Park v. Edlow

CourtDistrict Court, District of Columbia
DecidedJuly 16, 2026
DocketCivil Action No. 2026-0504
StatusPublished

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

Bluebook
Park v. Edlow, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

EUN YOUNG PARK,

Plaintiff, Civil Action No. 26-504 (BAH) v. Judge Beryl A. Howell JOSEPH B. EDLOW, et al.,

Defendants.

MEMORANDUM OPINION

Plaintiff Eun Young Park, a citizen of South Korea, seeks to compel defendants Joseph B.

Edlow, the director of U.S. Citizenship and Immigration Services, Alissa L. Emmel, the Chief of

the U.S. Citizenship and Immigration Services Immigrant Investor Program Office, and

Markwayne Mullin, the Secretary of the U.S. Department of Homeland Security, in their official

capacities (collectively, “defendants”), to adjudicate her application for an EB-5 visa, which had

been in administrative proceedings for more than two years at the time plaintiff initiated this

lawsuit. See Compl. ¶ 22, ECF No. 1. 1 Plaintiff claims that defendants have unreasonably delayed

adjudication of her application, in violation of the Administrative Procedure Act (“APA”), 5

U.S.C. § 706(1), the Mandamus Act, 28 U.S.C. § 1361, and the Declaratory Judgment Act, 28

U.S.C. § 2201. Compl. ¶¶ 4-5, 37. Defendants now move to dismiss for lack of jurisdiction, under

Federal Rule of Civil Procedure 12(b)(1), or, alternatively, for failure to state a claim under Rule

1 An original defendant to this action, Kristi Noem, then-Secretary of the U.S. Department of Homeland Security, has been substituted with the current Secretary of the U.S. Department of Homeland Security, Markwayne Mullin. See FED. R. CIV. P. 25(d) (“An action does not abate when a public officer who is a party in an official capacity dies, resigns, or otherwise ceases to hold office while the action is pending. The officer’s successor is automatically substituted as a party.”).

1 12(b)(6). See Defs.’ Mot. to Dismiss & Mem. in Supp. Thereof (“Defs.’ Mot.”), ECF No. 7. For

the reasons set out below, defendants’ motion is granted.

I. BACKGROUND

The statutory and regulatory background underlying the claims is set out below, followed

by a summary of the factual and procedural history of this case.

A. Statutory and Regulatory Background

Congress established the EB-5 immigrant-investor visa program through the Immigration

Act of 1990, Pub. L. No. 101-649, § 121, 104 Stat. 4978, 4987 (1990) (codified at 8 U.S.C.

§ 1153(b)(5)), and “is so named because it is the ‘fifth employment-based visa category available

to foreign nationals’ under the Immigration and Nationality Act.” Del. Valley Reg’l Ctr., LLC v.

U.S. Dep’t of Homeland Sec., 106 F.4th 1195, 1197 (D.C. Cir. 2024) (quoting Mirror Lake Vill.,

LLC v. Wolf, 971 F.3d 373, 374 (D.C. Cir. 2020)). These visas are available “to qualified

immigrants seeking to enter the United States for the purpose of engaging in a new commercial

enterprise (including a limited partnership)” that “will benefit the United States economy by

creating full-time employment for not fewer than 10 United States citizens, United States nationals,

or aliens lawfully admitted for permanent residence or other immigrants lawfully authorized to be

employed in the United States (other than the immigrant and the immigrant’s spouse, sons, or

daughters).” 8 U.S.C. § 1153(b)(5)(A). To that end, the immigrant must have made or be in the

process of making an investment of at least $1,050,000 generally or at least $800,000 into a

“targeted employment area.” Id. § 1153(b)(5)(C)(ii).

“The EB-5 process is administered by USCIS and the State Department.” Del. Valley, 106

F.4th at 1198. First, “USCIS processes and approves the visa petitions—i.e., it assesses whether

petitioners qualify for the requested visa,” and then “[t]he State Department determines how many

visas are available and allocates visas to approved applicants.” Id. (citing 8 C.F.R. §§ 100.1, 103.2, 2 254.2(a), and 22 C.F.R. §§ 42.41, 42.51). “Once an immigrant investor obtains an EB-5 visa, they

may apply for a two-year conditional lawful-permanent-resident status,” after which period, “the

investor may file a petition to become a permanent resident in the United States.” Id. (citing 8

U.S.C. § 1186b(a), (c), (d), and 8 C.F.R. §§ 216.1, 216.6, 245.2).

B. Factual Background

Plaintiff paid the appropriate fees and filed the instant I-526E Petition on January 5, 2024,

to which USCIS assigned Case Number IOE8079101172. Compl. ¶¶ 19-20, 31. “The application

was received by USCIS’s Service Center and subsequently transferred to the USCIS Immigrant

Investor Program [O]ffice,” which is “a program office . . . devoted exclusively to EB-5

adjudications.” Id. ¶ 21. In the two years since the petition was filed, “[d]efendants have offered

no explanation for their persistent delay and no indication whether a decision on the petition is

imminent.” Id. ¶ 28. Plaintiff seeks an expeditious decision on this petition because “[t]he delay

in adjudication postpones the date on which she will be eligible to live with her family studying in

the U.S.” Id. ¶ 29. According to plaintiff, such “unreasonable delay has caused Plaintiff

significant harm, including prolonged uncertainty regarding lawful permanent residence, inability

to proceed with adjustment of status or immigrant visa processing, and financial and emotional

hardship.” Id. ¶ 18.

C. Procedural Background

Plaintiff filed the instant complaint on February 17, 2026, seeking “to compel Defendants

to make a decision on h[er] long-pending I-526E petition without further unreasonable day.”

Compl. ¶ 30. Defendants have now moved to dismiss, arguing that “this Court lacks subject matter

jurisdiction over Plaintiff’s claims regarding the processing of her Form I-526 petition,” so “the

Complaint must be dismissed pursuant to Rule 12(b)(1),” and that “Plaintiff alleges no facts

3 beyond the approximate two-year delay to make a claim of unreasonable delay plausible,” so the

complaint should be dismissed under Federal Rule of Civil Procedure 12(b)(6). Defs.’ Mot. at 1.

On June 5, 2026, plaintiff was ordered to show cause “by June 12, 2026, why defendants’

[] Motion to Dismiss should not be granted as conceded,” given that any opposition was due

several weeks earlier, on May 15, 2026. Minute Order (June 5, 2026) (citing D.D.C. Local Rule

47(b)). On June 15, 2026, plaintiff was granted leave to file a belated opposition to defendants’

dismissal motion. See Pl.’s Resp. to O.S.C. & Opp’n to Defs.’ Mot. to Dismiss (“Pl.’s Opp’n”),

ECF No. 8 (arguing excusable neglect justified acceptance of the untimely filing); Minute Order

(June 15, 2026) (granting leave to file and discharging order to show cause). The pending motion

to dismiss became ripe for resolution on June 18, 2026. See Defs.’ Reply in Further Supp. of

Defs.’ Mot. to Dismiss & Opp’n to Pl.’s Cross-Mot. for Summ. J.

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