FENG
v.
UNITED STATES CITIZENSHIP AND IMMIGRATION SERVICES
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Plaintiff Feng sued USCIS under the Administrative Procedure Act challenging an allegedly unreasonable delay in adjudicating her I-485 application. After her application was approved during the litigation, the court granted the Government's unopposed motion to dismiss the case as moot, finding that the plaintiff's complaint became justiciable once the underlying administrative action was resolved.
The case is moot and must be dismissed. Once Plaintiff's I-485 application was approved, she no longer had a legally cognizable interest in the outcome of the litigation, as the issues presented were no longer 'live.'
[1] A case becomes moot when the issues presented are no longer live or the parties lack a legally cognizable interest in the outcome.
[2] Federal courts lack jurisdiction to issue opinions on moot questions or abstract propositions that cannot affect the matter in issue.
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“Article III of the Constitution limits the jurisdiction of the federal courts to the consideration of 'Cases' and 'Controversies.'”
Establishes the constitutional foundation for the mootness doctrine that requires an active case or controversy for federal court jurisdiction.
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Join FLexlaw to unlock all legal intelligencePlaintiff Feng filed suit on October 3, 2023, challenging the delay in adjudication of her I-485 application. On February 29, 2024, while the case was…
The full statement of facts, procedural history, and disposition for this case are member content.
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THIS CAUSE is before the Court on the Government's Unopposed Renewed Motion to Dismiss (Doc. 13). On October 3, 2023, Plaintiff filed this action seeking relief under the Administrative Procedure Act, 5 U.S.C. § 701 et seq., for the alleged unreasonable delay in the adjudication of her I-485 application. (Compl., Doc. 1, 3- 4). On February 29, 2024, Plaintiff's I-485 application was approved by United States Citizenship and Immigration Services. (Approval Notice, Doc. 13-1, at 1). The Government now moves to dismiss Plaintiff's Complaint as moot, which Plaintiff has indicated she does not oppose. (Doc. 13 at 2–3).
"Article III of the Constitution limits the jurisdiction of the federal courts to the consideration of 'Cases' and 'Controversies.” Mingkid v. U.S. Atty. Gen., 468
F. 3d 763, 768 (11th Cir. 2006) (citing U.S. Const. art. III, § 2). “[A] federal court has no authority 'to give opinions upon moot questions or abstract propositions, or to declare principles or rules of law which cannot affect the matter in issue in the case before it.” Harrell v. The Fla. Bar, 608 F. 3d 1241, 1265 (11th Cir. 2010) (quoting Church of Scientology of Ca. v. United States, 506 U.S. 9, 12 (1992)). “[A] case is moot when the issues presented are no longer 'live' or the parties lack a legally cognizable interest in the outcome.” Fla. Ass'n of Rehab. Facilities, Inc. v. State of Fla. Dep't of Health & Rehab. Servs., 225 F. 3d 1208, 1216 (11th Cir. 2000) (quoting Powell v. McCormack, 395 U.S. 486, 496 (1969)).
The approval of Plaintiff's I-485 application has rendered moot Plaintiff's Complaint and it is due to be dismissed. Accordingly, it is ORDERED and ADJUDGED as follows:
1. The Government's Unopposed Renewed Motion to Dismiss (Doc. 13) is GRANTED.
2. Plaintiff's Complaint (Doc. 1) is DISMISSED as moot.
3. The Clerk is directed to close this case.
DONE and ORDERED in Orlando, Florida on May 15, 2024.
CARLOS E. MENDOZA
UNITED STATES DISTRICT JUDGE
Copies furnished to:
Counsel of Record Unrepresented Party
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Powell v. McCormack, 395 U.S. 486 (U.S. 1969)
- Church of Scientology of Cal. v. United States, 506 U.S. 9 (U.S. 1992)
- Fla. Ass'n OF Rehab. Facilities, Inc. v. State OF Fla. Dep't OF Health & Rehabilitative Servs., 225 F.3d 1208 (11th Cir. 2000)