Chen v. Noem

CourtCourt of Appeals for the Second Circuit
DecidedMay 22, 2025
Docket24-2058
StatusUnpublished

This text of Chen v. Noem (Chen v. Noem) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Chen v. Noem, (2d Cir. 2025).

Opinion

24-2058 Chen v. Noem

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 22nd day of May, two thousand twenty-five.

Present: GUIDO CALABRESI, BARRINGTON D. PARKER, JR., WILLIAM J. NARDINI, Circuit Judges. _____________________________________

BAOMING CHEN,

Plaintiff-Appellant,

v. 24-2058-cv

KRISTI NOEM, IN HER OFFICIAL CAPACITY AS SECRETARY OF THE DEPARTMENT OF HOMELAND SECURITY, AND UR M. JADDOU, IN HER OFFICIAL CAPACITY AS DIRECTOR OF U.S. CITIZENSHIP AND IMMIGRATION SERVICES,

Defendants-Appellees. ∗ _____________________________________

∗ Pursuant to Federal Rule of Appellate Procedure 43(c)(2), the Clerk of Court is respectfully directed to amend the caption as reflected above. 1 For Plaintiff-Appellant: SAMUEL I. FERENC (Andrew T. Tutt, Tess C. Saperstein, on the brief), Arnold & Porter Kaye Scholer LLP, Washington, D.C., and New York, NY; Jan Potemkin, Esq., Law Office of Jan Potemkin, New York, NY.

For Defendants-Appellees: ELLIOT M. SCHACHNER (Varuni Nelson, on the brief), Assistant United States Attorneys, for John J. Durham, United States Attorney for the Eastern District of New York, New York, NY.

Appeal from a judgment of the United States District Court for the Eastern District of New

York (Pamela K. Chen, District Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

DECREED that the appeal is DISMISSED as moot, the June 6, 2024, judgment of the district

court is VACATED, and the case is REMANDED with instructions to dismiss the complaint for

lack of subject matter jurisdiction.

Plaintiff-Appellant Baoming Chen, a native and citizen of the People’s Republic of China,

appeals from a judgment of the United States District Court for the Eastern District of New York

(Pamela K. Chen, District Judge) entered on June 6, 2024, dismissing for failure to state a claim

Chen’s action against Defendants-Appellees, the Secretary of the Department of Homeland

Security and the Director of U.S. Citizenship and Immigration Services (USCIS) (collectively, the

“Government”). See Chen v. Mayorkas, 736 F. Supp. 3d 151 (E.D.N.Y. 2024). Chen brought

this action pursuant to the Mandamus Act, 28 U.S.C. § 1361, and the judicial review provisions of

the Administrative Procedure Act, 5 U.S.C. § 706(1), seeking a court order directing USCIS to

adjudicate and approve within 30 days his I-601A Application for Provisional Unlawful Presence

Waiver (“I-601A”), which, he contends, USCIS had unreasonably delayed adjudicating. After

the district court granted the Government’s motion to dismiss pursuant to Federal Rule of Civil 2 Procedure (“Rule”) 12(b)(6), and shortly after Chen filed his notice of appeal, USCIS approved

his I-601A. Despite receiving the relief he sought, Chen continues to pursue his appeal, invoking

two exceptions to the mootness doctrine—“voluntary cessation” of the challenged conduct and

issues “capable of repetition, yet evading review.” We assume the parties’ familiarity with the

case.

“Article III of the Constitution grants the Judicial Branch authority to adjudicate ‘Cases’

and ‘Controversies.’” Already, LLC v. Nike, Inc., 568 U.S. 85, 90 (2013). 1 “To qualify as a case

fit for federal-court adjudication, ‘an actual controversy must be extant at all stages of review, not

merely at the time the complaint is filed.’” Arizonans for Official English v. Arizona, 520 U.S.

43, 67 (1997) (quoting Prieser v. Newkirk, 422 U.S. 395, 401 (1975)). “A case becomes moot

. . . when the issues presented are no longer live or the parties lack a legally cognizable interest in

the outcome,” Already, 568 U.S. at 91, making it “impossible for a court to grant any effectual

relief whatever to the prevailing party,” Am. Freedom Def. Initiative v. Metro. Transp. Auth., 815

F.3d 105, 109 (2d Cir. 2016).

Chen does not dispute that his unreasonable delay claim was mooted when the Government

granted his then-pending I-601A waiver. He nevertheless argues that approval of his I-601A soon

after he filed this notice of appeal constituted a “tactic to evade judicial review,” Appellant’s Br.

at 62, which triggers the voluntary cessation doctrine—“an exception to mootness that applies

where a defendant voluntarily ceases the offending conduct—[that] aims to prevent parties from

evading judicial review . . . by temporarily altering questionable behavior.” Ruesch v. Comm’r of

Internal Revenue Serv., 25 F.4th 67, 70-71 (2d Cir. 2022).

1 Unless otherwise indicated, when quoting cases, all internal quotation marks, alteration marks, emphases, footnotes, and citations are omitted. 3 As an initial matter, Chen offers no adequate basis for his contention that the Government’s

adjudication of his waiver was done as a matter of gamesmanship, in a ploy to thwart appellate

review. All he points to is the fact that the Government granted the waiver on August 5, 2024—

three calendar days (and as Chen points out, only one business day) after he filed his notice of

appeal. This approval occurred approximately 40 months after Chen filed his application, which

is consistent with USCIS’s publicly disclosed data that as of June 5, 2024, it was then processing

80% of I-601A applications within 43 months, Joint App’x at 51 (quoting USCIS, Check Case

Processing Times, https://egov.uscis.gov/processing-times/ (last visited June 5, 2024))—a fact of

which we can take judicial notice, see United States v. Akinrosotu, 637 F.3d 165, 168 (2d Cir.

2011) (taking judicial notice of government website, which listed defendant’s projected release

date from prison). 2

Putting aside the question of strategic behavior, we have held that “[a]n alleged

wrongdoer’s voluntary cessation of a disputed action will still render a case moot if the wrongdoer

can show that (1) there is no reasonable expectation the action will recur, and (2) interim relief or

events have completely and irrevocably eradicated the effects of the alleged violation,” Srour v.

New York City, 117 F.4th 72, 82 (2d Cir. 2024). The Government satisfies both requirements

here.

First, there is no reason to believe that Chen will once again face delayed adjudication of

his I-601A application, for the simple reason that his application is no longer pending. His

argument to the contrary depends on speculation that the following chain of events will come to

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