Bonafos De Belinay v. Mayorkas

District Court, District of Columbia·Decided March 3, 2025·No. Civil Action No. 2024-0240·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

HUBERT DE BONAFOS DE BELINAY,

Plaintiff,

v. Case No. 1:24-cv-00240 (CRC)

ALEJANDRO N. MAYORKAS, et al.,

Defendants.

MEMORANDUM OPINION & ORDER

Plaintiff Hubert de Bonafos de Belinay, a French citizen, brings this action to compel

several government agencies to adjudicate his nonimmigrant visa application. In August 2023,

the United States Citizenship and Immigration Services (“USCIS”) approved Plaintiff’s

application for an E-2 nonimmigrant treaty-investor visa. Three months later, Plaintiff attended

an interview at the U.S. Embassy in Paris to finalize the application. Following the interview,

the Embassy informed Plaintiff that his application had been placed into administrative

processing, leaving his case stalled with no clear timeline for resolution. Plaintiff then initiated

this action asserting that the government has unlawfully delayed final adjudication of his

application and seeking to compel the defendants to conclusively decide it. The government has

moved to dismiss the complaint for lack of subject matter jurisdiction and failure to state a claim.

Concluding that Plaintiff has standing, and that subject matter jurisdiction otherwise lies, the

Court will dismiss Plaintiff’s unreasonable delay claim for failure to state a claim. But it will

deny the motion as to his due process claim, as the government challenges only Plaintiff’s

standing to bring that claim, not the claim’s merits. I. Background

The Court draws the following background from the allegations in the Complaint

(“Compl.”).

Hubert de Bonafos de Belinay, a citizen of France, resides in Paris with his family.

Compl. ¶¶ 4, 8. In August 2023, USCIS approved Plaintiff’s application for an E-2

nonimmigrant visa. Id. ¶ 9. The E-2 visa is available to foreign nationals from certain countries

who invest substantial capital in a U.S. business, enabling them to manage and develop their

enterprise. See 8 U.S.C. § 1101(a)(15)(E)(ii); 22 C.F.R. § 41.51; Compl. ¶ 9.

In preparation to obtain an E-2 visa stamp for foreign travel, Plaintiff scheduled an

interview at the U.S. Embassy in Paris for November 2023. Id. ¶ 10. As requested by the

Embassy, he submitted a new E-2 application three weeks before the interview. Id. ¶ 11. At the

interview, however, Plaintiff was informed that his application was “rejected” and that the

Embassy required “additional information for national security purposes.” Id. ¶ 12. Plaintiff

was given a form containing supplemental questions concerning his application, which he

completed and returned one week after the interview. Id.

The following month, in December 2023, Plaintiff sent a follow-up email to the Embassy

seeking an update on the status of his application. Id. ¶ 13. The Embassy responded that the

application was still in “administrative processing.” Id. Plaintiff’s subsequent efforts to obtain

updates through both direct inquiries and congressional assistance have yielded no information

or timeline for adjudication. Id. ¶¶ 13–15.

Plaintiff alleges that the delay has caused severe personal and financial harm to him and

his family. See id. ¶¶ 17–25. He claims his business has lost contracts, suffered employee

resignations, and incurred substantial financial burdens due to his inability to travel to the United

2 States. Id. ¶¶ 18–22, 24. Additionally, Plaintiff alleges his family has experienced disruptions,

including his children’s inability to attend school in the United States, further compounding the

emotional toll of the delay. Id. ¶¶ 23, 25.

In January 2024, Plaintiff filed this action against Alejandro Mayorkas, Secretary of the

Department of Homeland Security (“DHS”), Antony Blinken, Secretary of State, and David

McCawley, Deputy Chief of Mission of the U.S. Embassy in Paris, in their official capacities.

Id. ¶¶ 5–7.1 He contends that the Administrative Procedure Act (“APA”), 5 U.S.C. §§ 555(b),

706(1), and the Mandamus Act, 28 U.S.C. § 1361, compel the defendants to adjudicate his visa

application without unreasonable delay and seeks a court order to that effect (Counts 1 & 3).

Compl. ¶¶ 26–35, 39–43. Plaintiff also brings a claim under the Due Process Clause of the Fifth

Amendment, asserting that the delay in processing his application has deprived him of

procedural and substantive due process (Count 2). Id. ¶¶ 32–38. The defendants have moved to

dismiss the complaint for lack of subject matter jurisdiction under Federal Rule of Civil

Procedure 12(b)(1) and failure to state a claim under Rule 12(b)(6).

II. Legal Standards

When analyzing a motion to dismiss under either Rule 12(b)(1) or 12(b)(6), the Court

“must treat the complaint’s factual allegations as true[] and must grant plaintiff the benefit of all

inferences that can be derived from the facts alleged.” Giliana v. Blinken, 596 F. Supp. 3d 13,

17 (D.D.C. 2022) (Cooper, J.) (quoting Sparrow v. United Air Lines, Inc., 216 F.3d 1111, 1113

1 Plaintiff filed his complaint before the recent change in administrations and thus named individuals who no longer hold office as defendants in their official capacities. As appropriate, the Court substitutes the individuals currently holding these offices as named defendants. See Fed. R. Civ. P. 25(d). Specifically, the Court substitutes Secretary of State Marco Rubio in place of former Secretary Blinken, and Department of Homeland Security Secretary Kristi Noem in place of former Secretary Mayorkas.

3 (D.C. Cir. 2000)). However, a court need not accept inferences drawn by the plaintiff that are

unsupported by facts alleged in the complaint nor accept a plaintiff’s legal conclusions as true.

Browning v. Clinton, 292 F.3d 235, 242 (D.C. Cir. 2002). Under Rule 12(b)(1), the plaintiff

bears the burden of establishing jurisdiction by a preponderance of the evidence. See Lujan v.

Defs. of Wildlife, 504 U.S. 555, 561 (1992). But on a 12(b)(6) challenge, the defendant bears

the burden, and must show that the complaint does not “contain sufficient factual matter,

accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556

U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007))”

III. Analysis

The government advances five arguments in support of its motion to dismiss: (1) Plaintiff

lacks standing; (2) the Secretary of Homeland Security and the Secretary of State are improper

parties; (3) the doctrine of consular nonreviewability bars judicial review of the delay; (4) the

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