Kullab v. United States Department of Homeland Security

CourtDistrict Court, N.D. California
DecidedMarch 25, 2025
Docket3:24-cv-04140
StatusUnknown

This text of Kullab v. United States Department of Homeland Security (Kullab v. United States Department of Homeland Security) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kullab v. United States Department of Homeland Security, (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 YASMIN KULLAB, Case No. 24-cv-04140-WHO

8 Plaintiff, ORDER GRANTING MOTION FOR 9 v. SUMMARY JUDGMENT

10 UNITED STATES DEPARTMENT OF Re: Dkt. No. 13 HOMELAND SECURITY, et al., 11 Defendants.

12 13 Plaintiff Yasmin Kullab (“Kullab”) filed an asylum application with the United States 14 Department of Citizenship and Immigration Services (“USCIS”) on November 3, 2020. To date, 15 Kullab’s application has not been adjudicated, and she has not yet been contacted for her asylum 16 interview. Kullab filed this action against USCIS, the United States Department of Homeland 17 Security (“DHS”), and three individuals—Alejandro Mayorkas (“Mayorkas”), Ur M. Jaddou 18 (“Jaddou”), and Emelia Bardini (“Bardini)—in their official capacities (together “defendants”). 19 Under both the Mandamus Act (“Mandamus”) and the Administrative Procedures Act (“APA”), 20 Kullab claims that the adjudication of her application has been unreasonably delayed and requests 21 an order compelling adjudication. Defendants move for summary judgment on both causes of 22 action, arguing that this court does not have jurisdiction to review Kullab’s claims but, even if it 23 did, the claims fail because USCIS has not unreasonably delayed adjudication. While I conclude 24 that I have jurisdiction, and the delay in adjudication is unquestionably long, I cannot find that it is 25 unreasonably long—yet. For the following reasons, the defendants’ motion is GRANTED. 26 BACKGROUND 27 I. USCIS HISTORY AND PROCEDURES 1 in the United States or who arrives in the United States . . . , irrespective of such alien’s status, 2 may apply for asylum in accordance with this section or, where applicable, section 1225(b) of this 3 title.” 8 U.S.C. § 1158(a)(1). The INA gives the Attorney General (and the Secretary of 4 Homeland Security) the discretion to establish procedures for considering asylum applications. 5 8 U.S.C. § 1158(d)(1). The INA does provide guidelines and rules for adjudicating asylum 6 applications, however. See 8 U.S.C. § 1158(d)(5)(A). For example, “in the absence of 7 exceptional circumstances,” asylum interviews shall be held within 45 days of an application’s 8 filing, and the application shall be fully adjudicated within 180 days of filing. 8 U.S.C. 9 § 1158(d)(5)(A)(ii)–(iii). Further, the INA expressly prohibits private substantive or procedural 10 rights of action. 8 U.S.C. § 1158(d)(7). 11 Prior to 1995, as a standard practice, the Immigration and Naturalization Service (“INS”) 12 issued employment authorization to nonfrivolous applicants whose asylum application was not 13 adjudicated in 90 days. Declaration of John L. Lafferty, Dkt. No. 13-1 ¶ 9. Because most 14 applications were not adjudicated in 90 days, INS began mailing employment authorization 15 documents (“EAD”) to applicants upon receipt of their applications. Id. ¶ 9. This practice, 16 however, spiked the number of frivolous asylum applications, resulting in a backlog of over 17 400,000 applications. Id. ¶ 9. 18 To deter people from filing frivolous asylum applications for the purpose of obtaining 19 EAD, the USCIS Asylum Division introduced the “Last-In, First-Out” (“LIFO”) system in 1995. 20 Lafferty Decl. ¶ 11. Under LIFO, “the Asylum Division scheduled recently filed asylum 21 applications for interview ahead of older applications.” Id. ¶ 11. The goal of LIFO was to “put 22 applicants on notice that filing asylum applications primarily to obtain EAD carried a significant 23 risk that their cases would be completed quickly and that their efforts to obtain an EAD would be 24 fruitless.” Id. ¶ 11. Over time, LIFO proved successful, as the backlog reduced from 25 approximately 464,100 applications in 1995 to 4,200 applications by the end of 2013. Id. ¶ 12. 26 LIFO, however, lost its effectiveness following a substantial increase in nationals from 27 Mexico starting in 2013. Lafferty Decl. ¶¶ 13, 21. Because many of these nationals feared 1 credible fear and reasonable fear screenings. Id. ¶¶ 13–14. Credible fear and reasonable fear 2 screenings take substantial USCIS resources because reasonable fear screenings must be 3 completed within 10 days of referral, and “a noncitizen subject to the credible fear process ‘shall 4 be detained’ pending a final determination of their claim.” Id. ¶¶ 15–16; see also 8 C.F.R. 5 § 201.31; 8 U.S.C. § 1225(b)(1)(B)(iii)(IV). In 2013, there was also a substantial increase in 6 unaccompanied children seeking asylum in the United States, which required immediate USCIS 7 effort. Id. ¶ 19. Because USCIS resources were diverted to these time-sensitive matters, asylum 8 applications were no longer adjudicated with the same speed, the deterrence effect of LIFO 9 weakened, and the number of frivolous applications again surged. Id. ¶¶ 20–21. To prevent long 10 adjudicative wait times for asylum applicants, USCIS returned to the “First-in, First-Out” 11 (“FIFO”) system—“under which asylum interviews were scheduled in the order that the 12 applications were filed”—in December 2014. Id. ¶ 21. 13 The return of FIFO had grave consequences for the asylum application backlog. Lafferty 14 Decl. ¶ 22. As such, USCIS announced that it was returning to the LIFO system in January 2018. 15 Id. ¶ 24. Although “receipts immediately fell upon the return to LIFO scheduling,” USCIS faced 16 “a crisis-level backlog of 311,000 pending asylum applications”; “the backlog had grown more 17 than 1,750 percent during the three years of FIFO scheduling.” Id. ¶¶ 26–27, 34 Charts 1 & 2. 18 Under the reinstated LIFO system, asylum interviews are scheduled in the following order: (1) 19 applications that were scheduled for an interview, but the applicant rescheduled; (2) applications 20 pending fewer than 21 days; and (3) “all other pending applications, starting with newer filings 21 and working back toward other filings.”1 Id. ¶ 25; Declaration of Elizabeth D. Kurlan, Dkt. No. 22 13-3 ¶ 3, Ex. 2. 23 In 2022 and 2023, the asylum application backlog began reaccumulating due to a surge in 24 applicants from Colombia, Cuba, Haiti, Nicaragua, and Venezuela. Lafferty Decl. ¶¶ 35–37. In 25 2022 alone, USCIS received 240,787 affirmative asylum applications—excluding credible fear 26 and reasonable fear filings—and a sustained backlog of 572,022 applications. Id. ¶ 34 Charts 1 & 27 1 2. By the end of the third quarter of 2024, there was a total backlog of 1,252,235 applications. Id. 2 ¶ 34 Chart 2. Further, the influx of nationals from these five countries led to more erroneously 3 filed applications, and administrative closures could only be conducted manually.2 Id. ¶¶ 38–39. 4 Other high priority matters and constraints have affected USCIS’s ability to reduce the 5 asylum application backlog. As of September 2021, USCIS is required to adjudicate applications 6 from Afghan nationals on a mandatory, nondiscretionary timeline. Lafferty Decl. ¶ 43. Under 7 Operation Allies Welcome (“OAW”), Congress required “USCIS to interview those applicants 8 within 45 days of filing and . . . to complete final adjudication of their applications within 150 9 days of filing.” Id. ¶ 43.

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Kullab v. United States Department of Homeland Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kullab-v-united-states-department-of-homeland-security-cand-2025.