Zhang v. United States Citizenship and Immigration Services

CourtDistrict Court, District of Columbia
DecidedSeptember 29, 2025
DocketCivil Action No. 2015-0995
StatusPublished

This text of Zhang v. United States Citizenship and Immigration Services (Zhang v. United States Citizenship and Immigration Services) 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.

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Zhang v. United States Citizenship and Immigration Services, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

HUASHAN ZHANG, et al.,

Plaintiffs,

v. No. 15-995 (EGS) UNITED STATES CITIZENSHIP AND IMMIGRATION SERVICES, et al.,

Defendants.

MEMORANDUM OPINION

After prevailing in their lawsuit challenging a decision by

Defendants United States Citizenship and Immigration Services’

(“USCIS”), Kristi Noem, in her official capacity as Secretary of

the U.S. Department of Homeland Security; Kika Scott, in her

official capacity as Director of USCIS; and Alissa Emmel, in her

official capacity as Chief of the Immigrant Investor Program as

USCIS (collectively, “Defendants” or “the government”) 1 related

to investor visa applications, named class Plaintiffs, Huashan

Zhang (“Mr. Zhang”) and Mayasuki Hagiwara’s (“Mr. Hagiwara”)

(collectively, “Plaintiffs”), sought attorneys’ fees and

expenses pursuant to the Equal Access to Justice Act (“EAJA”).

See Pls.’ Mot. for Attorneys’ Fees & Expenses Under the Equal

1 Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, the current government officials are substituted as Defendant for their predecessors. See Fed. R. Civ. P. 25(d). 1 Access to Justice Act (“Mot.”), ECF No. 51 2; see Huashan Zhang

v. U.S. Citizenship & Immigr. Servs., 344 F. Supp. 3d 32, 41-42

(D.D.C. 2018), aff’d, 978 F.3d 1314 (D.C. Cir. 2020).

On February 17, 2023, this Court denied in part without

prejudice and held in abeyance in part Plaintiffs’ Motion for

Attorney’s Fees and Expenses Under the EAJA (“Motion”) while the

parties provided supplemental briefing on Plaintiffs’ EAJA

eligibility. See Order, ECF No. 59. The supplemental briefing is

complete and the Motion, as well as the supplements, are now

pending before this Court. Upon careful consideration of the

briefs, the applicable law, and the entire record herein, the

Court hereby GRANTS IN PART Plaintiffs’ Motion and awards

Plaintiffs fees in the amount of $207,702.33 and expenses in the

amount of $19,850.00.

I. Background

A. Underlying Litigation

The Court previously described the background of this case.

See Mem. Op., ECF No. 58. To summarize, Plaintiffs brought this

action on behalf of themselves and a class of people who sought

“EB-5 visas.” See Zhang, 344 F. Supp. 3d at 41-42. The EB-5 visa

program is a system through which immigrants who invest a

2 When citing electronic filings throughout this Opinion, the Court refers to the ECF page numbers, not the page numbers of the filed documents. 2 minimum amount of capital in a new commercial enterprise may

pursue lawful permanent residency in the United States. See

Zhang, 344 F. Supp. 3d at 40 (citing U.S.C. § 1153(b)(5)(A)).

Prior to 2015, USCIS had defined capital to include lawfully

acquired cash and indebtedness. See id. at 41; 8 C.F.R. §

204.6(e). But in 2015, USCIS announced that it would treat loan

proceeds as “indebtedness” instead of “cash” for purposes of EB-

5 visa petitions, unless the loan was secured by personally

owned assets. See Zhang, 344 F. Supp. 3d at 41.

On June 23, 2015, Plaintiffs filed this lawsuit on behalf

of themselves and other similarly situated individuals who were

denied EB-5 visas due to this change in interpretation, seeking

to invalidate USCIS’s loan proceeds rule. See id. at 42–43;

Compl., ECF No. 1. On November 30, 2018, the Court issued a

memorandum opinion and order holding that cash loan proceeds are

unambiguously “cash” under 8 C.F.R. § 204.6(e); that USCIS’s

position contravened the regulation’s plain meaning; and that

USCIS violated the Administrative Procedure Act, 5 U.S.C. § 706,

in issuing the rule without notice and comment. See Zhang, 344

F. Supp. 3d at 46–56. The Court also certified the plaintiff

class pursuant to Federal Rule of Civil Procedure 23(b)(2),

which was the applicable rule for class certification because

“USCIS’ interpretation of its regulation has been or will be

applied generally to the entire class and plaintiffs seek

3 declaratory and injunctive relief that will benefit the class as

a whole.” Id. at 65. Additionally, the Court remanded all EB-5

visa petitions that the agency denied based on its invalid

interpretation of loan proceeds. See id. at 60–66. On October

27, 2020, the U.S. Circuit Court for the District of Columbia

Circuit (“D.C. Circuit”) affirmed the Court’s decision. See

Zhang, 978 F.3d at 1316.

B. Attorneys’ Fees

After the time elapsed for the government to seek

certiorari before the U.S. Supreme Court, Plaintiffs filed this

Motion on April 23, 2021. See Mot. for Attorneys’ Fees, ECF No.

51. In their initial Motion, Plaintiffs provided documentation

and argued that they were entitled to fees for 1,017.85 hours,

under the EAJA, and gave three different calculations: (1)

$429,986.00, applying the regular hourly rates of Plaintiffs’

counsel; (2) $452,411.00, applying the Laffey Matrix hourly

rates; or (3) $198,645.03, applying their calculation of the

relevant statutory hourly rate as adjusted for cost-of-living

increases. See id. at 16-22. Plaintiffs also sought

reimbursement of $3,802.00 in expenses and/or costs. 3 See Ex. B,

ECF No. 51-2.

3 As explained more below, infra Part III.C(2)(b), the parties use both the terms “costs” and “expenses” when referring to the same items. 4 On June 7, 2021, the government filed its brief in

opposition to Plaintiffs’ motion (“Opposition”). See Defs.’

Resp. to Mot. (“Opp’n”), ECF No. 54 at 12–16. Defendants did not

contest that Plaintiffs were the prevailing party, nor assert

that their positions were substantially justified. See id.

Instead, they argued: (1) Mr. Hagiwara, the only Plaintiff

seeking fees, did not meet the statutory net worth requirements

for EAJA relief; (2) Plaintiffs failed to provide notice to

class members pursuant to Federal Rule of Civil Procedure 23(e);

and (3) that if the Court awards relief, Plaintiffs are not

entitled to the full amount requested. See id. Plaintiffs

replied on July 20, 2021. See Pls.’ Reply in Supp. Mot. Atty’s

Fees & Expenses Under Equal Access to Justice Act (“Reply”), ECF

No. 57.

In its February 17, 2023 Memorandum Opinion, the Court

determined that it needed additional information regarding

Plaintiffs’ net worth eligibility before reaching the other

issues in Plaintiffs’ Motion. See Mem. Op., ECF No. 58 at 3, 14.

Specifically, it held that even though a declaration may be

sufficient in some situations, it needed additional information

to substantiate Mr. Hagiwara’s net worth claim given the

government’s arguments that aspects of the Administrative Record

(“AR”) cast doubt on Mr. Hagiwara’s credibility. See id.

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