Idania M. Acosta Reynoso et al. v. United States Citizenship and Immigration Services et al.

The case of *Idania M. Acosta Reynoso et al. v. United States Citizenship and Immigration Services et al.*, filed in the Middle District of Florida, represents a significant challenge to U.S. Citizenship and Immigration Services (USCIS) policies causing delays in immigration benefit adjudications. The plaintiffs, a large group of individuals, have brought claims under the Administrative Procedure Act and the Mandamus Act, seeking to compel USCIS to adjudicate their pending Form I-485 (adjustment of status) and Form I-765 (employment authorization) applications. The lawsuit specifically targets USCIS policy memoranda that allegedly implement a “Benefits Hold Policy” impacting applicants from certain countries, including those referenced in Proclamation 10998. This litigation highlights the ongoing struggle of applicants facing unreasonable processing delays and the judicial avenues available to compel agency action.

The United States immigration system is frequently characterized by extensive processing times, leading to significant uncertainty and hardship for applicants. In this context, federal courts often serve as a crucial forum for individuals seeking to compel timely action from immigration agencies. The recent filing of *Idania M. Acosta Reynoso et al. v. United States Citizenship and Immigration Services et al.* in the U.S. District Court for the Middle District of Florida, Case No. 8:26-cv-1314-KKM-NHA, underscores the persistent challenges faced by applicants and the increasing reliance on judicial intervention to address agency inaction.

This class action-like lawsuit, involving numerous plaintiffs, directly confronts alleged systemic delays by USCIS in adjudicating critical immigration benefits, specifically Form I-485 applications for adjustment of status and Form I-765 applications for employment authorization. The core of the plaintiffs' challenge centers on specific USCIS policy memoranda that purportedly institute a “Benefits Hold Policy” or “Adjudication Hold Policy,” which places applications from individuals from countries listed in Proclamation 10998 under an indefinite hold. This article will delve into the legal framework underpinning such challenges, analyze the specific claims and procedural posture of the *Acosta Reynoso* case, and discuss the broader implications for immigration practitioners navigating prolonged agency delays.

Challenges to federal agency inaction or unreasonable delay typically arise under two primary statutory provisions: the Mandamus Act, 28 U.S.C. § 1361, and the Administrative Procedure Act (APA), 5 U.S.C. § 706(1). The Mandamus Act grants federal district courts original jurisdiction over actions seeking to compel an officer or employee of the United States or any agency thereof to perform a duty owed to the plaintiff. For a writ of mandamus to issue, a plaintiff must demonstrate three elements: (1) a clear right to the relief requested, (2) a clear, non-discretionary duty on the part of the defendant to perform the act in question, and (3) the absence of any other adequate remedy.

Complementing the Mandamus Act, the APA provides that a reviewing court shall “compel agency action unlawfully withheld or unreasonably delayed.” 5 U.S.C. § 706(1). The APA further requires agencies to conclude matters presented to them “within a reasonable time.” 5 U.S.C. § 555(b). While the Mandamus Act and APA claims for unreasonable delay are often brought concurrently and require essentially the same showing, they provide distinct, yet overlapping, bases for judicial intervention. In the immigration context, these provisions are frequently invoked when USCIS fails to adjudicate applications within reasonable processing times, particularly after applicants have exhausted available administrative remedies such as service requests or congressional inquiries.

The *Acosta Reynoso* litigation exemplifies the use of these legal tools to address systemic delays in immigration processing. The plaintiffs specifically challenge USCIS policy memoranda PM-602-0192, 602-0194, and 602-0199, which they allege constitute a “Benefits Hold Policy” that effectively stalls the adjudication of Form I-485 and Form I-765 applications for individuals from countries subject to Proclamation 10998. This policy, described as placing a hold on all adjudications for people from “Travel Ban Countries,” has been a subject of contention, with at least one other federal court, in *Dorcas International Institute of Rhode Island v. United States Citizenship & Immigration Services*, vacating a similar “Benefits Hold Policy.”

To succeed in *Acosta Reynoso*, the plaintiffs must establish that USCIS has a clear, non-discretionary duty to adjudicate their applications and that the delay is unreasonable. While USCIS has discretion over the outcome of an application (approval or denial), it generally has a mandatory duty to make a decision. The determination of “unreasonable delay” is fact-specific, considering factors such as published processing times, the absence of any action on the file for an extended period, and any statutory deadlines. The plaintiffs in *Acosta Reynoso* sought immediate relief through a motion for a temporary restraining order and preliminary injunction, requesting that the court enjoin the challenged policies and compel adjudication within 30 days. However, the court denied the temporary restraining order, ordering the defendants to respond to the motion for preliminary injunction, indicating that the court will require a more thorough adversarial process before potentially granting injunctive relief.

This procedural posture highlights a critical aspect of mandamus and APA delay cases: while they can compel agency action, they do not dictate the outcome of the underlying application. A court order typically directs USCIS to adjudicate the case, which could still result in a denial if there are substantive grounds. Nevertheless, such lawsuits often prove effective in breaking through bureaucratic inertia, with many cases seeing movement on the underlying application within months of filing, as the government often prefers to act rather than litigate. The Middle District of Florida, where *Acosta Reynoso* is pending, regularly handles immigration-related litigation, including habeas corpus petitions and other challenges to agency action, demonstrating its familiarity with such cases.

The *Acosta Reynoso* case serves as a critical reminder for immigration practitioners and their clients that federal litigation remains a viable and often necessary avenue to address unreasonable delays by USCIS. While the denial of the temporary restraining order in this specific instance indicates the court's cautious approach to emergency relief, the underlying motion for a preliminary injunction and the merits of the mandamus and APA claims continue to press for accountability. Practitioners representing clients facing prolonged processing times, especially those impacted by broad agency policies, should carefully consider the elements required for a successful mandamus or APA delay claim, including demonstrating a clear right to relief, a clear agency duty, and the exhaustion of administrative remedies.

Looking ahead, the outcome of *Acosta Reynoso* and similar cases will be closely watched. A favorable ruling compelling USCIS to cease applying the challenged “Benefits Hold Policy” and to adjudicate applications within a reasonable timeframe could set an important precedent for thousands of applicants. This litigation underscores the judiciary's role in ensuring that federal agencies adhere to their statutory duties and process immigration benefits in a timely and lawful manner, thereby upholding due process and preventing indefinite administrative limbo for individuals seeking to regularize their status in the United States.