Mustafin v. Blinken

CourtDistrict Court, D. Massachusetts
DecidedJune 5, 2025
Docket1:24-cv-12484
StatusUnknown

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

Bluebook
Mustafin v. Blinken, (D. Mass. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

* ARSENII MUSTAFIN, * * Plaintiff, * * v. * * Civil Action No. 24-cv-12484-ADB * MARCO RUBIO, Secretary U.S. * Department of State, in his official capacity; * * BRIAN HEATH, Consul General U.S. * Consulate, Frankfurt, Germany, in his * official capacity; and * * JOHN DOES 1-10, Consular Officers * responsible for issuing visas * at the U.S. Consulate Frankfurt, Germany, in * their official capacities, * * Defendants. * *

MEMORANDUM AND ORDER

BURROUGHS, D.J.

Arsenii Mustafin (“Mustafin” or “Plaintiff”) brings the instant suit against Marco Rubio, in his official capacity as Secretary of the U.S. Department of State; Brian Heath, in his official capacity as Consul General of the U.S. Consulate in Frankfurt, Germany; and John Does 1-10, in their official capacities as Consular Officers at the U.S. Consulate in Frankfurt (collectively, “Defendants”) for failure to adjudicate his visa application within a reasonable time. The Complaint asserts claims for unreasonable delay under the Administrative Procedure Act (“APA”), 5 U.S.C. § 706(1) (Count II) and seeks to compel agency action pursuant to the Mandamus and Venue Act (“MVA”), 28 U.S.C. § 1361 (Count I). [ECF No. 1 (“Complaint” or “Compl.”)]. Presently before the Court is Defendants’ motion to dismiss, [ECF No. 11], which is, for the reasons stated herein, GRANTED without prejudice. I. BACKGROUND Following a brief review of the applicable statutory scheme, the Court provides a

summary of the relevant facts, taken primarily from the Complaint. As it may on a motion to dismiss, the Court also considers “documents incorporated by reference in [the complaint], matters of public record, and other matters susceptible to judicial notice.” Giragosian v. Ryan, 547 F.3d 59, 65 (1st Cir. 2008) (alteration in original) (quoting In re Colonial Mortg. Bankers Corp., 324 F.3d 12, 20 (1st Cir. 2003)). A. Statutory Scheme Under the Immigration and Nationality Act of 1952 (“INA”), a foreign citizen may only enter the United States with either an immigrant or a nonimmigrant visa. 8 U.S.C. §§ 1181(a), 1182(a)(7). The nonimmigrant F-1 visa allows foreign citizens who are enrolled as full-time

students in an accredited academic educational program to enter the United States. U.S. Citizenship and Immigr. Servs., Students and Employment, https://www.uscis.gov/working-in- the-united-states/students-and-exchange-visitors/students-and-employment (last visited May 21, 2025). As part of the F-1 visa application process, the applicant files the Nonimmigrant Visa Application, or DS-160, through the State Department’s website. 22 C.F.R. § 41.103(a). The applicant must also attend an in-person interview with a consular officer. 8 U.S.C. § 1202(h) (“[T]he Secretary of State shall require every alien applying for a nonimmigrant visa” to appear for an interview.); see also 8 U.S.C. § 1202(d) (“All nonimmigrant visa applications shall be reviewed and adjudicated by a consular officer.”). After the interview, a consular officer must “issue the visa” or “refuse the visa.” 22 C.F.R. § 41.121(a) (“When a visa application has 2 been properly completed and executed in accordance with the provisions of the INA and the implementing regulations, the consular officer must issue the visa, refuse the visa, or, pursuant to an outstanding order under INA 243(d), discontinue granting the visa.”).1 If the consular officer refuses the visa, they must “inform the alien of the ground(s) of ineligibility . . . and whether

there is, in law or regulations, a mechanism (such as a waiver) to overcome the refusal.” 22 C.F.R. § 41.121(b)(1). Section 221(g) of the INA, the basis of refusal at issue here, provides that no visa shall be issued if: (1) it appears to the consular officer, from statements in the application, or in the papers submitted therewith, that such alien is ineligible to receive a visa or such other documentation under section 1182 of this title, or any other provision of law, (2) the application fails to comply with the provisions of this chapter, or the regulations issued thereunder, or (3) the consular officer knows or has reason to believe that such alien is ineligible to receive a visa or such other documentation under section 1182 of this title, or any other provision of law[.]

8 U.S.C. § 1201(g); see 22 C.F.R. § 41.121(a) (refusals of nonimmigrant visas “must be based on legal grounds, such as . . . INA 221(g)”); see also 8 U.S.C. § 1182 (a)(1)–(10) (defining “[c]lasses of aliens ineligible for visas or admission,” on health-related grounds, criminal and related grounds, and security and related grounds, among others); 9 U.S. Dep’t of State, Foreign Affairs Manual § 302.1-8(B)(a) (“FAM”) (listing additional grounds for refusing a visa under INA 221(g), including where an applicant “fails to furnish information as required by law or regulations” or an application “is not supported by the documents required by law or regulations”).

1 An order under INA 243(d) allows the United States to sanction countries for failing to accept the return of their citizens and nationals removed from the United States. That provision, however, is not relevant for present purposes. 22 C.F.R. § 41.121(a); see 8 U.S.C. § 1253(d). 3 Agency guidance permits a consular officer who refuses a visa to obtain additional information from the applicant and place the visa application in “administrative processing.” See 9 FAM § 306.2-2(A)(a); Rahman v. Blinken, No. 22-cv-02732, 2023 WL 196428, at *1 (D.D.C. Jan. 17, 2023) (noting that a consular officer “need only make an initial, rather than a final,

determination about an applicant’s visa eligibility” and that under § 221(g) they “can temporarily refuse to issue a visa in order to allow for further administrative processing of an applicant’s case if the officer needs more information or time to determine eligibility” (citing 8 U.S.C. § 1201(g)). Put differently, refusal under § 221(g) may be overcome “when additional evidence is presented, or administrative processing is completed.” 9 FAM § 306.2-2(A)(a); U.S.

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Bluebook (online)
Mustafin v. Blinken, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mustafin-v-blinken-mad-2025.