Hojjatoleslami v. Blinken

CourtDistrict Court, District of Columbia
DecidedJuly 30, 2025
DocketCivil Action No. 2024-2871
StatusPublished

This text of Hojjatoleslami v. Blinken (Hojjatoleslami 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
Hojjatoleslami v. Blinken, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

NADIA HOJJATOLESLAMI,

Plaintiff, v. Civil Action No. 24-2871 (JDB) MARCO RUBIO, Secretary of State, et al.,

Defendants. 1

MEMORANDUM OPINION

In May 2024, Nadia Hojjatoleslami and her husband interviewed for nonimmigrant visas

at the U.S. consulate in Frankfurt, Germany. Her husband’s visa application was approved that

day. Hojjatoleslami’s was not. Instead, the consulate told Hojjatoleslami that it had refused her

application, and it requested additional biographical information—which she promptly provided.

Yet Hojjatoleslami’s application remains today in a kind of purgatory the Department of State calls

“administrative processing.”

Hojjatoleslami, believing her application has been in administrative processing for an

unreasonably long period, asks this Court to compel certain U.S. government officials to act,

namely by reevaluating her visa application in light of the supplemental information that she has

provided. Defendants 2 seek dismissal on several grounds. The Court agrees with two: some of

1 See Fed. R. Civ. P. 25(d). 2 Hojjatoleslami sues the following individuals in their official capacities: Marco Rubio, Secretary of State; Pamela Bondi, Attorney General; Alan Meltzer, Chargé d’Affaires ad interim of the U.S. Embassy to Germany; Brian Heath, Consul General at the U.S. Consulate in Frankfurt, Germany; and Jeanine Pirro, interim U.S. Attorney for the District of Columbia. See Compl. for Writ. of Mandamus Compelling Administrative Processing of EB-2 Visa [ECF No. 1] ¶¶ 6–10; Fed. R. Civ. P. 25(d).

1 the defendants are improper, and Hojjatoleslami fails to state a claim for an unreasonable delay at

this time. Accordingly, the Court grants the motion to dismiss without prejudice.

Legal Background

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

issuance of different types of visas to certain categories of foreign nationals. The State Department

issues E-2 nonimmigrant visas to certain foreign nationals who seek to operate commercial

enterprises in which they have already invested “a substantial amount of capital.” See 9 Foreign

Affs. Manual (“FAM”) § 402.9-2(a). Spouses of those investors may be eligible for the same

nonimmigrant visas as “derivatives.” Id. § 402.9-9(a). Recipients of E-2 investor visas are

allowed to stay in the United States for an initial term of up to two years, though they may request

multiple extensions of up to two years each. E-2 Treaty Investors, U.S. CITIZENSHIP &

IMMIGRATION SERVICES, (Apr. 8, 2025), https://www.uscis.gov/working-in-the-united-

states/temporary-workers/e-2-treaty-investors.

An applicant for a U.S. visa bears the burden of demonstrating she is eligible for the visa.

8 U.S.C. § 1361. To secure a nonimmigrant visa such as the E-2, an applicant generally must,

among other steps, interview with a consular officer. See 22 C.F.R. § 41.102; 9 FAM § 403.5-

2(C)(1). After the interview, the consular officer “must issue the visa” if the applicant has

“properly completed” her visa application or “refuse the visa” if the applicant has not established

her eligibility. 3 22 C.F.R. § 41.121(a); see also 8 U.S.C. §§ 1201(a)(1)(B).

Even if a consular officer concludes an applicant has not demonstrated eligibility for the

requested visa and refuses that visa, the application may not be doomed forever. The officer may,

if he perceives that the applicant might be able to demonstrate eligibility for the visa under changed

3 In some circumstances not applicable here, the consular officer might also discontinue granting a visa. See 22 C.F.R. §§ 41.121(a), 41.123.

2 circumstances or with additional information, choose to place the refused application in a status

known as “administrative processing.” See Administrative Processing Information, U.S. DEP’T OF

STATE – BUREAU OF CONSULAR AFFS., https://travel.state.gov/content/travel/en/us-visas/visa-

information-resources/administrative-processing-information.html (last visited July 29, 2025) 4; 9

FAM § 403.10-4. A visa application in administrative processing remains refused, but “[a]

consular officer will request additional information when she or he believes the information is

relevant to establishing that an applicant is eligible for the visa sought.” See Administrative

Processing Information.

Factual Background

Nadia Hojjatoleslami is an Iranian citizen and a permanent resident of Germany. Compl.

for Writ. of Mandamus Compelling Administrative Processing of EB-2 Visa [ECF No. 1]

(“Compl.”) ¶ 5. Before seeking the E-2 visa at issue here, Hojjatoleslami and her husband, Reza

Zahedi, applied for a different kind of nonimmigrant visa, the B1/B2 visitor visa. Id. ¶ 1. Zahedi,

a Dutch national, see Compl. Ex. C [ECF No. 1-3], received that visa, Compl. ¶ 1. But

Hojjatoleslami’s application was refused and placed in administrative processing, where it has

remained since March 2023. Id. ¶¶ 1, 20.

In February 2024, Zahedi applied for the E-2 investor visa on behalf of himself and

Hojjatoleslami so he could establish in the United States an asset-management and investment

company focused on real estate. Id. ¶ 22. The couple planned for Hojjatoleslami, who has a

bachelor’s degree in civil engineering, to help with the business. Id. But in May 2024,

Hojjatoleslami’s application was again refused and placed in administrative processing, while

Zahedi’s was again approved. Id. ¶¶ 23–24. The consulate asked Hojjatoleslami for additional

4 Courts may take judicial notice of information on government websites. Pharm. Rsch. & Mfrs. of Am. v. U.S. Dep’t of Health & Hum. Servs., 43 F. Supp. 3d 28, 33 (D.D.C. 2014).

3 biographical information, which she provided the next day. Id. ¶ 24. Hojjatoleslami is still waiting

to hear whether her supplemental information has changed the outcome of her application. Id.

¶ 27. She remains in Germany, while Zahedi resides in the United States. Id. ¶ 31.

After waiting more than four months for a response to her supplemental information, id.

¶ 27, Hojjatoleslami filed this lawsuit in October 2024 against State Department and Justice

Department officials, id. at 13. She contends the defendants have unreasonably delayed acting on

her E-2 application and asks this Court to compel action under the Administrative Procedure Act

(“APA”), 5 U.S.C., § 706(1), or the Mandamus Act, 28 U.S.C. § 1361. See Compl. ¶¶ 36–48. 5

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