Samalla v. Jaddou

Samalla v. Jaddou · United States District Court for the Eastern District of North Carolina · May 30, 2025 · No. 7:24-CV-989-FL

Summary

This United States District Court order grants the defendants' motion to dismiss a pro se complaint challenging delays in USCIS processing of immigrant visa petitions. The court finds the action moot because the underlying petitions were subsequently approved, thereby depriving the plaintiff of a live controversy. Additionally, the court denies the plaintiff's motion for leave to amend, ruling that he lacks Article III standing to compel the admission of his family members. The case is dismissed without prejudice for lack of subject matter jurisdiction.

Court
United States District Court for the Eastern District of North Carolina
Jurisdiction
United States District Court for the Eastern District of North Carolina
Decision date
May 30, 2025
Docket number
7:24-CV-989-FL
Procedural posture
Defendants moved to dismiss for lack of subject‑matter jurisdiction, standing, and mootness; plaintiff moved to retain jurisdiction and to amend the complaint.
Precedential value
nonprecedential
Disposition
dismissed

Topics

subject matter jurisdictionstandingcivil procedure

Practice areas

civil procedureconstitutional lawimmigration

Questions Presented

  1. Whether the district court has subject‑matter jurisdiction over a mandamus action under the Administrative Procedure Act.
  2. Whether plaintiff has standing to sue to compel USCIS processing of the petitions.
  3. Whether the case is moot because the petitions have been approved.
  4. Whether the court may retain jurisdiction and allow amendment of the complaint.

Holdings

  1. The court lacks subject‑matter jurisdiction; the motion to dismiss is granted.
  2. Plaintiff lacks standing because he has no cognizable injury; the motion to retain jurisdiction is denied.
  3. The case is moot; the complaint is dismissed without prejudice.
  4. The court declines to retain jurisdiction and denies the motion to amend.

Factual background

Plaintiff, a U.S. citizen, filed I‑130 petitions for his wife (a Canadian permanent resident) and daughter, which remained pending for nearly a year. The petitions were approved before the plaintiff’s motion to retain jurisdiction was filed. Plaintiff seeks a writ of mandamus to compel USCIS to process the petitions.

Procedural history

Plaintiff filed a pro se mandamus action on October 15, 2024 seeking expedited processing of I‑130 petitions for his wife and daughter. Defendants filed a Rule 12(b)(1) motion to dismiss. Plaintiff responded with motions to retain jurisdiction and to amend the complaint.

Court Document

Open PDF
Loading document…