Sidhu v. Emmel

CourtDistrict Court, District of Columbia
DecidedJune 20, 2024
DocketCivil Action No. 2023-2963
StatusPublished

This text of Sidhu v. Emmel (Sidhu v. Emmel) 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
Sidhu v. Emmel, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

HARMINDER SIDHU,

Plaintiff,

v. Civil Action No. 23-2963 (TJK)

ALISSA EMMEL et al.,

Defendants.

MEMORANDUM

Plaintiff is an Indian national living in Australia who alleges that his immigrant visa appli-

cation has been pending since June 29, 2021, when he filed an I-526 Immigrant Petition by Alien

Entrepreneur. ECF No. 1 (“Compl.”) ¶¶ 1–2. Section 203(b)(5) of the Immigration and Nation-

ality Act, known as the EB-5 program, provides for visas “to qualified immigrants seeking to enter

the United States for the purpose of engaging in a new commercial enterprise.” 8 U.S.C.

§ 1153(b)(5)(A). Under that program, lawful permanent resident status is available to foreign na-

tionals who make a minimum investment in a new commercial enterprise that will create a certain

number of full-time jobs in the United States. See 82 Fed. Reg. 3211, 3212 (Jan. 11, 2017). Plain-

tiff has invested $540,000 into a commercial real estate project in San Bernardino and Riverside

Counties, California, and thus seeks lawful permanent resident status in the United States. See

Compl. ¶ 18. And after waiting about 27 months for his application to be adjudicated, he brought

this case in October 2023. He alleges that Defendants have unreasonably delayed resolving his

visa application and seeks to compel them to issue a final decision. See generally id. Defendants

move to dismiss for failure to state a claim. For the reasons explained below, the Court will grant

the motion and dismiss the case. “A Rule 12(b)(6) motion to dismiss tests the legal sufficiency of a plaintiff’s complaint; it

does not require a court to ‘assess the truth of what is asserted or determine whether a plaintiff has

any evidence to back up what is in the complaint.’” Herron v. Fannie Mae, 861 F.3d 160, 173

(D.C. Cir. 2017) (quoting Browning v. Clinton, 292 F.3d 235, 242 (D.C. Cir. 2002)). “In evaluat-

ing a Rule 12(b)(6) motion, the Court must construe the complaint ‘in favor of the plaintiff, who

must be granted the benefit of all inferences that can be derived from the facts alleged.’” Hettinga

v. United States, 677 F.3d 471, 476 (D.C. Cir. 2012) (quoting Schuler v. United States, 617 F.2d

605, 608 (D.C. Cir. 1979)). But a court is not “bound to accept as true a legal conclusion couched

as a factual allegation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v.

Twombly, 550 U.S. 544, 555 (2007)).

The complaint asserts claims of unreasonable delay under both the Administrative Proce-

dure Act (“APA”) and the Mandamus Act, 28 U.S.C. § 1361. In Count I, Plaintiff alleges unrea-

sonable delay under 5 U.S.C. §§ 555(b) and 706(1). The APA requires that agencies pass on mat-

ters presented to them “within a reasonable time,” 5 U.S.C. § 555(b), and if they fail to do so,

authorizes reviewing courts to “compel agency action unlawfully withheld or unreasonably de-

layed,” id. § 706(1). “To state a claim for unreasonable delay, Plaintiffs must first allege that the

agency ‘failed to take a discrete agency action that it is required to take’ . . . and, second, that the

delay was unreasonable.” Da Costa v. Immigr. Inv. Program Off., 80 F.4th 330, 340 (D.C. Cir.

2023) (quoting Norton v. S. Utah Wilderness All., 542 U.S. 55, 64 (2004), and Am. Anti-Vivisection

Soc’y v. USDA, 946 F.3d 615, 621 (D.C. Cir. 2020)). 1

1 Count II asserts a claim under 5 U.S.C. § 706(2)(A), which requires courts to “hold un- lawful and set aside agency action” that is “arbitrary, capricious, an abuse of discretion, or other- wise not in accordance with law.” See Compl. ¶¶ 41–43; ECF No. 4 at 10 (“In count II, Plaintiff asserts that Defendants unreasonably delayed action under . . . § 706(2)(A).”). “But, by the APA’s

2 In Count III, Plaintiff invokes the Court’s mandamus jurisdiction. Courts may issue writs

of mandamus to “compel an officer or employee of the United States or any agency thereof to

perform a duty owed to the plaintiff.” 28 U.S.C. § 1361. “[C]onsideration of any mandamus

petition starts from the premise that issuance of the writ is an extraordinary remedy, reserved only

for the most transparent violations of a clear duty to act.” In re Core Commc’ns, Inc., 531 F.3d

849, 855 (D.C. Cir. 2008) (internal quotation marks and citations omitted). The central question,

then, is “whether the agency’s delay is so egregious as to warrant mandamus.” Id. (quoting Tele-

comms. Rsch. & Action Ctr. v. FCC (“TRAC”), 750 F.2d 70, 79 (D.C. Cir. 1984)).

The same standard applies to claims of unreasonable delay under the APA and the Manda-

mus Act. See Norton, 542 U.S. at 63–64; Am. Hosp. Ass’n v. Burwell, 812 F.3d 183, 189 (D.C.

Cir. 2016). “There is ‘no per se rule as to how long is too long’ to wait for agency action.” In re

Am. Rivers & Idaho Rivers United, 372 F.3d 413, 419 (D.C. Cir. 2004) (quoting In re Int’l Chem.

Workers Union, 958 F.2d 1144, 1149 (D.C. Cir. 1992)). Instead, courts rely on the six “TRAC

factors”:

(1) the time agencies take to make decisions must be governed by a rule of reason;

(2) where Congress has provided a timetable or other indication of the speed with which it expects the agency to proceed in the enabling statute, that statutory scheme may supply content for this rule of reason;

(3) delays that might be reasonable in the sphere of economic regulation are less tolerable when human health and welfare are at stake;

plain text, a claim for ‘agency action unlawfully withheld or unreasonably delayed’ arises under § 706(1), not § 706(2)(A),” so to the extent this count is duplicative of Count I, it fails to state a claim for the same reasons described later in this Memorandum. See Lee v. Blinken, No. 23-cv- 1783 (DLF), 2024 WL 639635, at *7 (D.D.C. Feb. 15, 2024).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Norton v. Southern Utah Wilderness Alliance
542 U.S. 55 (Supreme Court, 2004)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
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 American Rivers
372 F.3d 413 (D.C. Circuit, 2004)
In Re Core Communications, Inc.
531 F.3d 849 (D.C. Circuit, 2008)
In Re Barr Laboratories, Inc.
930 F.2d 72 (D.C. Circuit, 1991)
In Re International Chemical Workers Union
958 F.2d 1144 (D.C. Circuit, 1992)
Hettinga v. United States
677 F.3d 471 (D.C. Circuit, 2012)
American Hospital Association v. Sylvia Burwell
812 F.3d 183 (D.C. Circuit, 2016)
Skalka v. Johnson
246 F. Supp. 3d 147 (District of Columbia, 2017)
Caroline Herron v. Fannie Mae
861 F.3d 160 (D.C. Circuit, 2017)
American Anti-Vivisection Society v. AGRI
946 F.3d 615 (D.C. Circuit, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
Sidhu v. Emmel, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sidhu-v-emmel-dcd-2024.