Vaz v. McHenry

CourtDistrict Court, D. Nevada
DecidedMarch 26, 2021
Docket2:20-cv-00316
StatusUnknown

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

Bluebook
Vaz v. McHenry, (D. Nev. 2021).

Opinion

1 2 UNITED STATES DISTRICT COURT 3 DISTRICT OF NEVADA 4 * * *

5 PRYMAS NAZRETH VAZ, Case No. 2:20-CV-00316-KJD-NJK

6 Plaintiff, ORDER

7 v.

8 JAMES MCHENRY, in his official capacity, Director of Executive Office for Immigration 9 Review, et al.,

10 Defendants.

11 12 Presently before the Court is Defendants’ Motion to Dismiss Writ of Mandamus (#14). 13 Plaintiff filed a response in opposition (#15) to which Defendants replied (#16). 14 I. Background 15 Plaintiff filed a complaint with the Executive Office for Immigration Review (“EOIR”) 16 on May 3, 2018, which alleged egregious misconduct on the part of Plaintiff’s previous attorney. 17 The EOIR maintains an Attorney Discipline Program to protect the general public and promote 18 the integrity of the immigration court system. As part of this program, EOIR investigates 19 misconduct complaints filed against immigration practitioners and representatives. 20 Upon receipt of Plaintiff’s complaint, and consistent with EOIR practice, an EOIR 21 investigator reviewed Plaintiff’s complaint. The investigator found that the complaint warranted 22 further review so that the attorney could be apprised of the allegations and be provided an 23 opportunity to address the allegations. The EOIR concluded that the complaint did not merit a 24 priority designation, meaning that the complaint would be addressed in the order it was received 25 and as resources permitted. 26 The Attorney Discipline Program headed by EOIR’s Disciplinary Counsel has 2 27 attorneys and 1 investigator to process and address the hundreds of complaints of misconduct 28 received each year. In 2018, EOIR received approximately 579 complaints of practitioner 1 misconduct; in 2019, EOIR received approximately 684 complaints; and as of the end of March, 2 2020, EOIR had already received approximately 417 complaints. Plaintiff feels that resolution of 3 his complaint, in his favor, is essential to immigration relief that he is pursuing in the Ninth 4 Circuit Court of Appeals. 5 II. Standard of Review 6 Defendants move to dismiss for lack of subject-matter jurisdiction pursuant to Federal 7 Rule of Civil Procedure (“Rule) 12(b)(1) and failure to state a claim under Rule 12(b)(6). There 8 are two types of attacks on subject-matter jurisdiction: facial and factual. Renck v. Novak, 2020 9 WL 2563834, at *1 (D. Nev. May 20, 2020) (citing Safe Air for Everyone v. Meyer, 373 F.3d 10 1035, 1039 (9th Cir. 2004)). “‘In a facial attack, the challenger asserts that the allegations 11 contained in a complaint are insufficient on their face to invoke federal jurisdiction. By contrast, 12 in a factual attack, the challenger disputes the truth of the allegations that, by themselves, would 13 otherwise invoke federal jurisdiction.’ If the moving party converts ‘the motion to dismiss into a 14 factual motion by presenting affidavits or other evidence properly brought before the court, the 15 party opposing the motion must furnish affidavits or other evidence necessary to satisfy its 16 burden of establishing subject matter jurisdiction.’” Wolfe v. Strankman, 392 F.3d 358, 362 (9th 17 Cir. 2004). 18 To survive a motion to dismiss for failure to state a claim under Rule 12(b)(6), “a 19 complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is 20 plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (internal quotation marks 21 omitted). 22 III. Analysis 23 A. Subject Matter Jurisdiction 24 The Mandamus Act, 28 U.S.C. § 1361, provides that “[t]he district courts shall have 25 original jurisdiction of any action in the nature of mandamus to compel an officer or employee of 26 the United States or any agency thereof to perform a duty owed to the plaintiff.” 28 U.S.C. § 27 1361. Mandamus is a drastic remedy to be invoked only in extraordinary situations. Bauman v. 28 - 2 - 1 U.S. Dist. Court, 557 F.2d 650, 654 (9th Cir. 1977). “Mandamus writs, as extraordinary 2 remedies, are appropriate only when a federal officer, employee, or agency owes a 3 nondiscretionary duty to the plaintiff that is so plainly prescribed as to be free from doubt.” 4 Macheret v. Chertoff, 2008 WL 763230, at *1 (D. Nev. Mar. 19, 2008) (citing Stang v. IRS, 788 5 F.2d 564, 565 (9th Cir. 1986)). “Whether each element of the three-part mandamus test is 6 satisfied is a question of law.” See, e.g., Ticheva v. Ashcroft, 241 F. Supp. 2d 1115, 1117 (D. 7 Nev. 2002). However, even if all elements are satisfied, the trial court retains discretion as to 8 whether to order mandamus relief. Indep. Mining Co. v. Babbitt, 105 F.3d 502, 505 (9th Cir. 9 1997). 10 “[M]andamus cannot be used to compel or control a duty which by law is given 11 discretion.” See Macheret, 2008 WL 763230, at *1 (citation omitted); see also Lowry v. 12 Commissioner, Social Security Admin., 231 F. Supp. 2d 981, 984 (D. Or. 2001) (mandamus may 13 not be used to instruct an official how to exercise discretion), aff’d, 50 Fed. App’x. 856 (9th Cir. 14 2002); see also, Ryon v. O’Neill, 894 F.2d 199, 205 (6th Cir.1990) (“For there to be a ‘duty 15 owed to the plaintiff’ within the meaning of section 1361, there must be a ‘mandatory or 16 ministerial obligation. If the alleged duty is discretionary or directory, the duty is not ‘owed.’”). 17 Similarly, the Administrative Procedures Act (“APA”), 5 U.S.C. § 706, authorizes an 18 action to compel an agency to take a discrete agency action that it is required to take, see Norton 19 v. So. Utah Wilderness Alliance, 542 U.S. 55, 64 (2004). However, the APA does not provide an 20 independent basis for federal jurisdiction. Califano v. Sanders, 430 U.S. 99, 107 (1977)). To 21 invoke jurisdiction under the APA, a plaintiff must demonstrate that (1) the agency has a non- 22 discretionary duty to act, and (2) the agency unreasonably delayed in acting on that duty. Norton, 23 542 U.S.at 63-65. Unreasonable delay “cannot be decided in the abstract, by reference to some 24 number of months or years beyond which agency inaction is presumed to be unlawful but will 25 depend in large part ... upon the complexity of the task at hand, the significance (and 26 permanence) of the outcome, and the resources available to the agency.” Mashpee Wampanoag 27 Tribal Council, Inc. v. Norton, 336 F.3d 1094, 1102 (D.C. Cir. 2003).

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Related

Califano v. Sanders
430 U.S. 99 (Supreme Court, 1977)
Norton v. Southern Utah Wilderness Alliance
542 U.S. 55 (Supreme Court, 2004)
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)
Smith v. Reagan
841 F.2d 28 (Second Circuit, 1988)
In Re Barr Laboratories, Inc.
930 F.2d 72 (D.C. Circuit, 1991)
Lowry v. Commissioner, Social Security Administration
231 F. Supp. 2d 981 (D. Oregon, 2001)
Ticheva v. Ashcroft
241 F. Supp. 2d 1115 (D. Nevada, 2002)
American Hospital Association v. Sylvia Burwell
812 F.3d 183 (D.C. Circuit, 2016)
Hawkins v. Borthwick
5 F.2d 564 (Sixth Circuit, 1925)
Wolfe v. Strankman
392 F.3d 358 (Ninth Circuit, 2004)

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Vaz v. McHenry, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vaz-v-mchenry-nvd-2021.