Vega Ayala v. Mayorkas

CourtDistrict Court, D. New Mexico
DecidedMay 6, 2025
Docket1:24-cv-00816
StatusUnknown

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

Bluebook
Vega Ayala v. Mayorkas, (D.N.M. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

MARIA CRISTINA VEGA AYALA, et al.,

Plaintiffs,

v. No. 1:24-cv-00816-MIS-JHR

KRISTI NOEM1, United States Secretary of Homeland Security, et al.,

Defendants.

ORDER DENYING MOTION TO DISMISS

THIS MATTER is before the Court on Defendants’ Motion to Dismiss, ECF No. 7, filed October 15, 2024. Plaintiffs filed a response, ECF No. 19, to which Defendants replied, ECF No. 20. Upon due consideration of the parties’ submissions, the record, and the relevant law the Court will DENY Defendants’ Motion to Dismiss. I. BACKGROUND This case concerns United States Citizenship and Immigration Services (USCIS)’s adjudication (or, more accurately, lack thereof) of U visa petitions. Plaintiffs are nineteen2 noncitizens who have filed petitions for nonimmigrant status under 8 U.S.C. § 1101(a)(15)(U). Such “U” visas are available for noncitizens who are the victim of certain qualifying crimes, have suffered “substantial physical or mental abuse” as a result thereof, and have been helpful in the investigation and/or prosecution of that crime. Id. A noncitizen granted U visa nonimmigrant status

1 Per Federal Rule of Civil Procedure 25, Kristi Noem is automatically substituted as United States Secretary of Homeland Security. 2 This case began with thirty-two plaintiffs. See Compl. (Aug. 14, 2024), ECF No. 1. Since the complaint was initially filed a number of plaintiffs have had their applications adjudicated, and their claims mooted, and have accordingly been dismissed from the case. See Order Granting Pls.’ Unopposed Mot. Dismiss Parties (Feb. 13, 2025), ECF No. 23; Order Granting Pls.’ Second Unopposed Mot. Dismiss Parties (Mar. 17, 2025), ECF No. 27. will be provided with employment authorization documents (“EADs”) pursuant to statute. Id. § 1184(p)(3)(B); see also 8 C.F.R. § 214.14(c)(7). The U visa application process is managed by USCIS, an agency within the Department of Homeland Security (DHS). Congress has placed a cap on U visas of 10,000 annually, id. § 1184(p)(2), and demand far exceeds supply, see Compl. ¶ 51. Accordingly, DHS created a waiting list via implementing

regulations. 8 C.F.R. § 214.14(d)(2). The regulation provides that “[a]ll eligible petitioners who, due solely to the cap, are not granted U-1 nonimmigrant status must be placed on a waiting list and receive written notice of such placement.” Id. (emphasis added). While a petitioner is on the waiting list, “USCIS will grant deferred action or parole” to such petitioner and “in its discretion, may authorize employment” for such petitioner. Id. (emphasis added). A petitioner also will not accrue unlawful presence while on the waiting list, but can be removed therefrom at the discretion of USCIS. Id. § 214.14(d)(3). For many years, the waiting list until final adjudication was the only process available for U visa petitioners. Separately, under the statute, DHS “may grant work authorization to any alien who has a

pending, bona fide application for nonimmigrant status under section 1101(a)(15)(U)[.]” 8 U.S.C. § 1184(p)(6). DHS did not implement a regime to grant work authorization under this provision until 2021. On June 14, 2021, DHS published policy guidance detailing how bona fide determinations under 8 U.S.C. § 1184(p)(6) would be made. U.S. Citizenship & Immigr. Servs., Policy Alert: Bona Fide Determination Process for Victims of Qualifying Crimes, and Employment Authorization and Deferred Action for Certain Petitioners (June 14, 2021). According to the guidance, published as part of the USCIS Policy Manual, USCIS now “first determines whether a pending petition is bona fide.” See U.S. Citizenship & Immigr. Servs., Policy Manual, Volume 3, Part C, Chapter 5 – Bona Fide Determination Process, https://www.uscis.gov/policy-manual/volume-3-part-c-chapter-5 [hereinafter USCIS Policy Manual Ch. 5]. This action is hereafter referred to as the Bona Fide Determination (“BFD”). “Second, USCIS, in its discretion, determines whether the petitioner poses a risk to national security or public safety, and otherwise merits a favorable exercise of discretion.” Id. If USCIS makes a favorable determination at this second step, then it will grant the petitioner an EAD and

deferred action. Id. Together, these two actions are the “BFD process.” The guidance describes the BFD process as an initial step in the U visa procedure; generally, only if a petitioner is not granted a BFD EAD will they then be considered for placement on the waiting list (“waiting list determination” or “WLD”). See id. (“USCIS generally does not conduct waiting list adjudications for noncitizens who USCIS grants BFD EADs and deferred action to; these petitioners’ next adjudicative step is final adjudication when space is available under the statutory cap.”). Plaintiffs filed the instant action on August 14, 2024. All plaintiffs are principal or derivative3 U visa petitioners who have been waiting between 17 and 78 months (as of this filing) for action on their applications and have yet to receive BFDs or WLDs.4 Their Complaint asserts

three causes of action. Count One seeks a declaratory judgment that “Defendants’ lack of action is against the law and violates the [Administrative Procedure Act (APA)].” Id. ¶¶ 89-91. Count Two (the “APA Claims”) alleges violation of 5 U.S.C. § 706(1) by Defendants’ inaction in performing its “nondiscretionary obligation[s]” to determine U visa petitioners’ eligibility, to determine if U visa petitions are bona fide, to adjudicate applications for EADs, and to make these determinations within a reasonable time, and in “Defendants’ failure to make waiting list eligibility determinations for Plaintiffs who would receive U nonimmigrant status but for the statutory cap.” Compl. ¶¶ 92-

3 Principal U visa petitioners may file derivative petitions on behalf of certain qualifying family members. 8 C.F.R. § 214.14(f)(1). 4 These numbers are based on the remaining nineteen plaintiffs. See Compl. ¶¶ 64-65, 68, 71, 73-74, 77-78, 80-83. 99. Plaintiffs further allege that Defendants’ inaction is arbitrary, capricious, and in excess of statutory authority. Id. ¶ 100 (citing 5 U.S.C. § 706(c)(2)). Count Three seeks a writ of mandamus under 28 U.S.C. § 1361 to compel DHS to perform its duties owed to Plaintiffs, namely, adjudication of their petitions for U visas and placement on the waitlist or issuance of a BFD, and grant of associated EADs and deferred action. Id. ¶¶ 101-110.

All Defendants moved to dismiss on October 15, 2024. Mot. Dismiss (“Mot.”), ECF No. 7. Plaintiffs responded on November 27, 2024, Pls.’ Resp. Opp’n Defs.’ Mot. Dismiss (“Resp.”), ECF No. 19. Defendants replied on December 13, 2024. Defs.’ Reply Supp. Mot. Dismiss (“Reply”), ECF No. 20. II.

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