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Christian v. Mullin

2026-08-21

Summary

Holding. The court denied the defendants' motion to dismiss because the D.C. Circuit's decision in Castaneira v. Noem directly controls this dispute, and the court lacks authority to revisit binding appellate precedent that squarely applies to the facts presented. The court also granted the plaintiff's motions to expedite consideration and denied without prejudice his motion for summary judgment, permitting him to resubmit it in light of this opinion and setting an expedited briefing schedule for cross-motions.

Mark Christian, a disabled U.S. citizen veteran, seeks judicial review of the U.S. Citizenship and Immigration Services' repeated denials of his I-130 petition on behalf of his foreign national wife. The USCIS invoked the Adam Walsh Act, which bars certain convicted sex offenders from sponsoring relatives for permanent residence, but the agency rejected Christian's request for a discretionary exception by requiring him to prove "beyond any reasonable doubt" that he poses no risk to his beneficiary. Christian contends that the USCIS violated its own binding precedent by applying this heightened standard rather than the traditional "preponderance of the evidence" standard that agency rules ordinarily require.

The defendants moved to dismiss on jurisdictional grounds, arguing that the Immigration and Nationality Act strips courts of authority to review discretionary agency decisions. The court rejected this argument, finding that recent D.C. Circuit precedent directly controls the case. The court held that even when Congress grants an agency broad discretion, that agency cannot disregard its own binding regulations and precedents in exercising that discretion, and courts retain jurisdiction to review whether an agency has complied with its self-imposed rules. The court granted Christian's request for expedited consideration given his serious health conditions and denied the defendants' motion to dismiss.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether federal courts retain jurisdiction to review agency compliance with binding internal precedent when a statute commits discretionary decisions to the agency
  • Whether the USCIS improperly applied a 'beyond any reasonable doubt' standard instead of the 'preponderance of the evidence' standard required by agency precedent
  • Whether the Adam Walsh Act's discretionary exception is subject to judicial review for procedural compliance with agency rules

Procedural posture

The plaintiff, proceeding pro se, initiated this civil action challenging USCIS denials of his I-130 petition and sought expedited consideration; the defendants moved to dismiss for lack of subject-matter jurisdiction, and the plaintiff moved for summary judgment.

Authorities cited

Opinion

majority opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

MARK CHRISTIAN,

Plaintiff,

Civil Action No. 26-1428 (RDM)

v.

MARKWAYNE MULLIN, et al.,

Defendants.

MEMORANDUM OPINION AND ORDER

Pro se Plaintiff Mark Christian brings this action challenging the United States

Citizenship and Immigration Service’s (“USCIS”) denial of his I-130 petition requesting that the

Attorney General recognize his wife, who is a foreign national, as an “immediate relative”

entitled to obtain lawful permanent residence status in the United States. See 8 U.S.C. § 1154.

Pending before the Court are Plaintiff’s motions to expedite consideration of his case, Dkts. 3 &

15, Defendants’ motion to dismiss, Dkt. 17, and Plaintiff’s motion for summary judgment, Dkt.

4.

For the reasons explained below, the Court will GRANT Plaintiff’s motions to expedite,

will DENY Defendants’ motion to dismiss, and will DENY Plaintiff’s motion for summary

judgment without prejudice to permit Plaintiff to re-brief the dispositive issues in light of the

Court’s opinion. The Court will also set an expedited schedule for cross-motions for summary

judgment.

I. BACKGROUND

Christian is a U.S. citizen and severely disabled veteran residing in Oklahoma City,

Oklahoma, who reports that he is facing a number of grave medical crises, including congestive heart failure, kidney failure, type 2 diabetes, and post-traumatic stress disorder. Dkt. 15 at 3;

Dkt. 11-1 at 1. Christian married his wife, a foreign national, in 2008, and has filed four separate

I-130 petitions on her behalf “[o]ver the span of fifteen years.” Dkt. 11-1 at 1. The USCIS has

denied each application from 2014 to 2026, id. at 2, based on the Adam Walsh Act (“AWA”),

which excludes U.S. citizens “who ha[ve] been convicted of” covered sex offenses from the I130 process, 8 U.S.C. § 1154(a)(1)(A)(viii)(I). The only exception to the exclusion is for cases

in which “the Secretary of Homeland Security, in [his] sole and unreviewable discretion,

determines that the citizen poses no risk to the alien with respect to whom a [I-130]

petition . . . is filed.” Id. Christian’s complaint pertains to the USCIS’s two most recent denials

on February 7, 2023 and February 25, 2026, both of which concluded that in order to qualify

under the exception to the AWA, Christian was required to “provide evidence to establish

‘beyond any reasonable doubt’ that he poses no risk to the beneficiary.” Dkt. 11-1 at 2; Dkt. 11-3

(February 7, 2023 decision); Dkt. 1-1 (February 25, 2026 decision). The USCIS never

considered whether Christian could prevail under a less demanding standard of proof, such as the

preponderance standard.

On April 24, 2026, Christian initiated this action, Dkt. 1, and, at the same time, sought

expedited consideration in light of his health crises and the risk that his wife, who is his sole

caregiver, might face imminent removal from the United States, Dkt. 3. On June 8, 2026,

Christian filed an amended complaint, alleging that the USCIS “applied a ‘beyond any

reasonable doubt’ standard . . . directly violat[ing] the ‘preponderance of the evidence’ standard

established [in] agency precedent.” Dkt. 11 at 4. He contends that the USCIS’s application of

the more demanding evidentiary standard in adjudicating and denying his I-130 petition violated

binding USCIS precedent in Matter of Chawathe, 25 I. & N. Dec. 369 (AOO 2010), and D.C.

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Circuit precedent, Castaneira v. Noem¸ 138 F.4th 540 (D.C. Cir. 2025). Id. On July 9, 2026,

Plaintiff filed a renewed motion for expedited consideration, reiterating the need for expeditious

resolution of his case in light of his “profound, active, and life-threatening” condition. Dkt. 15 at

2.

Although Defendants were not required to respond to the amended complaint until

August 14, 2026, Dkt. 14, they promptly moved to dismiss on July 20, 2026, Dkt. 17, but have

not otherwise responded to Plaintiff’s motions to expedite the litigation.

II. ANALYSIS

The Court starts with Plaintiff’s motion to expedite the litigation, which requires only

brief consideration. Defendants do not dispute any of Plaintiff’s factual representations

regarding his health crises and, beyond moving to dismiss with considerable dispatch, they do

not respond to Plaintiff’s request for expedition. The Court will, accordingly, resolve the

pending motion to dismiss without delay and will set an expedited schedule for cross-motions for

summary judgment.

Defendants’ motion to dismiss, in turn, can be resolved with similar ease. In Plaintiff’s

view, this case is controlled by the D.C. Circuit’s recent decision in Castaneira v. Noem. 138

F.4th 540 (D.C. Cir. 2025). Defendants, for their part, do not dispute that the question presented

by their motion to dismiss is on all fours with Castaneira. Nor could they. In Castaneira, a U.S.

citizen filed a Form I-130 petition for his spouse, a Mexican national. Id. at 542. The USCIS

sent him a notice of intent to deny because he had been convicted of committing crimes “that

appeared to qualify as ‘special offenses against a minor’ under the AWA. Id. In declining to

grant an exception, the Secretary applied a beyond-a-reasonable-doubt standard, which the

plaintiff argued was at odds with controlling administrative precedent, Matter of Chawathe, 25 I.

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& N. Dec. 369 (AAO 2010), which “imposed a preponderance of the evidence standard except

where a different standard is specified by law,” Castaneira, 138 F.4th at 542–43 (citation

modified). And, indeed, those are precisely the same facts at issue here. Plaintiff alleges that his

request for an exception from the AWA was rejected under the beyond-a-reasonable-doubt

standard, even though Matter of Chawathe required the Secretary to apply the traditional

preponderance standard. Dkt. 11 at 4; Dkt. 11-1 at 2.

Moreover, here, as in Castaneira, Defendants argue that the Court lacks subject-matter

jurisdiction because the Immigration and Nationality Act (“INA”) strips federal courts of

jurisdiction “to review . . . any . . . decision or action of the Attorney General or the Secretary of

Homeland Security the authority for which is specified . . . to be in the[ir] [respective]

discretion,” 8 U.S.C. § 1252(a)(2)(B)(ii). Dkt. 17 at 11. In addressing essentially the same

argument in Castaneira, the D.C. Circuit held that Section 1252(a)(2)(B)(ii) did not strip the

courts of jurisdiction to review a U.S. citizen’s claim that the USCIS failed to comply with

binding agency precedent in adjudicating and denying discretionary immigration benefits (the

denial of which, nobody disputes, would otherwise be unreviewable). 138 F.4th at 548–51.

Specifically, Section 1252(a)(2)(B)(ii) bars judicial review only if the “decision or action of the

Attorney General or the Secretary of Homeland Security” is committed “under [that]

subchapter,” meaning Subchapter II of Title 8, Chapter 12 of the United States Code, Kucana v.

Holder, 558 U.S. 233, 239 n.3 (2010), to “the discretion of the Attorney General or the Secretary

of Homeland Security,” 8 U.S.C. § 1252(a)(2)(B)(ii). The D.C. Circuit reasoned that “[e]ven

where Congress has accorded an agency broad discretion, if the agency itself chooses to bind

itself to published procedures, this choice means that it must then ‘exercise its own discretion’ in

accordance with its own ‘existing valid regulations’ and binding precedents.” Castaneira, 138

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F.4th at 551 (quoting United States ex rel. Accardi v. Shaughnessy, 347 U.S. 260, 268 (1954)).

In other words, discretion-granting statutes do not typically “afford[] the agency discretion to

depart from its own binding regulations or precedents in making” otherwise unreviewable,

discretionary determinations. Id. at 549.

Defendants do not even attempt to distinguish Castaneira on the facts or the law. That

should end the matter. Remarkably, however, Defendants devote the core of the brief to the

contention that the D.C. Circuit erred in Castaneira. See Dkt. 17 at 15–18. In doing so, they fail

to identify any argument that the D.C. Circuit did not consider and reject. But, even more

fundamentally, Defendants ignore the cardinal principle “that binding precedent for the district

courts within a circuit is set only by the court of appeals for that circuit.” Cannon v. Watermark

Ret. Communities, Inc., 45 F.4th 137, 149 (D.C. Cir. 2022) (citation modified). This Court is not

free to revisit binding D.C. Circuit precedent that is, as here, squarely on point.

Nor does Defendants’ passing reference to the Administrative Procedure Act’s (“APA”)

“bar[] [on] review” of decisions “committed to agency discretion by law,” 5 U.S.C. § 701(a)(2),

fare any better. Dkt. 17 at 11. To start, to the extent Defendants intend to raise Section

701(a)(2) as a jurisdictional bar, akin to Section 1252(a)(2)(B), their argument is at odds with

settled precedent. As the D.C. Circuit has repeatedly explained, Section 701(a)(2) “limits the

cause of action provided by the APA,” but does not deprive the court of federal question

jurisdiction. Oryszak v. Sullivan, 576 F.3d 522, 525 & n.2 (D.C. Cir. 2009); see also People for

the Ethical Treatment of Animals v. U.S. Dep’t of Agric., 797 F.3d 1087, 1097 (D.C. Cir. 2015).

Here, Defendants treat Section 701(a)(2) as merely reinforcing Section 1252(a)(2)(B)(ii); on

their telling, “both the APA and the INA divest courts of jurisdiction over discretionary agency

action, including those of [the] USCIS.” Dkt. 17 at 11. That is incorrect.

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But even giving Defendants the benefit of the doubt, and treating their invocation of

Section 701(a)(2) as a merits defense, they fail to explain how that defense can be reconciled

with Castaneira, which recognized that, to the extent Matter of Chawathe “constitutes binding

agency precedent pursuant to the agency’s own regulations,” the Secretary—by definition—

lacks discretion to disregard it. 138 F.4th at 549. As in Castaneira, the Court leaves the

question whether Matter of Chawathe is controlling in the present circumstance for the merits

and, instead, merely rejects Defendants’ contention that the Court lacks jurisdiction to consider

that question.

Finally, Defendants argue that the Court should dismiss Plaintiff’s complaint to the extent

it purports to assert a cause of action under the Declaratory Judgment Act (“DJA”), 28 U.S.C.

§ 2201, or the Mandamus Act, 28 U.S.C. § 1361. As to the DJA, Defendants observe that it does

not establish a stand-alone cause of action. Dkt. 17 at 19. That is true, but Plaintiff does not

purport to bring a stand-alone DJA claim, and it is premature for the Court to decide whether he

might be entitled to relief under the DJA, if he prevails on his substantive APA claim. See Dkt.

11 at 4 (seeking declaratory relief). And as to the Mandamus Act, Defendants argue that the

claim is moot because the agency has already rejected his I-130 petition. Dkt. 17 at 20. But that

misunderstands Plaintiff’s claim. He is not seeking expedited consideration of his previously

rejected I-130 petition. He is merely asking that, if the Court remands the matter for further

consideration, it set a time limit to ensure that the agency renders a new decision, applying what

he asserts is the correct burden of proof, expeditiously. Dkt. 11 at 5. Again, it is premature for

the Court to resolve that question. The request for relief, however, is not moot.

The Court will, accordingly, deny Defendants’ motion to dismiss, Dkt. 17.

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CONCLUSION

For the foregoing reasons, Plaintiff’s motions to expedite, Dkts. 3, 15 are hereby

GRANTED, and Defendants’ motion to dismiss, Dkt. 17, is hereby DENIED. It is further

ordered that Plaintiff’s Motion for Summary Judgment, Dkt. 4, which was filed before Plaintiff’s

operative complaint, Dkt. 11, is DENIED without prejudice to permit Plaintiff to re-brief the

dispositive issues in light of this decision. Among other things, Plaintiff should address whether

Matter of Chawathe is controlling in the present circumstances. It is further ordered that if

Defendants intend to move for summary judgment, they file their motion on or before September

8, 2026, and if Plaintiff intends to cross-move and, if necessary, oppose Defendants’ motion, he

may do so on or before September 29, 2026. Defendants may then, as appropriate, file an

opposition and reply on or before October 13, 2026, and Plaintiff may file a final reply brief on

or before October 27, 2026.

SO ORDERED.

/s/ Randolph D. Moss

RANDOLPH D. MOSS

United States District Judge

Date: August 21, 2026

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