearing and revoked his H-1B cap

number in violation of the Administrative Procedure Act (“APA”), 5 U.S.C. § 551 et seq. ECF

2 No. 1 ¶¶ 134-179. Mr. Bekkam also seeks to enjoin DHS’s “legislative rule prohibiting employers

from filing multiple H-1B applications,” which he alleges DHS enacted without conducting

notice-and-comment rulemaking, in violation of the APA. Id. at 1, 30.

II. LEGAL STANDARD

Under 28 U.S.C. § 1404(a), a court may transfer a case from one proper venue to another

appropriate venue if it serves “the convenience of parties and witnesses” and is “in the interest of

justice.”1 This is an “individualized, case-by-case consideration,” comprised of two steps. Stewart

Org. v. Ricoh Corp., 487 U.S. 22, 29 (1988) (quoting Van Dusen v. Barrack, 376 U.S. 612, 622

(1964)). First, the transferor court must determine that the action “[could] have been brought” in

the transferee district or that the parties consent to litigating there. 28 U.S.C. § 1404(a). Second,

the court must decide whether “considerations of convenience and the interest of justice weigh in

favor of transfer to that district.” Blackhawk Consulting, LLC v. Fed. Nat’l Mortg. Ass’n, 975 F.

Supp. 2d 57, 59 (D.D.C. 2013). In making this determination, the court “weigh[s] several

private- and public-interest factors.” Id. at 59-60. The private-interest factors include: “(1) the

plaintiff’s choice of forum; (2) the defendant’s preferred forum; (3) the location where the claim

arose; (4) the convenience of the parties; (5) the convenience of the witnesses; and (6) ease of

access to sources of proof.” Id. at 60. The public-interest factors include: “(1) the transferee’s

familiarity with the governing law; (2) the relative congestion of the courts of the transferor and

potential transferee; and (3) the local interest in deciding local controversies at home.” Id. (quoting

Onyeneho v. Allstate Ins. Co., 466 F. Supp. 2d 1, 3 (D.D.C. 2006)). “If the balance of private and

1 In contrast, 28 U.S.C. § 1406(a) governs transfer or dismissal when the initial venue is improper. See Liu v. Mayorkas, 737 F. Supp. 3d 1, 3-5 (D.D.C. 2024). Here, venue is proper in this district under 28 U.S.C. § 1391(e)(1)(A) because DHS is headquartered in the District of Columbia.

3 public interests favor[s] a transfer of venue, then a court may order a transfer.” Id. (quoting Sheffer

v. Novartis Pharms. Corp., 873 F. Supp. 2d 371, 375 (D.D.C. 2012)).

III. DISCUSSION

A. Motion to Transfer Venue

Mr. Bekkam consents to DHS’s motion to transfer. ECF No. 6, at 1. Nevertheless, the

court will consider the facts and determine whether transferring this case to the District of

Maryland is in the interest of justice. Stewart Org., 487 U.S. at 29 (“Section 1404(a) is intended

to place discretion in the district court to adjudicate motions for transfer according to an

‘individualized, case-by-case consideration of convenience and fairness.’” (quoting Van Dusen,

376 U.S. at 622)).

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

Related

Van Dusen v. Barrack
376 U.S. 612 (Supreme Court, 1964)
Stewart Organization, Inc. v. Ricoh Corp.
487 U.S. 22 (Supreme Court, 1988)
Al-Ahmed v. Chertoff
564 F. Supp. 2d 16 (District of Columbia, 2008)
Trout Unlimited v. United States Department of Agriculture
944 F. Supp. 13 (District of Columbia, 1996)
Onyeneho v. Allstate Insurance
466 F. Supp. 2d 1 (District of Columbia, 2006)
National Wildlife Federation v. Harvey
437 F. Supp. 2d 42 (District of Columbia, 2006)
Johnson v. Lumenos, Inc.
471 F. Supp. 2d 74 (District of Columbia, 2007)
Mohammadi v. Scharfen
609 F. Supp. 2d 14 (District of Columbia, 2009)
Blackhawk Consulting, LLC v. Federal National Mortgage Association
975 F. Supp. 2d 57 (District of Columbia, 2013)
Sheffer v. Novartis Pharmaceuticals Corporation
873 F. Supp. 2d 371 (District of Columbia, 2012)
Louis v. Hagel
177 F. Supp. 3d 401 (District of Columbia, 2016)
Ngonga v. Sessions
318 F. Supp. 3d 270 (D.C. Circuit, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
Bekkam v. United States Department of Homeland Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bekkam-v-united-states-department-of-homeland-security-dcd-2025.