Salem v. Mayorkas

CourtDistrict Court, N.D. Illinois
DecidedJune 3, 2025
Docket1:24-cv-11522
StatusUnknown

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

Bluebook
Salem v. Mayorkas, (N.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION HUSSEIN SALEH SALEM, ) ) Plaintiff, ) No, 24-ev-11522 ) v. ) Judge Jeffrey I. Cummings ) KRISTI NOEM, in her official capacity ) as Secretary of Homeland Security, ) et al.,! ) ) Defendants. ) MEMORANDUM OPINION AND ORDER Plaintiff Hussein Saleh Salem (“plaintiff’ or “Hussein”), a citizen of the United States, brings this action on behalf of his son, Saleh Hussain Salem (“Saleh”), a citizen of Yemen, against the U.S. Secretary of the Department of Homeland Security (“DHS”), the U.S. Secretary of State, the Director of the FBI, the Chicago Field Office Director of the U.S. Citizenship and Immigration Services (“USCIS”), and the U.S. Special Envoy for Middle East Humanitarian Issues (collectively, “defendants”) to compel further action on Saleh’s I-130 visa application. Hussein purports to bring his claims under the under the Administrative Procedure Act, 5 U.S.C. §706(1), and the Mandamus Act, 28 U.S.C. §1361. Defendants now move to dismiss the complaint pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6), arguing that the Court lacks subject matter jurisdiction, and that plaintiff has otherwise failed to state a claim upon which relief can be granted. Despite appearing through counsel and agreeing to a briefing schedule with a specified date to file his

' Pursuant to Federal Rule of Civil Procedure 25(d), the Court substitutes Secretary of the Department of Homeland Security Kristi Noem, Secretary of State Marco Rubio, Director of the FBI Kash Patel, and Chicago Field Office Director of the U.S. Citizenship and Immigration Services Kevin Riddle for the previously named defendants.

response brief in a January 21, 2025 joint status report, (Dckt. #9), plaintiff failed to respond to defendants’ motion. For the reasons set forth below, defendants’ motion to dismiss, (Dckt. #7), is granted. I. BACKGROUND A. The I-130 Visa Application Process The Immigration and Nationality Act (“INA”) governs the admission of noncitizens into the United States. 8 U.S.C. §1101 ef seg. Pursuant to the INA, “a noncitizen seeking to reside permanently in the United States and obtain a path to eventual citizenship must obtain an immigrant visa.” Ebrahimi v. Blinken, 732 F.Supp.3d 894, 899 (N.D.Ill. 2024) (citing 8 U.S.C. §§1101(a)(15), 1181(a), 1182(a)(7), 1184(a)). A noncitizen seeking admission to the United States bears the burden of establishing eligibility to receive a visa. See 8 U.S.C. §1361; 22 C.F.R. §40.6. “One means of obtaining an immigrant visa is for a U.S. citizen to file a file a Form 1-130 petition for a family-based immigrant visa” with the USCIS. Patel v. Sanders, No. 24 C 8386, 2025 WL 1039505, at *1 (N.D.II. Apr. 7, 2025) (citing 8 U.S.C. §1154(a); 8 C.F.R. §204.2). After USCIS reviews and approves the I-130 application, the noncitizen must complete a Form DS-260 (“Application for Immigrant Visa and Alien Registration”). USCIS then transfers case to the U.S. Consulate so a consular officer can interview the potential visa recipient. See 8 U.S.C. §§1154(b), 1201(a), (h). “At the conclusion of the interview between the consular officer and the noncitizen, the consular officer must either issue or refuse the visa.” Patel, 2025 WL 1039505, at *1; 22 C.F.R. §42.81(a) (“[T]he consular officer must issue the visa, refuse the visa under INA 212(a) or 221(g) or other applicable law or, pursuant to an outstanding order under INA 243(d), discontinue granting the visa.”).

Pursuant to §221(g): No visa or other documentation shall be issued to an alien if (1) it appears to the consular officer, from the statements in the application . . . that such alien is ineligible to receive a visa... , (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

8 U.S.C. §1201(g). Moreover, if a consular officer refuses to issue a visa, they must “inform the applicant of the provision of law or implementing regulation on which the refusal is based and of any statutory provision of law or implementing regulation under which administrative relief is available.” 22 C.F.R. §42.81(b). B. Plaintiff's Form I-130 Application The following facts are taken from the allegations in the complaint, (Dckt. #1), “documents that are attached to the complaint, documents that are central to the complaint and are referred to in it, and information that is properly subject to judicial notice.” Williamson v. Curran, 714 F.3d 432, 436 (7th Cir. 2013). Plaintiff Hussein was born in 1980 in Yemen. (Dckt. #1 at 2). He subsequently immigrated to the United States and became a naturalized citizen. (/d.). On June 1, 2021, Hussein filed a Form I-130 (“Petition for Alien Relative”) on behalf of his son Saleh, a citizen of Yemen. (/d. at 3). On or about June 1, 2022, USCIS approved the I-130 petition and transferred the case to the U.S. Department of State for visa processing. (/d.). On June 30, 2022, plaintiff submitted the Form DS-260 Application. (/d.). The U.S. Embassy in Djibouti scheduled Saleh’s visa interview for February 9, 2023. (d.). Saleh attended the interview as directed. (/d.). Subsequently, a consular officer refused the application “under 221(g) and requested a DNA test for proof of parentage.” (/d.; see also Dckt. #1-2 at 3). Although plaintiff did not attach the refusal notice to his complaint, defendants include in their

motion a screenshot of plaintiffs application status (as of January 15, 2025), which indicates that the application was “Refused” and provides in relevant part: A US. consular officer has adjudicated and refused your visa application. Please follow any instructions provided by the consular officer. If you were informed by the consular officer that your case was refused for administrative processing, your case will remain refused which undergoing such processing. You will receive another adjudication once such processing is complete. (Dckt. #8 at 4) (emphasis added). On June 8, 2024, plaintiff contacted the Embassy via email requesting a status update on the application and confirming that he had previously provided the requested DNA test. (Dckt. #1-2 at 3). A representative from the Embassy responded on July 10, 2024, as follows: Thank you for your email. After a review of the documents submitted, this case remains refused under 221G.

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Bluebook (online)
Salem v. Mayorkas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/salem-v-mayorkas-ilnd-2025.