Diakite v. U.S. Citizenship and Immigration Services (USCIS)

CourtDistrict Court, S.D. New York
DecidedMarch 11, 2024
Docket1:23-cv-00725
StatusUnknown

This text of Diakite v. U.S. Citizenship and Immigration Services (USCIS) (Diakite v. U.S. Citizenship and Immigration Services (USCIS)) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Diakite v. U.S. Citizenship and Immigration Services (USCIS), (S.D.N.Y. 2024).

Opinion

ELECTRONICALLY FILED DOC#; □□ □□□ UNITED STATES DISTRICT COURT DATE FILED: _3/11/20?4____ SOUTHERN DISTRICT OF NEW YORK DIAKITE, Petitioner, -against- 23-cv-00725 (ALC) OPINION & ORDER UNITED STATES CITIZENSHIP AND IMMIGRATION SERVICES, Respondent.

ANDREW L. CARTER, United States District Judge: In January 2023, petitioner filed this writ of mandamus petition, seeking to compel the government to grant her application, filed in October 2011, to Adjust to Permanent Resident Status. Respondent argues that this court lacks subject matter jurisdiction because Diakite’s petition is moot. Since the filing of the petition, respondents granted her application. However, following the grant of her application, petitioner complained to respondents about purported errors on her green card—the documentation of her lawful permanent status. Respondents examined the matter and now claim that petitioner’s green card should not have even been issued, filing a Notice of intent to Rescind Permanent Residence (“NOIR”). The NOIR states that petitioner can file a written response or request a hearing before an immigration judge. Petitioner has not exhausted administrative remedies connected to the NOIR. Because Respondents have granted Petitioner the relief she initially requested in her mandamus petition, the request is moot. Therefore, Respondent’s motion to dismiss is GRANTED.

BACKGROUND Ms. Diakite, a citizen of Guinea, initially applied for asylum in the United States on January 22, 2002. Declaration of Nancy Lazaro (“Lazaro Decl.”), Exhibit (“Ex.”) A, p.7. In the asylum application, Petitioner failed to list her United States children on her application and was

subsequently charged with removability in March 2002. Id. Petitioner subsequently appealed the determination over several years and ultimately obtained an order from the Board of Immigration Appeals reopening and remanding her case back to the Immigration Court for further proceedings in 2010. Id. Petitioner then filed an application for Cancellation Of Removal (“EOIR-42-B”) in 2011 and was told by Respondent that the application was “accepted as an [Application to Register Permanent Residence or Adjust Status] I-485 receipt at the Texas Service Center.” Id. Respondent, while acknowledging that Petitioner filed an EOIR-42B in 2011 and was issued a receipt which stated that the application “ha[d] been received and accepted as an I-485 receipt,” alleges that a I-485 application was never submitted in 2011. Id. In 2015, Petitioner filed an Application for Temporary Protected Status (“TPS”) alongside an

Application for Travel which was rejected that same year. The following year, Petitioner then filed an Application for Waiver of Grounds of Inadmissibility in connection with her 2015 TPS application. Id. Respondent claims that when filling out this application, Petitioner stated that she was not filing the application after having already previously filed a Form I-485 Application. Id. Respondents then approved the TPS application and subsequent Application for Waiver of Grounds of Inadmissibility on February 3, 2016. Id. In January 2020, Diakite’s daughter filed a Petition for Alien Relative on Petitioner’s behalf, and the petition was approved in February 2021. Petitioner then commenced this mandamus action in January 2023, asserting an unreasonable delay in the final determination of the 2011 Form I-485 Application. See ECF No. 1 (“Petition”). Following the filing of this action, Petitioner was then interviewed in connection with the Petition for Alien Relative that her daughter had filed in 2020. Lazaro Decl., Ex. A, p.7.

Following that interview and the submission of certain documentation, Respondent adjusted Petitioner’s status to that of a lawful permanent resident on May 16, 2023. Id. Upon receiving her green card in the mail, Petitioner observed that the date of issuance listed on the documentation was purportedly incorrect and “not consistent with USCIS policy.” ECF No. 15 at 2. Petitioner then requested that Respondent correct the error. Id. In response to that request, Respondent sent Petitioner a Notice of Intent to Rescind Permanent Resident Status (“NOIR”). See Lazaro Decl., Ex. A. In the NOIR, Respondent stated that Petitioner’s status alteration was allegedly erroneous because: (1) Petitioner failed to file a Form I-485 Application in 2011, (2) Respondent does not have jurisdiction over the status adjustment because the removal proceedings before the Immigration Judge have not yet been terminated, (3) Petitioner

neither had prior to nor contemporaneously applied for a visa when filing the 2011 Form I-485, (4) Petitioner was not inspected and admitted or paroled into the United States, and (5) Petitioner violated INA § 212(a)(6)(C)(i) when failing to divulge her American-born children in her asylum application. Id. at 4-6. The NOIR also states that Petitioner can file a written response or request a hearing before an immigration judge. Id. at 7-8. On July 11, 2023, filed a motion for “Judicial Notice And/Or Motion to Cancel NOIR Ex Parte” in which Petitioner moved for “voluntary dismissal of the instant action following the correction of the [green card’s] approval date” as well as “an order of cancellation of” the NOIR. ECF No. 15 at 2. On August 9, 2023, Respondents moved to dismiss the Petition as moot, arguing that Petitioner’s requested mandamus relief—that USCIS process and/or grant Petitioner’s Form I-485 Application—had already been granted. ECF No. 21 at 6. Respondents also argue that Petitioner’s Motion to Cancel the NOIR ought not be reviewed as Petitioner did not include a request for such relief in the mandamus petition, has not yet exhausted the available

administrative remedies, and because this claim is not yet ripe for review. ECF No. 21 at 8. LEGAL STANDARD Dismissal of a case pursuant to Rule 12(b)(1) for lack of subject-matter jurisdiction is appropriate “when the district court lacks the statutory or constitutional power to adjudicate it.” Makarova v. United States, 201 F.3d 110, 113 (2d Cir. 2000). Mootness is one such appropriate ground for dismissal under Rule 12(b)(1). See Doyle v. Midland Credit Mgmt., Inc., 722 F.3d 78, 80 (2d Cir. 2013). A case is moot where it “is impossible for a court to grant any effectual relief whatever to the prevailing party.” Chevron Corp. v. Donziger, 833 F.3d 74, 124 (2d Cir. 2016) (quoting Chafin v Chafin, 568 U.S. 165, 172 (2013)). So long as “the parties have a concrete interest, however small, . . . the case is not moot.” Id. (quoting Knox v. SEIU, Local 1000, 567

U.S. 298, 307-308 (2012)). The doctrine of exhaustion of remedies establishes that a mandamus petitioner must first seek “all possible relief within the agency itself.” Beharry v. Ashcroft, 329 F.3d 51, 56 (2d Cir. 2003) (internal quotation marks omitted). The exhaustion requirement applies to those seeking review of a denial of a Form I-485 Application. Belem v. Jaddou, No. 21-CV-4093 (VEC), 2022 U.S. Dist. LEXIS 94184, at *7 (S.D.N.Y. May 25, 2022).1 Failure to adequately establish exhaustion of administrative remedies leaves a federal court without subject matter jurisdiction to adjudicate a petition. Howell v. I.N.S., 72 F.3d 288, 291 (2d Cir. 1995). Exceptions to the

1 Petitioner will be provided with copies of all unpublished opinions cited in this decision. See Lebron v. Sanders, 557 F.3d 76, 79 (2d Cir.

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Bluebook (online)
Diakite v. U.S. Citizenship and Immigration Services (USCIS), Counsel Stack Legal Research, https://law.counselstack.com/opinion/diakite-v-us-citizenship-and-immigration-services-uscis-nysd-2024.