The U.S. Court of Appeals for the D.C. Circuit dismissed consolidated immigration appeals as moot in *Shahnaz Haeri Mehneh v. Marco Rubio*, ruling that the court could not provide effective relief after the State Department completed processing of the contested visa applications during the appeals process.
The case, decided Jan. 16, 2026, involved two visa applicants, Shahnaz Haeri Mehneh and Aliasghar Nejat, who challenged what they characterized as unreasonable delays in the adjudication of their visa applications. Both applications had been placed in administrative processing by the Department of State, a status that can extend processing times indefinitely while additional security or background checks are conducted.
Senior Circuit Judge Douglas Ginsburg wrote the opinion for the three-judge panel, which also included Circuit Judge Michelle Childs and Senior Circuit Judge Harry Edwards. The court consolidated two separate district court cases that had raised similar claims against Secretary of State Marco Rubio and Robert Jachim, acting director of screening, analysis and coordination at the State Department.
Both appellants initially filed complaints in the U.S. District Court for the District of Columbia seeking to compel the State Department to complete adjudication of their visa applications. The district court dismissed both complaints for failure to state a claim, prompting the applicants to appeal to the D.C. Circuit.
However, during the pendency of the appeals, the State Department concluded its administrative processing of both applications. According to the court's opinion, the agency issued a visa to one applicant while refusing a visa to the other, effectively resolving the underlying dispute that had prompted the litigation.
The D.C. Circuit determined that these intervening events rendered the appeals moot under Article III of the Constitution, which requires federal courts to address only live cases and controversies. "We conclude the appeals are moot because we cannot grant any effectual relief to the applicants," Judge Ginsburg wrote in the opinion.
The court found that no exception to the mootness doctrine applied to the case. Federal courts recognize limited exceptions that allow adjudication of otherwise moot cases, such as when issues are capable of repetition yet evading review, or when voluntary cessation of challenged conduct does not eliminate the possibility of recurrence.
The case attracted significant attention from immigration advocacy organizations, with multiple groups filing amicus curiae briefs supporting the appellants. The American Immigration Council and American Immigration Lawyers Association jointly filed a brief, as did the libertarian Cato Institute and the National Iranian American Council.
The appellants were represented by attorneys Curtis Lee Morrison, Garrett Carter May, Spencer Faber, and Andrew T. Tutt. The government's defense was handled by Assistant Attorney General Brett A. Shumate and other attorneys from the Department of Justice's Office of Immigration Litigation.
Visa administrative processing has become a contentious issue in immigration law, particularly affecting applicants from certain countries or those whose applications trigger additional security screening requirements. The process can extend visa adjudication for months or years beyond normal processing times, often with limited transparency about the reasons for delays or expected completion dates.
While the appellants' specific nationalities or visa categories were not detailed in the available portion of the opinion, the involvement of the National Iranian American Council as an amicus suggests the case may have involved applicants from Iran, a country whose nationals often face extended administrative processing due to national security screening requirements.
The mootness dismissal means the D.C. Circuit did not reach the merits of whether the State Department's processing delays violated the appellants' rights or whether courts have authority to compel agencies to complete visa adjudications within specific timeframes. This leaves unresolved broader questions about judicial oversight of immigration processing delays.
The ruling reflects the challenges faced by visa applicants seeking judicial relief for processing delays. Courts are often reluctant to interfere with executive branch immigration decisions, particularly those involving national security screening. Additionally, the inherently time-sensitive nature of visa applications can make cases vulnerable to mootness when agencies complete processing during litigation.
The decision comes as the State Department under Secretary Rubio continues to face scrutiny over visa processing times and procedures. Immigration attorneys and advocacy groups have long criticized administrative processing as lacking sufficient transparency and procedural safeguards.
The consolidated cases originated in the district court in 2024, suggesting the administrative processing delays lasted at least through the initial filing of the complaints. The timing indicates that even cases challenging processing delays can themselves face lengthy court proceedings that may ultimately become academic if the underlying applications are resolved.
For future applicants facing similar delays, the ruling demonstrates the difficulty of obtaining judicial relief for visa processing issues, particularly when agencies maintain discretion over the timing and scope of administrative review procedures.