Abdi v. Flake

U.S. District Court, District of Minnesota

Abdi v. Flake

Trial Court Opinion

            UNITED STATES DISTRICT COURT                             
                DISTRICT OF MINNESOTA                                


Nurudiin Mohamud Abdi,                 Case No. 24-CV-00532 (JMB/JFD)     

          Plaintiff,                                                 

    v.                                                                         ORDER 

Jeffry Flake, U.S. Ambassador to Turkey;                                  
Antony J. Blinken, Secretary;                                             

          Defendants.                                                


Mai Neng Moua, Moua & Swanson PLLC, Minneapolis, MN, for Plaintiff Nurudiin 
Mohamud Abdi.                                                             
Emily M. Peterson, United States Attorney’s Office, Minneapolis, MN, for Defendants 
Jeffry Flake and Antony J. Blinken.                                       


This  matter  is  before  the  Court  on  Defendants  Jeffry  Flake’s  and  Antony  J. 
Blinken’s (together, the Defendants) motion to dismiss this mandamus action against them 
brought under the Administrative Procedure Act (APA) by Plaintiff Nurudiin Mohamud 
Abdi.  (Doc. No. 5.)  For the reasons explained below, the Court will grant Defendants’ 
motion and will dismiss this action.                                      
                     BACKGROUND                                      
Abdi is a U.S. citizen.  (Doc. No. 1 [hereinafter, “Compl.”] ¶¶ 4, 10.)  Abdi’s wife, 
Faiza Abdirahman Mohamed Dadle, is a citizen of Somalia.  (Id. ¶ 10, Ex. 2 at 1.)  On 
January 17, 2022, Abdi filed a Form I-130 with United States Citizenship and Immigration 
Services (USCIS) on behalf of Dadle, so that she may come to the United States.  (Compl. 
¶ 12, Ex. 1.)  USCIS approved it on May 2, 2023.  (Id.)  On May 24, Abdi and Dadle 
submitted a Form DS-260 Immigrant Visa Application (Application) to USCIS.1  (Id. 

¶ 13.)                                                                    
Approximately six weeks later, on July 7, the NVC confirmed to Abdi that it had 
“received all of the fees, forms, and documents that are required prior to scheduling your 
immigrant visa interview,” and that it would work with the embassy in Ankara, Türkiye to 
schedule Dadle’s consular interview on her Application.  (Id. ¶ 14, Ex. 3.)  According to 
the Department of State’s Foreign Affairs Manual (FAM), the NVC schedules consular 

interview appointments in the order that documentarily complete applications are received.  
9 FAM 504.4-6(a).2  Since that time, approximately fifteen months have elapsed and Dadle 
had not been scheduled for an interview.  (Id. ¶ 15.)                     


1 To obtain such a visa, a U.S. citizen must submit a Form I-130 to USCIS on behalf of 
their foreign relative.  See 
8 U.S.C. § 1154
; 
8 C.F.R. § 204.1
(a)(1).  Upon approval by 
USCIS, the petition is forwarded to the Department of State’s National Visa Center (NVC).  
8 U.S.C. § 1154
(b).  After that, the foreign relative must submit a Form DS-260 and certain 
required  supporting  documents  to  the  NVC.    
22 C.F.R. §§ 42.63
(a),  42.65.    Upon 
determination by the NVC that the Form DS-260 is complete, it will schedule a consular 
interview with the foreign relative at the appropriate embassy.  
Id.
 §§ 42.61(a), 42.62(a). 

2 The FAM is “a single, comprehensive, and authoritative source for the Department’s 
organization structures, policies, and procedures that govern the operations of the State 
Department, the Foreign Service, and, when applicable, other federal agencies.”  Foreign 
Affairs  Manual  -  U.S.  Department  of  State,  Library  of  Congress,  available  at 
https://www.loc.gov/item/lcwaN0026575/#:~:text=%22The%20Foreign%20Affairs%20
Manual%20(FAM,when%20applicable%2C%20other%20federal%20agencies           
[https://perma.cc/FDF6-4WJX] (last visited May 31, 2024).  The FAM “convey[s] codified 
information to Department staff and contractors so they can carry out their responsibilities 
in  accordance  with  statutory,  executive  and Department  mandates.”    Id.   The  Court 
properly takes judicial notice of government websites.  See, e.g., Missourians for Fiscal 
Accountability v. Klahr, 
830 F.3d 789, 793
 (8th Cir. 2016).               
The  Complaint  alleges  that  the  embassy  in  Türkiye  has  “unlawfully  and 
unreasonably  withh[eld]  agency  action”  on  Dadle’s  Application  in  violation  of  the 

Administrative Procedure Act (APA) and requests that the Court to use its mandamus 
powers to compel such action.3  (See Doc No. 1.)  Defendants now move to dismiss the 
Complaint in its entirety.4  (Doc. No. 6.)                                
                      DISCUSSION                                     
Because  the  Complaint  does  not  include  sufficient  facts  to  raise  a  reasonable 
inference that the embassy unreasonably withheld action on the Application, the Court 

grants Defendants’ motion.                                                
On a motion to dismiss brought under Federal Rule of Civil Procedure 12(b)(6), 
courts consider all facts alleged in the complaint to be true and then determine whether the 
complaint states a “claim to relief that is plausible on its face.”  Braden v. Wal-Mart Stores, 
Inc., 
588 F.3d 585, 594
 (8th Cir. 2009) (quoting Ashcroft v. Iqbal, 
556 U.S. 662
, 678 


3 Although the Complaint includes two causes of action (a violation of the APA and a 
request  for  mandamus),  in  immigration-delay  cases,  APA  and mandamus  claims are 
considered together.  E.g., Ali v. Frazier, 
575 F. Supp. 2d 1084, 1090
 (D. Minn. 2008) 
(“[I]n immigration-delay cases . . . , the duty to be enforced by way of mandamus is a duty 
of timeliness established by the APA, [thus] there is little reason to consider mandamus 
claims separately from claims under the APA.”).                           

4 In his written submission opposing Defendants’ motion, Abdi makes additional factual 
allegations that do not appear in the Complaint, including that Abdi’s oldest child wishes 
to attend school in the United States, that NVC informed Abdi in February 2024 that 
interviews were being scheduled at the embassy in Türkiye, and that the embassy in 
Türkiye has worked through the backlog caused by the COVID-19 pandemic.  (Doc. No. 
10 at 4–5.)  The Court cannot consider these allegations because, “it is axiomatic that a 
complaint may not be amended by the briefs in opposition to a motion to dismiss.”  Morgan 
Distrib. Co. v. Unidynamic Corp., 
868 F.2d 992, 995
 (8th Cir. 1989).      
(2009)).  A pleading has facial plausibility when its factual allegations “allow[] the court 
to draw the reasonable inference that the defendant is liable for the misconduct alleged.”  

Iqbal, 
556 U.S. at 678
.  In this analysis, the Court construes the allegations and draws 
inferences from them in the light most favorable to the plaintiff.  Park Irmat Drug Corp. 
v. Express Scripts Holding Co., 
911 F.3d 505, 512
 (8th Cir. 2018).  However, the Court 
will not give the plaintiff the benefit of unreasonable inferences, Brown v. Medtronic, Inc., 
628 F.3d 451, 461
 (8th Cir. 2010), and is “not bound to accept as true a legal conclusion 
couched as a factual allegation.”  Papasan v. Allain, 
478 U.S. 265, 286
 (1986). 

The APA compels agencies, “[w]ith due regard for the convenience and necessity 
of the parties or their representatives and within a reasonable time, . . . [to] proceed to 
conclude a matter presented to it.”  
5 U.S.C. § 555
(b).  The APA also provides that this 
Court “shall . . . compel agency action unlawfully withheld or unreasonably delayed.”   
5 U.S.C. § 706
(1).  However, the Court may compel agencies to take only those “discrete 

agency action[s] that it is required to take.”  Norton v. S. Utah Wilderness All., 
542 U.S. 55, 64
 (2004).                                                            
To determine whether an agency’s delay violates the APA, courts consider six 
factors  set  forth  in  Telecommunications  Research  and  Action  Center  v.  Federal 
Communications Commission, et al., 
750 F.2d 70
 (D.C. Cir. 1984) (TRAC):   

     (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;  
     (4) the court should consider the effect of expediting delayed  
     action on agency activities of a higher or competing priority;  
     (5) the court should also take into account the nature and extent 
     of the interests prejudiced by delay; and (6) the court need not 
     find any impropriety lurking behind agency lassitude in order   
     to hold that agency action is unreasonably delayed.             
TRAC, 750 F.2d at 80 (citations omitted); see also, e.g., Da Costa v. Immigr. Inv. Program 
Off., 
80 F.4th 330
, 338–40 (D.C. Cir. 2023) (affirming dismissal under Rule 12(b)(6) of 
lawsuits alleging decision on visa-related petitions had not been issued after approximately 
four years); Infracost Inc. v. Blinken, __ F.3d __, __, 
2024 WL 1914368
, at *7 (S.D. Cal. 
Apr. 30, 2024) (analyzing TRAC factors on motion to dismiss plaintiff’s immigration-delay 
claim under APA); Arab v. Blinken, 
600 F. Supp. 3d 59
, 69 (D.D.C. Apr. 21, 2022); Jaraba 
v. Blinken, 
568 F. Supp. 3d 720
, 733–42 (W.D. Tex. 2021) (applying TRAC factors to 
analyze sufficiency of allegations in complaint in motion to dismiss).  Abdi argues that his 
allegations  in  the  Complaint  satisfy  the  TRAC  factors,  but  the  Court  disagrees  and 
concludes that the allegations in the Complaint do not sufficiently allege facts to establish 
either TRAC factor one or four.                                           
As noted above, TRAC factor one requires the Court to consider whether the timing 

of the agency’s decision is governed by a “rule of reason.”  TRAC, 750 F.2d at 80.  The 
Court is persuaded by the analysis in many orders from other courts underlying their 
conclusion that an agency’s decision to process applications in the order received, known 
as a “first-in, first-out rule,” constitutes a rule of reason.  E.g., Da Costa, 80 F.4th at 340–
41 (concluding that USCIS’s decision to process and issue visas in the order that the visa 

petitions are filed constitutes a “rule of reason”); see also, e.g., Hassan v. Bitter, No. 8:24-
CV-0145, 
2024 WL 4113835
, at *21 (D. Neb. Sept. 9, 2024) (concluding that USCIS’s 
“system of adjudication” of Form I-130 applications and NVC’s system of filling “these 

appointments in a first-in, first-out manner . . . qualifies as a ‘rule of reason’ under the first 
TRAC factor”) (quotation omitted); Telukunta v. Mayorkas, No. 21-CV-10372, 
2021 WL 2434128
,  *2  (E.D.  Mich.  June  15,  2021)  (concluding  that  USCIS’s  review  of  visa 
applications based on a “‘first-in, first-out’ system . . . constitutes a ‘rule of reason’”); Ray 
v. Cuccinelli, No. 20-CV-06279, 
2020 WL 6462398
, at *9 (N.D. Cal. Nov. 3, 2020) 
(concluding  that  USCIS’s  adjudication  procedure  for  adjudication  of  certain  renewal 

applications “in the order they were filed . . . satisfied the first TRAC factor”); Muvvala v. 
Wolf, No. 20-CV-02423, 
2020 WL 5748104
, at *3 (D.D.C. Sept. 25, 2020) (same).   
Given these cases, and because Abdi did not direct this Court to any contrary 
authority, USCIS’s decision to process applications and interviews in the order received 
complies with a rule of reason.  The Complaint makes no allegation that Defendants have 

not processed applications in a manner consistent with the FAM.5  9 FAM 504.4-6(a).  


5 To the extent that portions of Abdi’s written submissions can be construed as an argument 
that the NVC website establishes a definitive time period by which they will schedule 
appointments (Doc. No. 10), the Court remains unconvinced for two reasons.  First, such 
facts are not included in the Complaint.  See Morgan Distrib. Co., 
868 F.2d at 995
.  Second, 
such an argument mischaracterizes the NVC website, which explicitly states that it “strives 
to schedule appointments within three months,” but “this timeframe is subject to the 
operating  status  and  capacity  of  the  consular  section”  and  “most  consular  posts  are 
operating  at  a  limited  capacity  as  they  work  through  a  backlog  of  immigrant  visa 
applications and scheduling may take significantly longer.”  Appointment, U.S. Dep’t of 
State—Bureau     of      Consulate    Affairs,    available    at         
https://travel.state.gov/content/travel/en/us-visas/immigrate/the-immigrant-visa-
process/step-10-prepare-for-the-interview/appointment.html#int1           
[https://perma.cc/DV3F-XFM8] (last visited July 25, 2024).                
Absent any allegation that NVC has deviated from this rule of reason, the Court concludes 
the Complaint has not alleged “enough fact[s] to raise a reasonable expectation that 

discovery will reveal evidence of [the claim].”  Twombly, 550 U.S. at 556. 
TRAC factor four requires the Court to consider the effect of expediting delayed 
action.  Again, the analysis of the Da Costa court is persuasive.  Absent allegations that 
the  agency  was  not  processing  applications  in  the  order  they  were  received,  the 
consequence of prioritizing Dadle’s application would be to permit “line-jumping” and 
thereby prejudice others who were also awaiting adjudication.  See Da Costa, 80 F.4th at 

343–44 (“Granting this individual relief would necessarily come at the expense of other 
similarly  situated  applicants,  unlike  broader  relief  that  would  avoid  line-jumping 
concerns”) (quotations omitted).  Abdi concedes as much and acknowledges that he “does 
not have a right to skip ahead of other petitions who filed an application before [Dadle].”  
(Doc. No. 10 at 5.)  However, he asserts that, through his lawsuit, he does not seek for 

Dadle to skip ahead of others because her application is and has been ripe for review.  
Specifically, in his opposition brief (not in his Complaint), Abdi states that someone at the 
NVC told him via phone that Dadle’s application was already reviewed and was ripe for a 
consular interview.  (Id.)  As previously noted, however, the Court cannot consider such 
representations of fact outside of the pleadings on a motion under Rule 12(b)(6).  Morgan 

Distrib. Co., 
868 F.2d at 995
.  Because the Abdi alleges nothing more than that “seven (7) 
months have passed since all required documents and filing fees were submitted, [and] 
Plaintiff’s  spouse  has  not  been  scheduled  for  an  interview  yet”  (Compl.  ¶ 15),  the 
Complaint reads as a request for “line-jumping” over others, and is, therefore, insufficient 
to survive Defendants’ motion.                                            

ORDER

Based on the foregoing, and on all of the files, records, and proceedings herein, IT 
IS HEREBY ORDERED THAT:                                                   
1.   Defendants Jeffry Flake’s and Antony J. Blinken’s Motion to Dismiss (Doc. 
     No. 5) is GRANTED; and                                          
2.   Plaintiff Nurudiin Mohamud Abdi’s Complaint (Doc. No. 1) is dismissed in 
     its entirety, without prejudice.                                
LET JUDGMENT BE ENTERED ACCORDINGLY.                                 

Dated:  October 2, 2024                 /s/ Jeffrey M. Bryan              
                                   Judge Jeffrey M. Bryan            
                                   United States District Court      

Trial Court Opinion

            UNITED STATES DISTRICT COURT                             
                DISTRICT OF MINNESOTA                                


Nurudiin Mohamud Abdi,                 Case No. 24-CV-00532 (JMB/JFD)     

          Plaintiff,                                                 

    v.                                                                         ORDER 

Jeffry Flake, U.S. Ambassador to Turkey;                                  
Antony J. Blinken, Secretary;                                             

          Defendants.                                                


Mai Neng Moua, Moua & Swanson PLLC, Minneapolis, MN, for Plaintiff Nurudiin 
Mohamud Abdi.                                                             
Emily M. Peterson, United States Attorney’s Office, Minneapolis, MN, for Defendants 
Jeffry Flake and Antony J. Blinken.                                       


This  matter  is  before  the  Court  on  Defendants  Jeffry  Flake’s  and  Antony  J. 
Blinken’s (together, the Defendants) motion to dismiss this mandamus action against them 
brought under the Administrative Procedure Act (APA) by Plaintiff Nurudiin Mohamud 
Abdi.  (Doc. No. 5.)  For the reasons explained below, the Court will grant Defendants’ 
motion and will dismiss this action.                                      
                     BACKGROUND                                      
Abdi is a U.S. citizen.  (Doc. No. 1 [hereinafter, “Compl.”] ¶¶ 4, 10.)  Abdi’s wife, 
Faiza Abdirahman Mohamed Dadle, is a citizen of Somalia.  (Id. ¶ 10, Ex. 2 at 1.)  On 
January 17, 2022, Abdi filed a Form I-130 with United States Citizenship and Immigration 
Services (USCIS) on behalf of Dadle, so that she may come to the United States.  (Compl. 
¶ 12, Ex. 1.)  USCIS approved it on May 2, 2023.  (Id.)  On May 24, Abdi and Dadle 
submitted a Form DS-260 Immigrant Visa Application (Application) to USCIS.1  (Id. 

¶ 13.)                                                                    
Approximately six weeks later, on July 7, the NVC confirmed to Abdi that it had 
“received all of the fees, forms, and documents that are required prior to scheduling your 
immigrant visa interview,” and that it would work with the embassy in Ankara, Türkiye to 
schedule Dadle’s consular interview on her Application.  (Id. ¶ 14, Ex. 3.)  According to 
the Department of State’s Foreign Affairs Manual (FAM), the NVC schedules consular 

interview appointments in the order that documentarily complete applications are received.  
9 FAM 504.4-6(a).2  Since that time, approximately fifteen months have elapsed and Dadle 
had not been scheduled for an interview.  (Id. ¶ 15.)                     


1 To obtain such a visa, a U.S. citizen must submit a Form I-130 to USCIS on behalf of 
their foreign relative.  See 
8 U.S.C. § 1154
; 
8 C.F.R. § 204.1
(a)(1).  Upon approval by 
USCIS, the petition is forwarded to the Department of State’s National Visa Center (NVC).  
8 U.S.C. § 1154
(b).  After that, the foreign relative must submit a Form DS-260 and certain 
required  supporting  documents  to  the  NVC.    
22 C.F.R. §§ 42.63
(a),  42.65.    Upon 
determination by the NVC that the Form DS-260 is complete, it will schedule a consular 
interview with the foreign relative at the appropriate embassy.  
Id.
 §§ 42.61(a), 42.62(a). 

2 The FAM is “a single, comprehensive, and authoritative source for the Department’s 
organization structures, policies, and procedures that govern the operations of the State 
Department, the Foreign Service, and, when applicable, other federal agencies.”  Foreign 
Affairs  Manual  -  U.S.  Department  of  State,  Library  of  Congress,  available  at 
https://www.loc.gov/item/lcwaN0026575/#:~:text=%22The%20Foreign%20Affairs%20
Manual%20(FAM,when%20applicable%2C%20other%20federal%20agencies           
[https://perma.cc/FDF6-4WJX] (last visited May 31, 2024).  The FAM “convey[s] codified 
information to Department staff and contractors so they can carry out their responsibilities 
in  accordance  with  statutory,  executive  and Department  mandates.”    Id.   The  Court 
properly takes judicial notice of government websites.  See, e.g., Missourians for Fiscal 
Accountability v. Klahr, 
830 F.3d 789, 793
 (8th Cir. 2016).               
The  Complaint  alleges  that  the  embassy  in  Türkiye  has  “unlawfully  and 
unreasonably  withh[eld]  agency  action”  on  Dadle’s  Application  in  violation  of  the 

Administrative Procedure Act (APA) and requests that the Court to use its mandamus 
powers to compel such action.3  (See Doc No. 1.)  Defendants now move to dismiss the 
Complaint in its entirety.4  (Doc. No. 6.)                                
                      DISCUSSION                                     
Because  the  Complaint  does  not  include  sufficient  facts  to  raise  a  reasonable 
inference that the embassy unreasonably withheld action on the Application, the Court 

grants Defendants’ motion.                                                
On a motion to dismiss brought under Federal Rule of Civil Procedure 12(b)(6), 
courts consider all facts alleged in the complaint to be true and then determine whether the 
complaint states a “claim to relief that is plausible on its face.”  Braden v. Wal-Mart Stores, 
Inc., 
588 F.3d 585, 594
 (8th Cir. 2009) (quoting Ashcroft v. Iqbal, 
556 U.S. 662
, 678 


3 Although the Complaint includes two causes of action (a violation of the APA and a 
request  for  mandamus),  in  immigration-delay  cases,  APA  and mandamus  claims are 
considered together.  E.g., Ali v. Frazier, 
575 F. Supp. 2d 1084, 1090
 (D. Minn. 2008) 
(“[I]n immigration-delay cases . . . , the duty to be enforced by way of mandamus is a duty 
of timeliness established by the APA, [thus] there is little reason to consider mandamus 
claims separately from claims under the APA.”).                           

4 In his written submission opposing Defendants’ motion, Abdi makes additional factual 
allegations that do not appear in the Complaint, including that Abdi’s oldest child wishes 
to attend school in the United States, that NVC informed Abdi in February 2024 that 
interviews were being scheduled at the embassy in Türkiye, and that the embassy in 
Türkiye has worked through the backlog caused by the COVID-19 pandemic.  (Doc. No. 
10 at 4–5.)  The Court cannot consider these allegations because, “it is axiomatic that a 
complaint may not be amended by the briefs in opposition to a motion to dismiss.”  Morgan 
Distrib. Co. v. Unidynamic Corp., 
868 F.2d 992, 995
 (8th Cir. 1989).      
(2009)).  A pleading has facial plausibility when its factual allegations “allow[] the court 
to draw the reasonable inference that the defendant is liable for the misconduct alleged.”  

Iqbal, 
556 U.S. at 678
.  In this analysis, the Court construes the allegations and draws 
inferences from them in the light most favorable to the plaintiff.  Park Irmat Drug Corp. 
v. Express Scripts Holding Co., 
911 F.3d 505, 512
 (8th Cir. 2018).  However, the Court 
will not give the plaintiff the benefit of unreasonable inferences, Brown v. Medtronic, Inc., 
628 F.3d 451, 461
 (8th Cir. 2010), and is “not bound to accept as true a legal conclusion 
couched as a factual allegation.”  Papasan v. Allain, 
478 U.S. 265, 286
 (1986). 

The APA compels agencies, “[w]ith due regard for the convenience and necessity 
of the parties or their representatives and within a reasonable time, . . . [to] proceed to 
conclude a matter presented to it.”  
5 U.S.C. § 555
(b).  The APA also provides that this 
Court “shall . . . compel agency action unlawfully withheld or unreasonably delayed.”   
5 U.S.C. § 706
(1).  However, the Court may compel agencies to take only those “discrete 

agency action[s] that it is required to take.”  Norton v. S. Utah Wilderness All., 
542 U.S. 55, 64
 (2004).                                                            
To determine whether an agency’s delay violates the APA, courts consider six 
factors  set  forth  in  Telecommunications  Research  and  Action  Center  v.  Federal 
Communications Commission, et al., 
750 F.2d 70
 (D.C. Cir. 1984) (TRAC):   

     (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;  
     (4) the court should consider the effect of expediting delayed  
     action on agency activities of a higher or competing priority;  
     (5) the court should also take into account the nature and extent 
     of the interests prejudiced by delay; and (6) the court need not 
     find any impropriety lurking behind agency lassitude in order   
     to hold that agency action is unreasonably delayed.             
TRAC, 750 F.2d at 80 (citations omitted); see also, e.g., Da Costa v. Immigr. Inv. Program 
Off., 
80 F.4th 330
, 338–40 (D.C. Cir. 2023) (affirming dismissal under Rule 12(b)(6) of 
lawsuits alleging decision on visa-related petitions had not been issued after approximately 
four years); Infracost Inc. v. Blinken, __ F.3d __, __, 
2024 WL 1914368
, at *7 (S.D. Cal. 
Apr. 30, 2024) (analyzing TRAC factors on motion to dismiss plaintiff’s immigration-delay 
claim under APA); Arab v. Blinken, 
600 F. Supp. 3d 59
, 69 (D.D.C. Apr. 21, 2022); Jaraba 
v. Blinken, 
568 F. Supp. 3d 720
, 733–42 (W.D. Tex. 2021) (applying TRAC factors to 
analyze sufficiency of allegations in complaint in motion to dismiss).  Abdi argues that his 
allegations  in  the  Complaint  satisfy  the  TRAC  factors,  but  the  Court  disagrees  and 
concludes that the allegations in the Complaint do not sufficiently allege facts to establish 
either TRAC factor one or four.                                           
As noted above, TRAC factor one requires the Court to consider whether the timing 

of the agency’s decision is governed by a “rule of reason.”  TRAC, 750 F.2d at 80.  The 
Court is persuaded by the analysis in many orders from other courts underlying their 
conclusion that an agency’s decision to process applications in the order received, known 
as a “first-in, first-out rule,” constitutes a rule of reason.  E.g., Da Costa, 80 F.4th at 340–
41 (concluding that USCIS’s decision to process and issue visas in the order that the visa 

petitions are filed constitutes a “rule of reason”); see also, e.g., Hassan v. Bitter, No. 8:24-
CV-0145, 
2024 WL 4113835
, at *21 (D. Neb. Sept. 9, 2024) (concluding that USCIS’s 
“system of adjudication” of Form I-130 applications and NVC’s system of filling “these 

appointments in a first-in, first-out manner . . . qualifies as a ‘rule of reason’ under the first 
TRAC factor”) (quotation omitted); Telukunta v. Mayorkas, No. 21-CV-10372, 
2021 WL 2434128
,  *2  (E.D.  Mich.  June  15,  2021)  (concluding  that  USCIS’s  review  of  visa 
applications based on a “‘first-in, first-out’ system . . . constitutes a ‘rule of reason’”); Ray 
v. Cuccinelli, No. 20-CV-06279, 
2020 WL 6462398
, at *9 (N.D. Cal. Nov. 3, 2020) 
(concluding  that  USCIS’s  adjudication  procedure  for  adjudication  of  certain  renewal 

applications “in the order they were filed . . . satisfied the first TRAC factor”); Muvvala v. 
Wolf, No. 20-CV-02423, 
2020 WL 5748104
, at *3 (D.D.C. Sept. 25, 2020) (same).   
Given these cases, and because Abdi did not direct this Court to any contrary 
authority, USCIS’s decision to process applications and interviews in the order received 
complies with a rule of reason.  The Complaint makes no allegation that Defendants have 

not processed applications in a manner consistent with the FAM.5  9 FAM 504.4-6(a).  


5 To the extent that portions of Abdi’s written submissions can be construed as an argument 
that the NVC website establishes a definitive time period by which they will schedule 
appointments (Doc. No. 10), the Court remains unconvinced for two reasons.  First, such 
facts are not included in the Complaint.  See Morgan Distrib. Co., 
868 F.2d at 995
.  Second, 
such an argument mischaracterizes the NVC website, which explicitly states that it “strives 
to schedule appointments within three months,” but “this timeframe is subject to the 
operating  status  and  capacity  of  the  consular  section”  and  “most  consular  posts  are 
operating  at  a  limited  capacity  as  they  work  through  a  backlog  of  immigrant  visa 
applications and scheduling may take significantly longer.”  Appointment, U.S. Dep’t of 
State—Bureau     of      Consulate    Affairs,    available    at         
https://travel.state.gov/content/travel/en/us-visas/immigrate/the-immigrant-visa-
process/step-10-prepare-for-the-interview/appointment.html#int1           
[https://perma.cc/DV3F-XFM8] (last visited July 25, 2024).                
Absent any allegation that NVC has deviated from this rule of reason, the Court concludes 
the Complaint has not alleged “enough fact[s] to raise a reasonable expectation that 

discovery will reveal evidence of [the claim].”  Twombly, 550 U.S. at 556. 
TRAC factor four requires the Court to consider the effect of expediting delayed 
action.  Again, the analysis of the Da Costa court is persuasive.  Absent allegations that 
the  agency  was  not  processing  applications  in  the  order  they  were  received,  the 
consequence of prioritizing Dadle’s application would be to permit “line-jumping” and 
thereby prejudice others who were also awaiting adjudication.  See Da Costa, 80 F.4th at 

343–44 (“Granting this individual relief would necessarily come at the expense of other 
similarly  situated  applicants,  unlike  broader  relief  that  would  avoid  line-jumping 
concerns”) (quotations omitted).  Abdi concedes as much and acknowledges that he “does 
not have a right to skip ahead of other petitions who filed an application before [Dadle].”  
(Doc. No. 10 at 5.)  However, he asserts that, through his lawsuit, he does not seek for 

Dadle to skip ahead of others because her application is and has been ripe for review.  
Specifically, in his opposition brief (not in his Complaint), Abdi states that someone at the 
NVC told him via phone that Dadle’s application was already reviewed and was ripe for a 
consular interview.  (Id.)  As previously noted, however, the Court cannot consider such 
representations of fact outside of the pleadings on a motion under Rule 12(b)(6).  Morgan 

Distrib. Co., 
868 F.2d at 995
.  Because the Abdi alleges nothing more than that “seven (7) 
months have passed since all required documents and filing fees were submitted, [and] 
Plaintiff’s  spouse  has  not  been  scheduled  for  an  interview  yet”  (Compl.  ¶ 15),  the 
Complaint reads as a request for “line-jumping” over others, and is, therefore, insufficient 
to survive Defendants’ motion.                                            

ORDER

Based on the foregoing, and on all of the files, records, and proceedings herein, IT 
IS HEREBY ORDERED THAT:                                                   
1.   Defendants Jeffry Flake’s and Antony J. Blinken’s Motion to Dismiss (Doc. 
     No. 5) is GRANTED; and                                          
2.   Plaintiff Nurudiin Mohamud Abdi’s Complaint (Doc. No. 1) is dismissed in 
     its entirety, without prejudice.                                
LET JUDGMENT BE ENTERED ACCORDINGLY.                                 

Dated:  October 2, 2024                 /s/ Jeffrey M. Bryan              
                                   Judge Jeffrey M. Bryan            
                                   United States District Court      

Reference

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