Iqbal v. Blinken

CourtDistrict Court, E.D. California
DecidedJuly 2, 2025
Docket2:23-cv-01299
StatusUnknown

This text of Iqbal v. Blinken (Iqbal v. Blinken) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Iqbal v. Blinken, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 Lailaa Iqbal, et al., No. 2:23-cv-01299-KJM-CSK. 12 Plaintiffs, ORDER 13 v. 14 Marco Rubio, et al., 1S Defendants. 16 17 In this action, plaintiffs Muhammad Hassan and Irsa Jamil allege the defendants—the 18 | Secretary of State’ and other federal officials, all named in their official capacities—have 19 | unreasonably delayed a decision on Jamil’s pending application for a visa to join Hassan, her 20 | spouse anda U.S. citizen, in the United States. See Prev. Order at 1, 5, 7, ECF No. 55. 21 | According to the complaint, Jamil is a Pakistani national. See Compl. § 18, ECF No. 1. The 22 | parties each move for reconsideration of certain aspects of this court’s prior order docketed at 23 | ECF No. 55. As explained below, those motions are denied. 24 | I. BACKGROUND 25 The court’s previous order denied defendants’ motion for summary judgment based on an 26 | analysis of the six-factor balancing test the Ninth Circuit has instructed district courts to use when

' Defendant Rubio was substituted automatically in place of his predecessor, Antony Blinken, under Federal Rule of Civil Procedure 25(d).

1 deciding whether an agency has unreasonably delayed a decision under the Administrative 2 Procedure Act (APA). See id. at 14–21 (citing In re Nat. Res. Def. Council, Inc., 956 F.3d 1134, 3 1138–39 (9th Cir. 2020), in turn citing Telecommc’ns Rsch. & Action Ctr. v. F.C.C. (TRAC), 750 4 F.2d 70, 79–80 (D.C. Cir. 1984)). Defendants were not entitled to judgment as a matter of law 5 based on the record as it then stood. In short, the factors favored neither side conclusively on the 6 record before the court: 7 1. The first and most important factor is whether the delay passed the “rule of 8 reason.” TRAC, 750 F.2d at 80 (citation omitted). The record in this case showed 9 the delays in processing Jamil’s application were due at least in part to a variety of 10 circumstances beyond defendants’ control, from the intervening COVID-19 11 pandemic to the Taliban’s assault on Kabul, Afghanistan. See Prev. Order at 14– 12 17. To compound these difficulties, the government has struggled to find people 13 who are qualified to make decisions about visa applications, which has prevented 14 defendants from filling multiple vacancies in the ranks of their reviewing staff. 15 See id. at 15. 16 2. Under the second factor, courts consider whether Congress has “provided a 17 timetable or other indication of the speed with which it expects the agency to 18 proceed.” TRAC, 750 F.2d at 80. Although Congress appears to have expected 19 the State Department to make decisions on visa applications within thirty days— 20 much faster than the years it has taken defendants to process the application in this 21 case—Congress has not set a statutory timetable or cutoff. Prev. Order at 17–19. 22 3. It also is relevant, under factor number three, whether the interests at stake are 23 merely “economic” or instead relate to “health and welfare.” TRAC, 750 F.2d at 24 80. Defendants did not dispute plaintiffs’ allegations of “significant emotional, 25 psychological and financial hardships as a result of the prolonged and indefinite 26 family separation caused by defendants’ delay.” Prev. Order at 19–20. 27 4. Fourth, courts “consider the effect of expediting delayed action on agency 28 activities of a higher or competing priority.” TRAC, 750 F.2d at 80. The court 1 agreed with defendants that it could not set the government’s priorities or permit 2 the plaintiffs to “cut in line.” Prev. Order at 20 (citation omitted). But the record 3 did not show whether granting Jamil’s application would put her in front of “other 4 similarly situated applicants who have been waiting the same amount or longer 5 time.” Id. at 21. The parties agreed, in fact, that there was no “first-in, first-out” 6 queue of applications. Id. Nor had defendants offered “evidence of the ‘line’ 7 plaintiffs were supposedly cutting,” nor explained what “competing or higher 8 priorities” were at stake. Id. The court did not question defendant’s “role in 9 making sure visa applicants do not pose national security risks.” Id. Nor did the 10 court doubt defendants “are working with limited consular resources.” Id. But the 11 court found that security concerns and limited resources “do not excuse defendants 12 from their duty to adjudicate plaintiffs’ immigrant visa applications within a 13 reasonable time.” Id. 14 5. As with the third factor, the fifth factor requires courts to “take into account 15 . . . the nature and extent of the interests prejudiced by delay.” TRAC, 750 F.2d at 16 80. In Jamil’s case, this factor weighed in her favor, given her shared interests 17 with Hassan. See id. at 19–21. 18 6. Finally, under factor six, the court weighs any “impropriety” or bad faith in the 19 government’s actions, but a plaintiff can prevail without showing any impropriety. 20 See TRAC, 750 F.2d at 80 (citation omitted). There was no evidence of 21 impropriety or bad faith in this case. Prev. Order at 21. 22 In addition to undertaking this balancing exercise, the court considered whether to grant 23 plaintiffs’ request to compel defendants to produce “the full administrative record.” Id. at 12. 24 The court denied that request. Plaintiffs had supported their arguments with citations to cases 25 about arbitrary or unreasonable “final agency actions.” Id. In this case, by contrast, plaintiffs 26 allege there has been no “final agency action,” so the court found the cited authorities 27 unpersuasive. Id. 1 As noted, both plaintiffs and defendants ask this court to reconsider its previous order: 2 plaintiffs move for reconsideration of their request for the full administrative record, and 3 defendants argue the court clearly erred in balancing the six TRAC factors. Briefing on both 4 reconsideration motions is now complete. See generally Defs.’ Mot., ECF No. 61; Pls.’ Opp’n, 5 ECF No. 63; Defs.’ Reply, ECF No. 64; Pls.’ Mot., ECF No. 59; Defs.’ Opp’n 62; Pls.’ Reply, 6 ECF No. 65. The court took the matter under submission without holding a hearing. Min. Order, 7 ECF No. 60. 8 The relevant legal standard is the same for both motions. Federal district courts have 9 inherent authority to revise their pretrial orders if doing so is “consonant with equity.” Waetzig v. 10 Halliburton Energy Servs., Inc., 145 S. Ct. 690, 697 (2025) (quoting John Simmons Vo. v. Grier 11 Brothers Co., 258 U.S. 92, 91 (1922)). But barring any “highly unusual circumstances,” district 12 courts do not reconsider their pretrial orders unless they are “presented with newly discovered 13 evidence, committed clear error, or if there is an intervening change in the controlling law.” 389 14 Orange St. Partners v. Arnold, 179 F.3d 656, 665 (9th Cir. 1999). This means litigants ordinarily 15 cannot “raise arguments or present evidence for the first time” in a motion for reconsideration 16 “when they could reasonably have been raised earlier in the litigation.” Kona Enters., Inc. v. Est. 17 of Bishop, 229 F.3d 877, 890 (9th Cir. 2000). Nor do federal district courts entertain requests to 18 revisit an argument a party has already advanced unsuccessfully, absent clear error. See, e.g., 19 Cachil Dehe Band of Wintun Indians of Colusa Indian Cmty. v. California, 649 F. Supp. 2d 1063, 20 1070 (E.D. Cal. 2009). 21 II. PLAINTIFFS’ MOTION 22 As noted, plaintiffs ask the court to reconsider its decision not to order the government to 23 file a complete administrative record.

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Bluebook (online)
Iqbal v. Blinken, Counsel Stack Legal Research, https://law.counselstack.com/opinion/iqbal-v-blinken-caed-2025.