Bonsi v. Bitter

CourtDistrict Court, District of Columbia
DecidedJanuary 23, 2025
DocketCivil Action No. 2023-3740
StatusPublished

This text of Bonsi v. Bitter (Bonsi v. Bitter) 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
Bonsi v. Bitter, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

SHIRLEY Y. BONSI et al.,

Plaintiffs,

v. Civil Action No. 23-3740 (TJK) RENA BITTER, Assistant Secretary for Con- sular Affairs, Department of State, et al.,

Defendants.

MEMORANDUM OPINION

Barbara Bonsi and her two daughters are residents of Ghana who want to join her mother

in the United States. Bonsi’s visa application has been pending since 2022, and officials at the

U.S. Embassy in Accra have yet to schedule her for a consular interview—a necessary step toward

receiving a visa. The family sued Defendants, claiming they have unreasonably delayed pro-

cessing of the application. Defendants move to dismiss. Although the Court sympathizes with

Plaintiffs’ situation, their complaint does not plausibly allege that the delay is unreasonable. So

the Court will grant the motion and dismiss the case.

I. Background

United States citizens wishing to bring their foreign national relatives to the United States

must file a Petition for Alien Relative (Form I-130) with the United States Citizenship and Immi-

gration Services (“USCIS”). See 8 U.S.C. § 1154; 8 C.F.R. § 204.1(a)(1). Upon approval of the

petition, USCIS sends the application to the State Department’s National Visa Center (“NVC”) for

processing. See 8 C.F.R. § 204.2(a)(3)(i). The foreign relative must then submit additional paper-

work, including a visa application (Form DS-260), and fees. See 22 C.F.R. § 42.63; 9 Foreign

Affs. Manual § 504.1-2(b). Once the applicant does so, the NVC designates the case “documentarily complete” and coordinates with the appropriate consulate or embassy to schedule

the applicant for a required consulate interview. See 22 C.F.R. § 42.62; 9 Foreign Affs. Manual

§ 504.1-2(b)-(d). “Appointments are generally scheduled in the chronological order of the docu-

mentarily complete applicants.” 9 Foreign Affs. Manual § 504.1-2(d)(1). After the interview, the

consular officer “must” either “issue the visa” or “refuse” it. 22 C.F.R. § 42.81(a).

Bonsi’s mother, a U.S. citizen, filed a I-130 Petition on behalf of her daughter and grand-

daughter, who currently live in Ghana. ECF No. 1 (“Compl.”) ¶¶ 11, 13. USCIS approved the

petition in 2014 and forwarded it to the U.S. Embassy in Accra for further processing. Id. ¶¶ 11,

18. In 2017, Bonsi received her “NVC welcome letter” instructing her to submit her DS-260 visa

application. Id. ¶ 19. Plaintiffs do not specify when Bonsi did so. But in February 2022, Plaintiffs

were told that the application was “documentarily complete” and “awaiting an interview appoint-

ment.” Id. ¶ 21. Despite their efforts to contact the State Department, the family has received no

meaningful updates on the status of their visa application and have yet to be scheduled for an

interview. See id. ¶¶ 22–23, 25–29.1

Tired of waiting, Plaintiffs sued in December 2023, seeking to compel Defendants to

schedule an interview and decide the visa application, among other things. See Compl. (“Prayer

for Relief”). Defendants now move to dismiss for failure to state a claim.2 See ECF No. 10.

1 In October 2022, Barbara Bonsi’s second daughter was born. She too “will . . . seek . . . to accompany her mother to the United States.” Compl. ¶ 14. 2 Although Defendants first say they also move to dismiss under Federal Rule of Civil Procedure 12(b)(1), ECF No. 10 at 6, they nowhere challenge the Court’s subject-matter jurisdic- tion. Nor does the Court discern any basis to do so here. To the contrary, courts routinely decide similar cases challenging the State Department’s delay in adjudicating visa applications. See, e.g., Khan v. Bitter, No. 23-cv-1576 (BAH), 2024 WL 756643 (D.D.C. Feb. 23, 2024).

2 II. Legal Standard

To survive a motion to dismiss under Rule 12(b)(6), a plaintiff must allege “sufficient fac-

tual 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. 554, 570 (2007)).

Though “a court must accept as true all of the allegations contained in a complaint,” “[t]hreadbare

recitals of the elements of a cause of action, supported by mere conclusory statements, do not

suffice.” Id. Rather, a claim is “plausible when it contains factual allegations that, if proved,

would ‘allow[] the court to draw the reasonable inference that the defendant is liable for the mis-

conduct alleged.’” Banneker Ventures, LLC v. Graham, 798 F.3d 1119, 1129 (D.C. Cir. 2015)

(alteration in original) (quoting Twombly, 550 U.S. at 556). And the court “may consider only the

facts alleged in the complaint, any documents either attached to or incorporated in the complaint

and matters of which [the court] may take judicial notice.” EEOC v. St. Francis Xavier Parochial

Sch., 117 F.3d 621, 624 (D.C. Cir. 1997).

III. Analysis

Plaintiffs’ claims must be dismissed because the delay in adjudicating the visa application

is not unreasonable as a matter of law. Plaintiffs bring their unreasonable delay claims under the

APA, 5 U.S.C. § 706, and the Mandamus Act, 28 U.S.C. § 1361. The Court applies the same legal

standard to both claims, Skalka v. Kelly, 246 F. Supp. 3d 147, 152 (D.D.C. 2017), and must deter-

mine “whether the agency’s delay is so egregious as to warrant mandamus.” In re Core Commc’ns,

Inc., 531 F.3d 849, 855 (D.C. Cir. 2008) (citation omitted). To help guide this inquiry, the D.C.

Circuit has laid out a six-factor test:

(1) the time agencies take to make decisions governed by a “rule of reason”;

(2) where Congress has provided a timetable or other indication of the speed with which it expects the agency to proceed in enabling the statute, that statutory scheme may supply content for this rule of reason;

3 (3) delays that might be reasonable in the sphere of economic regulation are less tolerable when human health and welfare are at stake;

(4) the court should consider the effect of expedited delay action on agency activ- ities of a higher or competing priority;

(5) the court should also take into account the nature and extent of the interests prejudiced by delay; and

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Mashpee Wampanoag Tribal Council, Inc. v. Norton
336 F.3d 1094 (D.C. Circuit, 2003)
In Re Core Communications, Inc.
531 F.3d 849 (D.C. Circuit, 2008)
In Re Barr Laboratories, Inc.
930 F.2d 72 (D.C. Circuit, 1991)
Banneker Ventures, LLC v. Jim Graham
798 F.3d 1119 (D.C. Circuit, 2015)
American Hospital Association v. Sylvia Burwell
812 F.3d 183 (D.C. Circuit, 2016)
Skalka v. Johnson
246 F. Supp. 3d 147 (District of Columbia, 2017)
Islam v. Heinauer
32 F. Supp. 3d 1063 (N.D. California, 2014)

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