Rohmeena v. Bitter

CourtDistrict Court, District of Columbia
DecidedAugust 22, 2024
DocketCivil Action No. 2023-2754
StatusPublished

This text of Rohmeena v. Bitter (Rohmeena v. Bitter) 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
Rohmeena v. Bitter, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

FNU ROHMEENA,

Plaintiff,

v. Case No. 1:23-cv-2754 (ACR)

RENA BITTER, et al.,

Defendants.

MEMORANDUM OPINION AND ORDER

In 2022, Plaintiff Fnu Rohmeena applied for an immigrant visa to join her husband in the

United States. She has not yet sat for a consular interview—a necessary step toward acquiring a

visa. Plaintiff has sued several State Department officials, seeking an order compelling prompt

adjudication of her application. Although the Court sympathizes with Plaintiff’s situation, her

Complaint does not plausibly show that the delay is unreasonable. The Court therefore dismisses

this case without prejudice.

I. BACKGROUND

A. Legal Background

A U.S. citizen who wants to help a noncitizen spouse obtain lawful permanent resident

status may file an I-130 Petition for Alien Relative with U.S. Citizenship and Immigration

Services (USCIS), a subagency of the Department of Homeland Security. See 8 U.S.C.

§§ 1152(b)(2)(A)(i), 1154; 8 C.F.R. § 204.1(a)(1). If USCIS approves the petition and the

beneficiary spouse is outside the United States, the agency forwards the case to the State

Department’s National Visa Center (NVC) for processing. 8 C.F.R. § 204.2(a)(3). The

beneficiary spouse must then submit additional paperwork, including a visa application form, 1 and fees. See 22 C.F.R. §§ 42.62-.63; 9 Foreign Affs. Manual § 504.1-2(b), https://fam.state.gov/

FAM/09FAM/09FAM050401.html [https://perma.cc/END7-MHKW]. Once the applicant (that

is, the beneficiary spouse) meets those requirements, the NVC designates the case

“documentarily complete” and coordinates with the appropriate consulate or embassy to

schedule the applicant for a required consular interview. See 22 C.F.R. § 42.62; 9 Foreign Affs.

Manual § 504.1-2(b)-(d). “Appointments are generally scheduled in the chronological order of

the documentarily complete applicants.” 9 Foreign Affs. Manual § 504.1-2(d). Following the

interview, the consular officer “must” generally either “issue the visa” or “refuse the visa.”1 22

C.F.R. § 42.81(a).

B. Factual Background

The Court takes the facts from Plaintiff’s Complaint. See Ashcroft v. Iqbal, 556 U.S.

662, 678 (2009).

Plaintiff Rohmeena is a citizen and resident of Pakistan. Dkt. 1 (Compl.) ¶ 12. Her

husband, Ramin Sadat, is a U.S. citizen. Id. ¶ 2. Sadat filed an I-130 petition with USCIS on

Plaintiff’s behalf in February 2021. Id. ¶ 19. USCIS approved the petition in September 2022.

Id. ¶ 20. At some point thereafter, USCIS forwarded the case to the NVC, which designated

Plaintiff’s application documentarily complete in December 2022—presumably after Plaintiff

submitted the application materials and fees described above, though the Complaint, puzzlingly,

does not describe those submissions or the dates on which Plaintiff made them. See id. ¶ 22.

The next step toward Rohmeena’s obtaining a visa is a consular interview at the U.S.

Embassy in Pakistan. See id. ¶ 4; supra Section I.A. But that interview has not yet taken place.

1 The consular officer must instead “discontinue granting the visa” if the applicant’s country is subject to visa sanctions under 8 U.S.C. § 1253(d). 22 C.F.R. § 42.81(a). 2 The delay has separated Plaintiff from her husband in the United States and caused them both

“significant personal, financial, and emotional hardship.” Compl. ¶ 7. Plaintiff has “experienced

episodes of vertigo, sleeplessness, fear, and nonstop emotional breakdowns.” Id. ¶ 8. Her

husband has suffered “stress and anxiety” and struggled to care for an ailing family member

without Plaintiff’s assistance. Id. ¶¶ 9, 10. Both have had to “forgo better work opportunities,”

and the need two support two households has strained the couple financially. Id. ¶¶ 10-11. In

addition, “Plaintiff and her husband are concerned about potential difficulties in conceiving

children if this delay continues.” Id. ¶ 9.

C. Procedural Background

Plaintiff filed this case against Assistant Secretary of State for Consular Affairs Rena

Bitter, Secretary of State Antony Blinken, and Deputy Chief of Mission for the U.S. Embassy in

Pakistan Andrew Schofer in September 2023. Compl. The Complaint asserts that Defendants

have unreasonably delayed in conducting Plaintiff’s consular interview and adjudicating her visa

application. Id. ¶¶ 1-5, 25-36. Citing both the Administrative Procedure Act (APA), 5 U.S.C. §

706, and the Mandamus Act, 28 U.S.C. § 1361, Plaintiff seeks an order compelling Defendants

to decide the application. Compl. ¶¶ 25-36; id. at 6-7. Defendants have moved to dismiss the

Complaint under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim.2 Dkt. 8

(Mot.).

2 The Motion also seeks dismissal for lack of jurisdiction under Rule 12(b)(1), arguing that Defendants do not have any clear, nondiscretionary duty to act, as is necessary for a mandamus claim. Mot. at 5-12. That argument, which has divided courts in this District, “is at most a matter of statutory jurisdiction, rather than an Article III concern.” Rashidian v. Garland, No. 23-cv-1187, 2024 WL 1076810, at *5 & n.5 (D.D.C. Mar. 8, 2024). Because the Court “may address the merits where doing so makes it possible to avoid a doubtful issue of statutory jurisdiction,” id. (cleaned up), and agrees that Plaintiff has not stated a claim, the Court bypasses this argument. 3 II. LEGAL STANDARDS

To avoid dismissal under Rule 12(b)(6), “a complaint must contain sufficient factual

matter, accepted as true, to state a claim to relief that is plausible on its face.” Iqbal, 556 U.S. at

678 (cleaned up). To meet that standard, a plaintiff’s allegations must support a “reasonable

inference that the defendant is liable for the misconduct alleged.” Id. “The plausibility standard

is not akin to a probability requirement, but it asks for more than a sheer possibility that a

defendant has acted unlawfully.” Id. (cleaned up). “Where a complaint pleads facts that are

merely consistent with a defendant’s liability, it stops short of the line between possibility and

plausibility of entitlement to relief.” Id. (cleaned up).

III. ANALYSIS

“[T]he central question” in unreasonable-delay cases under both the APA and the

Mandamus Act “is ‘whether the agency’s delay is so egregious as to warrant mandamus.’”

Barazandeh v. U.S. Dep’t of State, No. 23-cv-1581, 2024 WL 341166, at *6 (D.D.C. Jan. 30,

2024) (cleaned up) (quoting In re Core Commc’ns, Inc., 531 F.3d 849, 855 (D.C. Cir. 2008)).

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Related

Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Mashpee Wampanoag Tribal Council, Inc. v. Norton
336 F.3d 1094 (D.C. Circuit, 2003)
In Re Core Communications, Inc.
531 F.3d 849 (D.C. Circuit, 2008)

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