Federal Court Orders USCIS to Adjudicate Iranian Green Card Applications Frozen by Trump Policy Memo
By Peter M. Viles, J.D., LL.M. · March 2026 · 5 min read · For informational purposes only. Not legal advice.
Background: The USCIS Adjudication Hold
In December 2025 and January 2026, USCIS issued two internal policy memoranda — PM-602-0192 and PM-602-0194 — instructing immigration officers to continue processing applications from nationals of certain designated countries, but to refrain from making any final adjudication decision. The hold initially covered 19 countries and was subsequently expanded to cover 20 additional countries, including Nigeria, for a combined total of 39 affected nationalities.
Iranian nationals were among the first affected. For applicants already in the pipeline — individuals who had attended biometrics appointments, submitted supporting documents, and waited months or years for a decision — the memos created a legal limbo with no stated end date and no avenue for recourse through normal USCIS channels.
The Plaintiffs: Varniab and Langroudi
Zahra Shokri Varniab and her husband Ashkan Pourabhari Langroudi are Iranian nationals and physicians working at Stanford University. Both graduated from Tehran University of Medical Sciences. They had timely filed their I-485 applications to adjust status to lawful permanent resident and their associated I-765 employment authorization applications. They attended biometrics appointments in May 2025 — and then watched their cases frozen in place when PM-602-0192 took effect.
Rather than wait indefinitely, they filed suit in the Northern District of California seeking a court order compelling USCIS to adjudicate their applications within 30 days. The government opposed the motion vigorously, arguing that USCIS’s decision to hold adjudications was a matter of unreviewable agency discretion.
The Court’s February 20, 2026 Ruling
The magistrate judge granted the preliminary injunction and ordered USCIS to adjudicate the plaintiffs’ I-485 and I-765 applications. The court rejected the government’s core argument — that an indefinite adjudication hold is shielded from judicial review as a discretionary agency action.
The Administrative Procedure Act, 5 U.S.C. § 706(1), authorizes courts to compel agency action “unlawfully withheld or unreasonably delayed.” An indefinite hold with no stated end date is precisely the kind of unreasonable delay the APA was designed to address.
The ruling neither invalidates PM-602-0192 or PM-602-0194 on their face, nor does the ruling create a class-wide remedy for all affected nationals. The court’s decision in this case is a case-specific injunction. However, the reasoning that indefinite delay is reviewable and compellable applies broadly.
What This Means If Your Application Is Frozen
If you are an Iranian national or a national of any of the other 38 countries covered by the policy memos,with a pending I-485 or I-765 application that has been frozen, the Varniab ruling matters to you:
APA Mandamus Action
A federal district court action under the APA and 28 U.S.C. § 1361 can compel USCIS to act. The court has authority to order adjudication within a defined timeframe.
Unreasonable Delay Standard
Courts apply the TRAC factors to evaluate whether delay is unreasonable. An indefinite hold tied to a blanket policy memo — with no case-specific review — is strong grounds for relief. The TRAC factors come from Telecommunications Research & Action Center v. FCC, 750 F.2d 70 (D.C. Cir. 1984). Courts use them to decide whether agency delay is unreasonable enough to warrant a court order compelling action.
I-765 Work Authorization
The hold freezes not just the green card but associated work permits. Loss of work authorization creates immediate, irreparable harm — a factor courts weigh heavily in granting injunctive relief.
Case-by-Case Filing
Because Varniab is not a class action, each affected individual must file his or her own action. An attorney can evaluate whether your specific facts support an APA mandamus petition.
The Broader Context
The adjudication hold is part of a wider pattern of using administrative delay — rather than formal denials — to effectively suspend immigration benefits without triggering the procedural protections that accompany outright denials. A denial can be appealed. An indefinite delay cannot be appealed through normal channels — which is precisely why APA mandamus litigation has become an essential tool in the current environment.
This same principle — that courts can compel unreasonably delayed agency action — underlies the § 1447(b) naturalization petition strategy used when USCIS fails to decide naturalization applications within 120 days of the examination. If USCIS will not act, the federal courts can and will step in.
IS YOUR APPLICATION FROZEN?
If you are an Iranian national or a national of another affected country with a pending I-485 or I-765 application that has received no decision, contact Viles Law Firm for a confidential consultation. We represent clients from all 50 states and worldwide.
(713) 622-4647 · peter@vileslaw.com · vileslaw.com
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