Chen v. Blinken

CourtDistrict Court, E.D. New York
DecidedFebruary 25, 2025
Docket1:23-cv-02279
StatusUnknown

This text of Chen v. Blinken (Chen v. Blinken) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Chen v. Blinken, (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK P. CHEN, SHIMING CHEN, and YAMINN MEMORANDUM & ORDER , 23-CV-2279 (NGG) Plaintiffs, -against- ANTONY BLINKEN, UNITED STATES SECRETARY OF STATE; NICHOLAS BURNS, UNITED STATES AMBASSADOR TO CHINA; and LISA K. HELLER, UNITED STATES CONSUL GENERAL, GUANGZHOU, Defendants. .

NICHOLAS G. GARAUFIS, United States District Judge. Plaintiffs Xiao P. Chen, Shiming Chen, and Yamin Yan (collec- tively, “Plaintiffs”) brought this action against Defendants Antony Blinken, Nicholas Burns, and Lisa K. Heller (collectively, ‘Defendants”) in their official capacities as United States Secre- tary of State, United States Ambassador to China, and United States Consul General for the United States Consulate in Guang- zhou, China, respectively. (Complaint (“Compl.”) (Dkt. 1).) Plaintiffs ask this court to invalidate Defendants’ decisions deny- ing the immigrant visa applications (“IV Applications”) of Plaintiffs’ respective relatives and to compel Defendants to adju- dicate the IV Applications in accordance with the applicable immigration laws. (See generally id.) Defendants now move to sever this action pursuant to Federal Rule of Civil Procedure 21, and move to dismiss the Complaint pursuant to Federal Rule of Civil Procedure 12(b)(1) and 12(b)(6), asserting that the doc- trine of consular nonreviewability bars judicial review of Defendants’ denial of the IV Applications. (Defendants’ Motion to Sever and Dismiss (“Defs.’ Mot.”) (Dkt. 19-1).) Plaintiffs oppose the motion. (Plaintiffs’ Opposition to Defendants’ Motion to

Sever and Dismiss (“Pls.’ Opp.”) (Dkt. 20).) For the reasons that follow, Defendants’ motion to dismiss is GRANTED, and Defend- ants’ motion to sever is DENIED as moot. Plaintiffs Xiao P. Chen and Shiming Chen’s claims are dismissed with prejudice and Plaintiff Yamin Yan’s claims are dismissed without prejudice. I. BACKGROUND A. Statutory and Regulatory Framework Congress establishes the terms of noncitizen entry into the United States, and the Department of State implements those require- ments at its embassies and consulates in foreign countries. Noncitizens residing outside of the United States typically need a visa to be admitted to the United States. Congress enacted a “streamlined” visa application process for noncitizens with im- mediate relatives in the United States whereby the citizen first files a petition with the United States Citizenship and Immigra- tion Services (“USCIS”) to have the noncitizen classified as an immediate relative, and, if USCIS approves the petition, then the noncitizen-relative may apply for an immigrant visa. See Dep’t of State v. Mufioz, 602 U.S. 899, 904 (2024) (“Munoz II’”);' 8 U.S.C. §§ 1151(b)(2)(A)@, 1154(a)(1)(A), 1201(@), 1202(b). A United States consular officer located in the consular district where the noncitizen resides then reviews the noncitizen’s visa application, interviews the applicant, and decides whether to is- sue the noncitizen a visa to enter the United States. See 8 U.S.C. §§ 1201(a)(1), 1202; 22 C.F.R. §§ 42.61, 42.62. Upon a deter- mination that a noncitizen visa applicant is ineligible for admission into the United States, consular officers must provide the noncitizen with a timely written notice that “(A) states the determination, and (B) lists the specific provision or provisions

1 When quoting cases, unless otherwise noted, all citations and internal quotation marks are omitted, and all alterations are adopted.

of law under which the [noncitizen] is inadmissible.” 8 U.S.C. 8 1182(b)(1). B. Factual and Procedural Background 1. Immigrant Visa Applications? Plaintiff Xiao P. Chen (“Plaintiff Xiao” or “Xiao”) resides in Queens, New York and is a United States citizen. (Compl. 4 5.) In 2007, Plaintiff Xiao filed a petition with USCIS to have her sister, Xiaolian Chen, who lived in China at the time, classified as Plaintiff Xiao’s immediate relative. (id. ({ 11-12.) USCIS ap- proved the petition on January 27, 2010. (Id. § 11.) Xiaolian Chen then submitted an immigrant visa application. (Id. 4 12.) On October 25, 2021, a consular officer at the United States Con- sulate in Guangzhou interviewed Xiaolian Chen. (Id. { 15.) Two days later, the consulate denied Xiaolian Chen’s visa application on the grounds of “[f]raud or misrepresentation” pursuant to Im- migration and Nationality Act Section 212(a)(6)(C) (codified at 8 U.S.C. § 1182(a)(6)(C)). (Compl., Exhibit A (“Xiolian Chen IV Application Denial”).) The denial also indicated that a waiver may be available, directing Xiaolian Chen to contact USCIS. (Id.) Plaintiff Xiao suspects that “the denial was based on a prior peti- tion filed for the benefit of Xiaolian Chen by a prior husband, which was denied in 2005.” (Compl. { 18.) Through counsel, Plaintiff Xiao reached out to the consulate to dispute the denial and also reached out to LegalNet, an email service operated by the Department of State for case-specific legal inquiries concern- ing U.S. visas. dd. 9 18-20.) Plaintiff Xiao submitted “numerous correspondences and internal appeals” to Defendants, none of which were successful in overturning the denial. (Ud. § 21.) De- fendants maintain that their denial of Xiaolian Chen’s visa

2 The following facts are drawn from the Complaint and, for purposes of this motion to dismiss, are assumed to be true. See Ark. Pub. Emps. Ret. Sys. v. Bristol-Myers Squibb Co., 28 F.4th 343, 349 (2d Cir. 2022).

application was proper under 8 U.S.C. § 1182(a)(6)(C). (See Re- ply in Support of Defendants’ Motion to Sever and Dismiss (“Defs.’ Reply’) (Dkt. 21) at 13.) Plaintiff Shiming Chen (“Plaintiff Shiming” or “Shiming”) resides in Brooklyn, New York and is a United States citizen. (Compl. 46.) In 2018, Plaintiff Shiming filed a petition with USCIS to have his mother, Jinyu Deng, who lived in China at the time, classified as his immediate relative. (Id. {{ 22-23.) USCIS approved the petition on December 11, 2018. Ud. 4 22.) Deng then submitted an immigrant visa application. (Id. € 23.) On May 10, 2021, a consular officer at the United States Consulate in Guangzhou interviewed Deng and informed her that her appli- cation was being denied. (Id. { 26.) The consulate denied the Jinyu Deng’s visa application on the grounds of “[f]raud or mis- representation” pursuant to Immigration and Nationality Act Section 212(a)(6)(C). (Compl., Exhibit C (Jinyu Deng IV Appli- cation Denial”) at 1.) The denial also indicated that a waiver may be available, directing Deng to contact USCIS. id.) Along with the denial, Deng was also given another form which noted that her case “require[d] additional processing” and requested that she submit her passport and a copy of the certificate of divorce from her former husband, Pui Sum Lam. (Id. at 4.) Plaintiff Shim- ing suspects that “the denial was based on a prior petition filed for the benefit of his mother Jinyu Deng by her prior husband, Piu Sum Lam, which was denied in 2009.” (Compl.

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