Ghobadi Pasha v. U.S. Department of State

CourtDistrict Court, District of Columbia
DecidedFebruary 21, 2024
DocketCivil Action No. 2023-1546
StatusPublished

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Ghobadi Pasha v. U.S. Department of State, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

MEHRNOUSH GHOBADI PASHI,

Plaintiff, Civil Action No. 23-1546 v. Judge Beryl A. Howell U.S. DEPARTMENT OF STATE, et al.,

Defendants.

MEMORANDUM OPINION

Plaintiff Mehrnoush Ghobadi Pasha, a citizen of Iran who “invested $500,000 into an

approved ‘Regional Center,’” Pet. for Writ of Mandamus (“Pet”) at 1, ECF No. 1, brought this

suit against defendants, the U.S. Department of State, Secretary of State Antony J. Blinken, the

U.S. Consul General in Naples, Italy, Tracy Roberts-Pounds, and the Attorney General of the

United States, Merrick B. Garland, seeking a writ of mandamus to compel the U.S. Department

of State to adjudicate her visa application, id. at 2, on claims that defendants have unreasonably

delayed her visa application, in violation of the Administrative Procedure Act (“APA”) and the

Mandamus Act, id. at 4–6. Defendants now move to dismiss the petition as moot because

plaintiff’s visa had already been issued or, in the alternative, to dismiss under Federal Rule of

Civil Procedure 12(b)(6) because the petition “names defendants who have no role in connection

with the adjudication of [plaintiff’s] visa application.” Defs.’ Mot. to Dismiss (“Defs.’ Mot.”) at

1, ECF No. 5. For the reasons set forth below, this petition must be dismissed as moot.

I. BACKGROUND

Following a brief review of the statutory and regulatory background, the factual history

underlying the claims and procedural history of this case are summarized below.

1 A. Statutory and Regulatory Background

1. EB-5 Classification Generally

The Immigration and Nationality Act (“INA”), 8 U.S.C. § 1101 et seq., authorizes the

issuance of visas to different categories of immigrants, including, under the so-called “EB-5”

program, to immigrants who contribute to “employment creation” by investing in new

commercial enterprises that create full-time jobs for American workers, see Immigration Act of

1990, Pub. L. No. 101-649, § 121(a), 104 Stat. 4978, 4989 (Nov. 29, 1990) (codified at 8 U.S.C.

§ 1153(b)(5)); see 8 C.F.R. § 204.6 (2020) (defining the requirements and process for EB-5

“alien entrepreneur” classification). To qualify for a visa under the EB-5 program, an immigrant

must “create[e] full-time employment for not fewer than 10 United States citizens . . . or aliens

lawfully admitted for permanent residence or other immigrants lawfully authorized to be

employed in the United States (other than the immigrant and the immigrant’s spouse, sons, or

daughters).” 8 U.S.C. § 1153(b)(5)(A)(ii). Under the regulations in effect at the time of

adjudication of plaintiff’s I-526 application, the immigrant must have made or be in the process

of making an investment of at least $1,000,000 generally or at least $500,000 into a “targeted

employment area,” 8 U.S.C. § 1153(b)(5)(C). 1

A “targeted employment area” is defined as “a rural area or an area designated by the

Secretary of Homeland Security . . . as a high unemployment area,” id. § 1153(b)(5)(D)(viii).

USCIS permits certain so-called “economic units” to apply for categorization as a “targeted

1 In 2019, then-Acting Homeland Security Secretary McAleenan signed a Final Rule that increased the threshold amounts required for EB-5 investments from $1,000,000 to $1,800,000 generally and from $500,000 to $900,000 for targeted employment areas. See Final Rule, EB-5 Immigrant Investor Program Modernization, 84 Fed. Reg. 35,750, 35,808 (Jul. 24, 2019). This Final Rule was vacated in June 2021, see Behring Reg’l Ctr. LLC v. Wolf, 544 F. Supp. 3d 937 (N.D. Cal. 2021), and USCIS has since “appl[ied] the EB-5 regulations that were in effect before the rule was finalized,” EB-5 Immigrant Investor Program, U.S. Citizenship and Immigration Servs., https://www.uscis.gov/working-in-the-united-states/permanent-workers/eb-5-immigrant-investor-program (last visited Feb. 21, 2024). In any event, Plaintiff’s I-526 application was adjudicated under the threshold amounts in place prior to this change.

2 employment area” and designation as a “regional center” through the Immigrant Investor Pilot

Program. See Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies

Appropriations Act of 1993 (“Appropriations Act”), Pub. L. No. 102-395, § 610(a), 106 Stat.

1828, 1874 (Oct. 6, 1992); 8 C.F.R. § 204.6(e), (m). To qualify for designation as a “regional

center,” an economic unit must “promot[e] . . . economic growth,” id. § 204.6(e); see

Appropriations Act § 610(a), and the proposal for such designation must explain, inter alia, how

the economic unit focuses on a geographic region of the United States and will promote

economic growth through “increased export sales, improved regional productivity, job creation,

and increased domestic capital investment,” 8 C.F.R. § 204.6(m)(3)(i). Upon designation as a

regional center, a foreign investor may then invest in the center to satisfy, with the requisite

threshold amount of funds, the EB-5 employment-creation requirement by creating jobs

indirectly. Id. §§ 204.6(j)(4)(iii), 204.6(m)(7)(ii).

2. EB-5 Visa Processing Procedure

Foreign investors seeking EB-5 visas must first file a petition with USCIS, using Form I-

526, to petition for classification as an EB-5 investor. See 8 C.F.R. §§ 204.6(a), (c). The burden

of proof rests on petitioners to establish, by a preponderance of the evidence, that they are

“eligible to receive [the] visa” for which they are petitioning. 8 U.S.C. § 1361; see Matter of

Chawathe, 25 I. & N. Dec. 369, 375–76 (2010). USCIS adjudicates I-526 petitions based on the

totality of the evidence presented. See id. at 375–76. “Once the petition is processed and [if] a

visa becomes available—which may take years—the immigrant advances to ‘conditional’ lawful

permanent resident status.” Mirror Lake Vill. LLC v. Wolf, 971 F.3d 373, 375 (D.C. Cir. 2020)

(citing 8 U.S.C. § 1186b(a)). Successful adjudication and approval of an I-526 petition makes a

petitioner eligible for a visa, but does not automatically provide a visa. At the same time,

3 approved eligibility status permits foreign investors (and their dependent family members) to

apply for two-year conditional permanent resident status either from within the United States or

overseas from the State Department at the United States consular post in the petitioner’s home

country. See 8 U.S.C. §§ 1186b(a)(1), 1201(a), 1255(i); 8 C.F.R.

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