KOTHAPALLY v. UNITED STATES DEPARTMENT OF HOMELAND SECURITY

CourtDistrict Court, N.D. Alabama
DecidedSeptember 30, 2025
Docket2:24-cv-00741
StatusUnknown

This text of KOTHAPALLY v. UNITED STATES DEPARTMENT OF HOMELAND SECURITY (KOTHAPALLY v. UNITED STATES DEPARTMENT OF HOMELAND SECURITY) is published on Counsel Stack Legal Research, covering District Court, N.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
KOTHAPALLY v. UNITED STATES DEPARTMENT OF HOMELAND SECURITY, (N.D. Ala. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

RAJENDRA KOTHAPALLY, } } Plaintiff, } } v. } Case No. 2:24-cv-00741-MHH } UNITED STATES } DEPARTMENT OF } HOMELAND SECURITY, } } Defendant. }

MEMORANDUM OPINION AND ORDER Plaintiff Rajendra Kothapally has sued the United States Department of Homeland Security for revoking his H-1B nonimmigrant “cap number” following DHS’s revocation of his employer’s H-1B nonimmigrant petition. (Doc. 24). DHS has filed a motion to dismiss Mr. Kothapally’s complaint under Rule 12(b)(1) and Rule 12(b)(6) of the Federal Rules of Civil Procedure. (Doc. 26). This opinion resolves DHS’s motion. The opinion begins with Mr. Kothapally’s allegations, as informed by documentation provided by DHS and referenced in Mr. Kothapally’s complaint. Because DHS contests Mr. Kothapally’s standing, the Court turns first to its ability to hear Mr. Kothapally’s claim. Next, the Court outlines the standard governing review of a motion to dismiss under Rule 12(b)(6). Consistent with that standard, the Court analyzes the parties’ contentions concerning the legal sufficiency of Mr. Kothapally’s complaint.

I. Mr. Kothapally is an Indian national. (Doc. 24, p. 11, ¶ 77). SS Lead Technology, Inc. recruited Mr. Kothapally for an information technology position in the United States. (Doc. 24, p. 11, ¶ 78).1 SSLT extended Mr. Kothapally an

employment offer and registered him for the H-1B nonimmigrant status lottery. (Doc. 24, p. 12, ¶ 80). DHS selected Mr. Kothapally for H-1B status. (Doc. 24, p. 12, ¶ 80).

After Mr. Kothapally’s selection, SSLT submitted a Labor Condition Application on Mr. Kothapally’s behalf to the Department of Labor. See § 1182(n)(1); (Doc. 24, p. 12, ¶ 81; Doc. 26-3, pp. 18–23).2 The DOL approved

SSLT’s application, and SSLT filed Mr. Kothapally’s H-1B petition. (Doc. 24, p. 12,

1 The Immigration and Nationality Act allows foreign nationals to enter the United States via the H-1B program to “perform services” in a “specialty occupation” upon the “petition of [an] importing employer.” 8 U.S.C. §§ 1101(a)(H)(i)(b), 1184(c)(1). The INA “caps” the number of H-1B nonimmigrant workers at 65,000 annually. § 1184(g)(1)(A)(vii). The statute permits an additional 20,000 H-1B workers who have “earned a master’s or higher degree from a United States institution of higher education.” § 1184(g)(5)(C). When demand for cap positions exceeds supply, DHS uses a lottery selection process. 8 C.F.R. § 214.2(h)(8)(iii)(A)(5)((ii). After DHS selects a worker and approves the employer’s petition, DHS assigns the worker a “cap number.” (Doc. 24, p. 8, ¶ 43).

2 Among other requirements, an employer must identify on the LCA “the occupational classification” of a requested worker and attest on the LCA that the employer will pay the worker a mandated wage. § 1182(n)(1)(A), (D). The LCA also must list the worker’s “place of employment,” defined as “the worksite or physical location where the work actually is performed by the H-1B” nonimmigrant. 20 C.F.R. §§ 655.715, 655.730(c)(4)(v). ¶ 84; Doc. 26-3). DHS approved the petition and assigned Mr. Kothapally a “cap number.” (See Doc. 24, pp. 8, 12, ¶¶ 43, 84; Doc. 26-4, p. 1).

Mr. Kothapally’s H-1B petition listed his job title as “Azure Consultant” at an address in Melville, New York. (Doc. 26-3, pp. 4–5). Just before Mr. Kothapally entered the United States, SSLT reassigned him to work as a consultant for Truist

Bank in Alabama. (Doc. 24, p. 12, ¶ 87). Mr. Kothapally entered the United States on December 14, 2022. (See Doc. 24, p. 12, ¶ 86). On January 11, 2023, DHS, through U.S. Citizenship and Immigration Services, issued to SSLT a letter entitled “Notice of Intent to Revoke.” (Doc. 26-

2).3 The letter concerned Mr. Kothapally’s H-1B petition. (Doc. 26-2, p. 1). The letter states: SS Lead Technology Inc. made false attestations on the documents, provided false information, and submitted fraudulent evidence in support of the petition to appear to have a bona fide job offer and specialty occupation work at the claimed end-client location. This conclusion was met due to the fact that USCIS was not able to locate the end-client listed on your petition and the LCA. A site visit was conducted and it was found that your end-client was not located at the address provided on this petition, 200 Broad Hollow Rd. in Melville, NY. Also, it was found that many of the signatures on the aforementioned evidence were fictitious names and signatures on documents supporting various petitions. USCIS contacted the person listed as the HR Manager at your end-client (Career Connection Services, Inc.) Abby Benedict Rife, and she stated that she has never worked for that end-client nor did she sign any of the documents included with her name on them in this application. She further stated

3 DHS regulations require notice to a petitioner before revoking an H-1B petition. 8 C.F.R. § 214.2(h)(11)(iii). she was never aware of the company entitled Career Connection Services, Inc.

(Doc. 26-2, p. 4). USCIS sought to revoke Mr. Kothapally’s H-1B petition because of SSLT’s misrepresentations. (Doc. 26-2, pp. 4–7). USCIS provided SSLT 30 days to submit information in support of the petition. (Doc. 26-2, p. 7). Mr. Kothapally did not receive notice of USCIS’s intent to revoke his H-1B petition. (Doc. 24, p. 13, ¶ 92). After SSLT’s window to submit additional information closed, SSLT

submitted an “application or petition” concerning Mr. Kothapally. (Doc. 26-5).4 On July 11, 2023, USCIS revoked Mr. Kothapally’s H-1B petition. (Doc. 26-4, pp. 1, 7). By letter to SSLT, USCIS reiterated its concerns with Mr. Kothapally’s H-1B

petition and stated that it had revoked the petition because of SSLT’s misrepresentations after SSLT did not submit additional evidence in support of Mr. Kothapally’s petition. (Doc. 26-4, p. 7). SSLT informed Mr. Kothapally about the revocation and told him that he “could no longer work for them.” (Doc. 24, p. 13, ¶

93). Enin Systems, Inc. accepted Mr. Kothapally for another position and agreed to sponsor his H-1B petition. (Doc. 24, p. 13, ¶ 94). Enin filed a transfer petition

4 DHS represents that this information included “an H-1B amendment petition” that reflected “a new job location.” (Doc. 26-1, p. 16 n.3). DHS has not provided a copy of the information SSLT submitted. Instead, DHS has provided a document which indicates that USCIS received the information SSLT submitted, but the document does not mention the substance of these materials. (Doc. 26-5). on August 14, 2023. (Doc. 24, p. 13, ¶ 94). DHS approved Enin’s petition, and Enin “assumed SSLT’s contract with Truist Bank,” allowing Mr. Kothapally to continue

his work. (Doc. 24, p. 13, ¶ 95). On September 24, 2024, DHS issued a notice of intent to revoke letter to Enin. (Doc. 24, p. 14, ¶ 96). The letter indicated that Mr. Kothapally “did not have a cap number and could not move to a new employer.” (Doc. 24, p. 14, ¶ 96).5

Mr. Kothapally has sued DHS for violating the Administrative Procedure Act. (Doc. 24, pp. 14–16, ¶¶ 98–111). Mr. Kothapally argues that DHS revoked his cap number improperly because of SSLT’s actions, not his actions, and because DHS did

not provide notice to him and an opportunity to respond before revocation. (Doc. 24, p. 15, ¶¶ 103, 105). Mr.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Maxcess, Inc. v. Lucent Technologies, Inc.
433 F.3d 1337 (Eleventh Circuit, 2005)
Watts v. Florida International University
495 F.3d 1289 (Eleventh Circuit, 2007)
Bell v. Hood
327 U.S. 678 (Supreme Court, 1946)
Plyler v. Doe
457 U.S. 202 (Supreme Court, 1982)
H. J. Inc. v. Northwestern Bell Telephone Co.
492 U.S. 229 (Supreme Court, 1989)
Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Christensen v. Harris County
529 U.S. 576 (Supreme Court, 2000)
Lamie v. United States Trustee
540 U.S. 526 (Supreme Court, 2004)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Stephen Grossman v. Nationsbank, N.A.
225 F.3d 1228 (Eleventh Circuit, 2000)
Steel Co. v. Citizens for a Better Environment
523 U.S. 83 (Supreme Court, 1998)
Lexmark Int'l, Inc. v. Static Control Components, Inc.
134 S. Ct. 1377 (Supreme Court, 2014)
Spokeo, Inc. v. Robins
578 U.S. 330 (Supreme Court, 2016)
City of Miami Gardens v. Wells Fargo & Co.
931 F.3d 1274 (Eleventh Circuit, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
KOTHAPALLY v. UNITED STATES DEPARTMENT OF HOMELAND SECURITY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kothapally-v-united-states-department-of-homeland-security-alnd-2025.