Fateh v. Blinken

CourtDistrict Court, District of Columbia
DecidedFebruary 29, 2024
DocketCivil Action No. 2023-1277
StatusPublished

This text of Fateh v. Blinken (Fateh v. Blinken) 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
Fateh v. Blinken, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

KOSAR FATEH, et al.,

Plaintiffs,

v. Case No. 1:23-cv-1277-RCL

ANTONY J. BLINKEN, Secretary of State, et al.,

Defendants.

MEMORANDUM OPINION

Plaintiffs are five Iranian citizens who applied for nonimmigrant visas at the United States

Embassy in Yerevan, Armenia. Their Iranian citizenship complicates their ability to receive a visa

because Iran is a state sponsor of terrorism. Plaintiffs contend that the lengthy periods they have

spent awaiting final decisions on their visa applications amount to unreasonable delay in violation

of the Administrative Procedure Act. They therefore seek declaratory, injunctive, and mandamus

relief ordering defendants to finish processing their visa applications.

Now before the Court is defendants’ motion to dismiss plaintiffs’ Amended Complaint

pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). Upon consideration of the

briefing, the relevant authorities, and the record as a whole, the Court will GRANT defendants’

Second Motion to Dismiss and DISMISS plaintiffs’ Amended Complaint in its entirety. 1 The

claims of two of the five plaintiffs are moot because the United States Department of State has

issued their visas. As for the remaining plaintiffs, the Court will dismiss their claims because

plaintiffs did not address—and thus conceded—defendants’ argument that they lack standing.

1 Before plaintiffs amended their complaint, defendants filed a motion to dismiss the original complaint. See 1st MTD, ECF No. 5. This motion will be DENIED AS MOOT.

1 I. BACKGROUND

The Court will first discuss the statutory and regulatory background to this case, before

turning to the facts and procedural history of this specific dispute.

A. Legal Background

A foreign student who wishes to study at a United States academic institution may apply

for an “F-1” non-immigrant visa. See 8 U.S.C. § 1101(a)(15)(F)(i). If the student is admitted, his

or her spouse or minor children may be eligible an “F-2” visa. See id. § 1101(a)(15)(F)(ii). A

person applying for an F-1 or F-2 nonimmigrant visa typically must submit to an in-person

interview with a consular officer. See id. § 1202(h). The applicant bears the burden of proof to

establish eligibility to the satisfaction of the consular officer. Id. § 1184(b); 42 C.F.R. § 41.11(a).

When an applicant has properly executed a visa application, the officer must either issue or refuse

the visa. See 22 C.F.R. § 41.121(a). The consular officer may not issue a visa if:

(1) it appears to the consular officer, from statements in the application, or in the papers submitted therewith, that such alien is ineligible to receive a visa or such other documentation under [8 U.S.C. § 1182] of this title, or any other provision of law, (2) the application fails to comply with the provisions of this chapter, or the regulations issued thereunder, or (3) the consular officer knows or has reason to believe that such alien is ineligible to receive a visa or such other documentation under [8 U.S.C. 1182], or any other provision of law:

8 U.S.C. §1201(g).

“In cases where the officer requires additional information to determine the applicant’s

eligibility, however, he may refuse the visa pending further ‘administrative processing.’” Khazaei

v. Blinken, No. 23-cv-1419 (JEB), 2023 WL 6065095, at *1 (D.D.C. Sept. 18, 2023) (citing U.S.

Administrative Processing Information, U.S. Dep’t of State, https://bit.ly/2GO3jEg

[https://perma.cc/NK8K-9U8H] (last visited Sept. 5, 2023)). The State Department provides the

status of each application on its public website. See id. (citing Visa Status Check, U.S. Dep’t of

State, http://tinyurl.com/52px458z [https://perma.cc/SBV4-AT2N] (last visited Sept. 5, 2023)).

2 One ground for refusing a visa is set forth in 8 U.S.C. § 1735(a), which provides that no

nonimmigrant visa may be issued to a noncitizen from a country that is designated a state sponsor

of terrorism “unless the Secretary of State determines, in consultation with the Attorney General

and the heads of other appropriate United States agencies, that such alien does not pose a threat to

the safety or national security of the United States.” 8 U.S.C. § 1735(a). Since 1984, one such

state sponsor of terrorism has been Iran. See State Sponsors of Terrorism, U.S. Dep’t of State,

http://tinyurl.com/mtd2aasf [https://perma.cc/CBT2-2C87] (last visited Feb. 26, 2024).

B. Factual Background

Plaintiffs are five Iranian citizens who reside in Iran. Am. Compl. ¶ 20, ECF No. 6; Am.

Compl. Ex. A 10, ECF No. 6-1; Am. Compl. Ex. B 26; Am. Compl. Ex. C 43; Am. Compl. Ex. D

55; Am. Compl. Ex. E 68. Each filed a nonimmigrant visa application with the State Department,

participated in an interview at the U.S. Embassy in Yerevan, Armenia, and submitted subsequent

questionnaires concerning employment, travel, and address history. Am. Compl. ¶¶ 31–33.

Plaintiffs allege that their applications were refused and are still pending administrative processing.

Id. ¶¶ 34, 36–37.

1. Kosar Fateh

Plaintiff Kosar Fateh applied for an F-2 visa on December 4, 2021 and submitted to a visa

interview on January 27, 2022. Am. Compl., Ex. A 3. A U.S. consular officer adjudicated and

refused her visa application. See Visa Status Check, U.S. Dep’t of State Consular Elec.

Application Ctr., http://tinyurl.com/52px458z [https://perma.cc/GZ3S-H5XJ] (last visited Feb. 26,

3 2023).2 Plaintiffs allege that the U.S. Embassy in Yerevan reported that Fateh’s visa application

remains in administrative processing. See Am. Compl., Ex. A 3.

2. Naser Einollahi

Plaintiff Naser Einollahi applied for an F-1 visa on January 27, 2022 and submitted to a

visa interview on February 4, 2022. Am. Compl., Ex. B 19. A U.S. consular officer adjudicated

and refused his visa application. See Visa Status Check, U.S. Dep’t of State Consular Elec.

Application Ctr., http://tinyurl.com/52px458z [https://perma.cc/GZ3S-H5XJ] (last visited Feb. 26,

2023).

3. Niloofar Javidi Moshtaghin

Plaintiff Niloofar Javidi Moshtaghin applied for an F-1 visa on March 16, 2022 and

submitted to a visa interview on March 18, 2022. Am. Compl., Ex. C 37. On July 26, 2023, the

State Department completed processing her application and issued her a nonimmigrant visa. See

Visa Status Check, U.S. Dep’t of State Consular Elec. Application Ctr.,

http://tinyurl.com/52px458z [https://perma.cc/GZ3S-H5XJ] (last visited Feb. 26, 2023).

4. Sepideh Zafari Naeini

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