Liang v. Attorney General of the United States

CourtDistrict Court, S.D. Florida
DecidedMarch 18, 2021
Docket1:20-cv-23625
StatusUnknown

This text of Liang v. Attorney General of the United States (Liang v. Attorney General of the United States) is published on Counsel Stack Legal Research, covering District Court, S.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Liang v. Attorney General of the United States, (S.D. Fla. 2021).

Opinion

United States District Court for the Southern District of Florida

Chunmei Liang, Plaintiff, ) ) v. ) ) Civil Action No. 20-23625-Civ-Scola Attorney General of the Unites ) States, William Barr, and others, ) Defendants. ) Order Granting Motion to Dismiss In her complaint, Plaintiff Chunmei Liang objects to the Defendant Government’s delay in processing her form I-485 application for adjustment of status, filed in 2015. (Compl., ECF No. 1.) Through this action, Liang “seeks to compel the Defendants . . . to take all appropriate action to adjudicate [her] application . . . without further delay.” (Id. at 2.) In response, the Government has filed a motion to dismiss, submitting Liang’s case is now moot because, about two months after she filed her complaint, USCIS adjudicated Liang’s application, albeit in the form of a denial. (Defs.’ Mot., ECF No. 9.) In response, Liang argues her complaint is not moot because the Government’s denial of her application violated her due-process rights as well as the Administrative Procedures Act and the Immigration and Nationality Act. (Pl.’s Resp., ECF No. 10.) The Government has timely replied, pointing out procedural and substantive defects in Liang’s position. (Defs.’ Reply, ECF No. 11.) After careful review, the Court agrees with the Government that Liang’s case is now moot and, therefore, grants the Government’s motion (ECF No. 11). 1. Background1 Liang entered the United States on a non-immigrant B-1 Visa on October 3, 2006. (Compl. ¶¶ 1, 20.) That Visa expired on September 14, 2007 but Liang nonetheless remained in the country. (Id., Ex. B, Visa, ECF No. 1-1, 3; Defs.’

1 The Court generally accepts the complaint’s factual allegations as true for the purposes of evaluating the Defendants’ motions to dismiss. Brooks v. Blue Cross & Blue Shield of Fla., Inc., 116 F.3d 1364, 1369 (11th Cir. 1997). The Court has also considered extrinsic documents, supplied by the parties, because the supplied documents are central to Liang’s claim and none of the parties challenges their authenticity. See Speaker v. U.S. Dept. of Health & Human Services Centers for Disease Control & Prevention, 623 F.3d 1371, 1379 (11th Cir. 2010) (“In ruling upon a motion to dismiss, the district court may consider an extrinsic document if it is (1) central to the plaintiff's claim, and (2) its authenticity is not challenged.”). Further, where a defendant makes a factual challenge to the Court’s subject matter jurisdiction, a district court may consider extrinsic evidence relevant to its jurisdictional determination. Carmichael v. Kellogg, Brown & Root Servs., Inc., 572 F.3d 1271, 1279 (11th Cir. 2009). Mot. ¶ 1.) In April 2015, Liang filed her application for adjustment. (Compl. ¶ 23.) During the pendency of her application, Liang has submitted all the requested documents, had her biometrics taken multiple times, and participated in two interviews with United States Citizenship and Immigration Services, one in November 2015, and one in June 2018. (Id. ¶ 25.) During the over five years in which her application has been pending, Liang has repeatedly requested updates and other information about her case. (Id. ¶ 29.) Invariably, USCIS’s response has been that “the file is in background investigation” or “it is out of our hands and we cannot do anything about it.” (Id.) In response to the delay, Liang filed her complaint, alleging violations of the Administrative Procedures Act (count one); seeking mandamus relief (count two); alleging a violation of 8 C.F.R. § 103.2(b)(18) (count three); seeking a declaratory judgment (count four); and alleging violations of her due-process and equal-protection rights (count five). (Compl., ¶¶ 37–51.) Nearly two months after her complaint was filed, on October 27, 2020, USCIS issued its decision, denying Liang’s application for adjustment. 2. Legal Standard A district court must dismiss an action if the court lacks jurisdiction over the subject matter of the suit. See Fed. R. Civ. P. 12(b)(1), 12(h)(3). “Attacks on subject matter jurisdiction under Fed. R. Civ. P. 12 (b)(1) come in two forms”: as either “facial attacks,” in which the court merely determines whether the plaintiff has sufficiently alleged a basis for subject matter jurisdiction; or as “factual attacks,” in which subject-matter jurisdiction is determined on matters “irrespective of the pleadings.” Lawrence v. Dunbar, 919 F.2d 1525, 1528–29 (11th Cir. 1990). “[W]here a defendant raises a factual attack on subject matter jurisdiction,” as here, “the district court may consider extrinsic evidence” relevant to its jurisdictional determination. Carmichael, 572 F.3d at 1279. A district court is free to weigh the facts and is not constrained to view them in the light most favorable to the plaintiff. Id. 3. Discussion Despite USCIS’s having adjudicated Liang’s application, Liang insists her case is not moot because, in issuing its decision, USCIS has “fail[ed] to follow its own procedures and violate[d her] due process rights.” (Pl.’s Resp. at 2.) In framing her position, Liang recites a host of complaints regarding errors she says USCIS made in denying her application. She argues that “the mere adjudication of her claim does not provide the relief requested” in that she “still maintains a legally cognizable interest in the outcome” and that, therefore, the Court still retains jurisdiction to hear her claim. (Id. at 11, 16.) The court disagrees. Although jurisdiction is usually determined at filing, after-arising events can affect jurisdiction because the case-or-controversy requirement of Article III, section 2, of the United States constitution persists through all stages of federal judicial proceedings. See Spencer v. Kemna, 523 U.S. 1, 7 (1998) (noting “[t]he parties must continue to have a personal stake in the outcome of the lawsuit” and, therefore, the “case-or-controversy requirement subsists through all stages of federal judicial proceedings”) (cleaned up). A plaintiff must demonstrate that the “actual injury traceable to the defendant,” as set forth in her complaint, will “likely be redressed by a favorable judicial decision.” Lewis v. Cont’l Bank Corp., 494 U.S. 472, 477 (1990) (“Article III denies federal courts the power to decide questions that cannot affect the rights of litigants in the case before them . . . .”) (cleaned up). And, so, that USCIS issued its decision after Liang filed her complaint, does not alter the Court’s jurisdictional analysis. Liang’s complaint focuses on USCIS’s failure to adjudicate her application. (E.g., Compl. at 1 (describing her lawsuit as the result of USCIS’s “failure to adjudicate [her] application for adjustment of status”) (“This action seeks to compel [USCIS] to take all appropriate action to adjudicate [her] application . . . without further delay”) (complaining USCIS has “improperly withheld action on [her] application for an unreasonable period of time”); ¶ 1 (“USCIS refuses to adjudicate the I-485 application”); ¶ 14 (“the present action . . .

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Related

Carmichael v. Kellogg, Brown & Root Services, Inc.
572 F.3d 1271 (Eleventh Circuit, 2009)
Lewis v. Continental Bank Corp.
494 U.S. 472 (Supreme Court, 1990)
Spencer v. Kemna
523 U.S. 1 (Supreme Court, 1998)
Dolcie Lawrence v. Peter Dunbar, United States of America
919 F.2d 1525 (Eleventh Circuit, 1990)
Benjamin Burgess v. Religious Technology Center, Inc.
600 F. App'x 657 (Eleventh Circuit, 2015)
Ronald C. Hood, Jr. v. Department of Children and Families
700 F. App'x 988 (Eleventh Circuit, 2017)
Brooks v. Blue Cross & Blue Shield of Florida, Inc.
116 F.3d 1364 (Eleventh Circuit, 1997)

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Liang v. Attorney General of the United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/liang-v-attorney-general-of-the-united-states-flsd-2021.