Case: Bowser v. Noem

1:26-cv-10382 | U.S. District Court for the District of Massachusetts

Filed Date: Jan. 27, 2026

Case Ongoing

Clearinghouse coding complete

Case Summary

This lawsuit was brought by a Venezuelan national lawfully residing and working in the United States to challenge the delay in her application for a visa renewal. On June 4, 2025, President Trump issued Proclamation 10949 entitled “Restricting the Entry of Foreign Nationals to Protect the United States from Foreign Terrorists and Other National Security and Public Safety Threats.” The Proclamation was intended to prevent the entry or admission of foreign nationals about whom the United States G…

This lawsuit was brought by a Venezuelan national lawfully residing and working in the United States to challenge the delay in her application for a visa renewal.

On June 4, 2025, President Trump issued Proclamation 10949 entitled “Restricting the Entry of Foreign Nationals to Protect the United States from Foreign Terrorists and Other National Security and Public Safety Threats.” The Proclamation was intended to prevent the entry or admission of foreign nationals about whom the United States Government lacks sufficient information to assess the risks they pose to the United States; it names Venezuela as a country subject to a partial restriction and limit on entry. On November 27, 2025, the United States Citizenship and Immigration Services (USCIS) issued new policy guidance indicating that the agency will consider, “relevant country-specific facts and circumstances such as those outlined in PP 10949 as part of its adjudication of discretionary benefit requests.” 

Valentina Amaro Bowser has studied, lived, and legally worked in this country since 2013. She first arrived on a F-1 visa to attend college, and had subsequently been granted two H-1B visas, which she never violated the terms of. Her third H-1B visa application was filed by her employer on December 10, 2025, and while her petition was pending, she was authorized to work only through February 14, 2026. After marrying her U.S. citizen husband Brandon Bowser, Valentina also applied for her residence on Form I-485 and Brandon filed a visa petition on Form I-130 for her on January 8, 2026. 

In accordance with the Trump Administration’s policies, Valentina’s applications were delayed over 12 months, and when she was finally interviewed by USCIS she “learn[ed] that the USCIS could not adjudicate the applications because of an unlawful hold on applications from citizens of 39 countries, one of which is Venezuela.”

On January 27, 2026, Plaintiffs Valentina Amaro Bowser and Brandon Bowser filed suit in the U.S. District Court for the District of Massachusetts against the Department of Homeland Security (DHS), USCIS, and their directors. They alleged that, despite the visa applications meeting all requirements for approval, the Defendants have “improperly withheld action on said applications to the detriment of each Plaintiff” in violation of the Administrative Procedure Act (APA). The Plaintiffs sought a writ of mandamus under the Mandamus act to compel the USCIS to undertake its “mandatory duty to adjudicate the Plaintiffs’ Forms I-130, I-485, and I-765 within a ‘reasonable time’ under the INA and APA.” They also sought declaratory and injunctive relief to set aside the challenged Trump Administration policies, and attorneys’ fees. The case was assigned to Judge Angel Kelley.

The Plaintiffs also filed a motion for emergency preliminary relief on February 6, 2026, to compel the Defendants to approve her visa applications. If she were not to be approved for “residence or for her employment authorization by February 14, 2026, she cannot legally work and will lose her job with the Commonwealth of Massachusetts after February 28, 2026 if she is not legally authorized to work by that date.” 

The Defendants filed a memorandum opposing the motion on February 16, arguing that the court lacks jurisdiction over the Plaintiffs’ APA claim because the USCIS’s interim guidance is not final agency action reviewable under the APA. Further, they argued that the “Immigration and Nationality Act (INA) bars jurisdiction over claims challenging the government’s discretionary actions with respect to employment authorization applications—including challenges to policies to hold such applications in abeyance.” And in the alternative, they argued that the USCIS’s adoption of the policy was “reasonable and reasonably explained.”

The Plaintiffs filed a reply on February 20. This case is ongoing.

Summary Authors

Madena Mustafa (2/25/2026)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/72192698/parties/bowser-v-noem/


Judge(s)

Kelley, Angel (Massachusetts)

Attorney for Plaintiff

Drago, Anthony Drago (Massachusetts)

Attorney for Defendant

Fitzgerald, Michael (Massachusetts)

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Documents in the Clearinghouse

Document
1

1:26-cv-10382

Plaintiffs' Compliant for Declaratory, Mandamus, and Injunctive Relief

Jan. 27, 2026

Jan. 27, 2026

Complaint
6

1:26-cv-10382

Plaintiffs' Memorandum in Support of Emergency Motion for Immediate Preliminary Relief

Feb. 6, 2026

Feb. 6, 2026

Pleading / Motion / Brief
19

1:26-cv-10382

Plaintiffs' Reply to Defendants' Opposition to Emergency Motion for Immediate Preliminary Relief

Feb. 20, 2026

Feb. 20, 2026

Pleading / Motion / Brief

Docket

See docket on RECAP: https://www.courtlistener.com/docket/72192698/bowser-v-noem/

Last updated March 30, 2026, 3:11 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT for Declaratory, Mandamus, and Injunctive Relief against All Defendants Filing fee: $ 405, receipt number AMADC-11502044 (Fee Status: Filing Fee paid), filed by Brandon Bowser, Valentina Amaro Bowser. (Attachments: # 1 Exhibit A - I-130-485 Receipts, # 2 Exhibit B - Biometrics, # 3 Exhibit C - I765 Receipt, # 4 Exhibit D - Interview Notice, # 5 Exhibit E - Processing Times, # 6 Civil Cover Sheet, # 7 Category Form)(Drago, Anthony) (Entered: 01/27/2026)

Jan. 27, 2026

Jan. 27, 2026

Clearinghouse
2

ELECTRONIC NOTICE of Case Assignment. District Judge Angel Kelley assigned to case. If the trial Judge issues an Order of Reference of any matter in this case to a Magistrate Judge, the matter will be transmitted to Magistrate Judge Jessica D. Hedges. (JKK) (Entered: 01/27/2026)

Jan. 27, 2026

Jan. 27, 2026

3

Summons Issued as to Jerry Scott Ammons, Joseph B. Edlow, Kristi Noem, US Citizenship and Immigration Services, US Department of Homeland Security. Counsel receiving this notice electronically should download this summons, complete one for each defendant and serve it in accordance with Fed.R.Civ.P. 4 and LR 4.1. Summons will be mailed to plaintiff(s) not receiving notice electronically for completion of service. (CEH) (Entered: 01/27/2026)

Jan. 27, 2026

Jan. 27, 2026

4

District Judge Angel Kelley: ORDER entered. Standing Order Regarding Motion Practice. (CEH) (Entered: 01/27/2026)

Jan. 27, 2026

Jan. 27, 2026

Notice of Case Assignment

Jan. 27, 2026

Jan. 27, 2026

5

Emergency MOTION for Preliminary Injunction Requiring Adjudication of Pending Application by Brandon Bowser, Valentina Amaro Bowser. (Attachments: # 1 Exhibit Plaintiff's Affidavit)(Drago, Anthony) (Entered: 02/06/2026)

1 Exhibit Plaintiff's Affidavit

View on RECAP

Feb. 6, 2026

Feb. 6, 2026

RECAP
6

MEMORANDUM in Support re 5 Emergency MOTION for Preliminary Injunction Requiring Adjudication of Pending Application filed by Brandon Bowser, Valentina Amaro Bowser. (Drago, Anthony) (Entered: 02/06/2026)

Feb. 6, 2026

Feb. 6, 2026

Clearinghouse
7

District Judge Angel Kelley: ELECTRONIC ORDER entered. Having received Petioners' Emergency Motion for Preliminary Injunction Requiring Adjudication of Pending Application [Dkt. 5], Respondents are hereby ORDERED to respond no later than February 16, 2026.Plaintiffs SHALL serve a copy of the Complaint [Dkt. 1] and Emergency Motion [Dkt. 5] to the Respondents no later than February 9, 2026.(MAL) (Entered: 02/06/2026)

Feb. 6, 2026

Feb. 6, 2026

Order

Feb. 6, 2026

Feb. 6, 2026

8

SUMMONS Returned Executed by Valentina Amaro Bowser, Brandon Bowser. (Drago, Anthony) (Entered: 02/10/2026)

Feb. 10, 2026

Feb. 10, 2026

9

SUMMONS Returned Executed by Valentina Amaro Bowser, Brandon Bowser. (Drago, Anthony) (Entered: 02/10/2026)

Feb. 10, 2026

Feb. 10, 2026

10

SUMMONS Returned Executed by Valentina Amaro Bowser, Brandon Bowser. (Drago, Anthony) (Entered: 02/10/2026)

Feb. 10, 2026

Feb. 10, 2026

11

SUMMONS Returned Executed as to US Attorney by Valentina Amaro Bowser, Brandon Bowser. All Defendants. (Drago, Anthony) (Entered: 02/10/2026)

Feb. 10, 2026

Feb. 10, 2026

12

SUMMONS Returned Executed by Valentina Amaro Bowser, Brandon Bowser. (Drago, Anthony) (Entered: 02/10/2026)

Feb. 10, 2026

Feb. 10, 2026

13

SUMMONS Returned Executed as to US Attorney by Valentina Amaro Bowser, Brandon Bowser. All Defendants. (Drago, Anthony) (Entered: 02/10/2026)

Feb. 10, 2026

Feb. 10, 2026

14

ELECTRONIC NOTICE of Hearing. Status Conference set for 2/11/2026 02:30 PM in Remote Proceeding : Boston before District Judge Angel Kelley. (MAL) (Entered: 02/11/2026)

Feb. 11, 2026

Feb. 11, 2026

15

NOTICE of Appearance by Michael Fitzgerald on behalf of Joseph B. Edlow, Kristi Noem, US Citizenship and Immigration Services, US Department of Homeland Security (Fitzgerald, Michael) (Entered: 02/11/2026)

Feb. 11, 2026

Feb. 11, 2026

16

Electronic Clerk's Notes for proceedings held before District Judge Angel Kelley: Status Conference held on 2/11/2026 by video conference. The Court held a brief status conference seeking clarification regarding petitioner's complaint. (Court Reporter: Linda Walsh at lwalshsteno@gmail.com.)(Attorneys present: Drago, Fitzgerald) (MAL) (Entered: 02/13/2026)

Feb. 11, 2026

Feb. 11, 2026

Notice of Hearing

Feb. 11, 2026

Feb. 11, 2026

Status Conference

Feb. 13, 2026

Feb. 13, 2026

17

Opposition re 5 Emergency MOTION for Preliminary Injunction Requiring Adjudication of Pending Application filed by Jerry Scott Ammons, Joseph B. Edlow, Kristi Noem, US Citizenship and Immigration Services, US Department of Homeland Security. (Fitzgerald, Michael) (Entered: 02/16/2026)

Feb. 16, 2026

Feb. 16, 2026

RECAP
18

District Judge Angel Kelley: ELECTRONIC ORDER entered. Having received the Respondents' Opposition [Dkt. 17] to the Emergency Motion for Preliminary Injunction Requiring Adjudication of Pending Application [Dkt. 5], Petitioners are ORDERED to submit a Reply, no later than 5:00 PM on Friday, February 20, 2026, addressing the issues of jurisdiction raised by the Respondents in their filing.(MAL) (Entered: 02/18/2026)

Feb. 18, 2026

Feb. 18, 2026

Order

Feb. 18, 2026

Feb. 18, 2026

19

REPLY to Response to 5 Emergency MOTION for Preliminary Injunction Requiring Adjudication of Pending Application filed by Brandon Bowser, Valentina Amaro Bowser. (Drago, Anthony) (Entered: 02/20/2026)

Feb. 20, 2026

Feb. 20, 2026

Clearinghouse
20

District Judge Angel Kelley: MEMORANDUM AND ORDER ON PLAINTIFFS' EMERGENCY MOTION FOR PRELIMINARY INJUNCTION REQUIRING ADJUDICATION OF PENDING APPLICATION entered.For the foregoing reasons, Plaintiffs' Emergency Motion for Preliminary Injunction Requiring Adjudication of Pending Application [Dkt. 5] is GRANTED. The Court ORDERS as follows:1. Defendants and all of their respective officers, agents, servants, employees, attorneys, and any person in active concert or participation with them who receive actual notice of this Order are ENJOINED from applying the adjudication hold of the December 2, 2025 and January 1, 2026 USCIS Policy Memoranda (PM-602-0192 and PM-602-0194) to Plaintiff Valentina Amaro Bowser's Form I-765, Application for Employment Authorization.2. Within ten (10) days of the date of this Order, Defendants shall adjudicate Plaintiff Valentina Amaro Bowser's Form I-765, Application for Employment Authorization, and inform Plaintiff of the decision and, if denied, the reasons for denial.3. Counsel for Defendants must provide written notice of this Order to all Defendants by March 2, 2026 at 5:00 PM. Defendants must file a copy of the notice on the docket at the same time.4. The Court finds that a bond is not required under Federal Rule of Civil Procedure 65(c) because Defendants did not request a bond or submit any evidence that they are likely to suffer damages from the injunction. (MAL) (Entered: 02/27/2026)

Feb. 27, 2026

Feb. 27, 2026

RECAP
21

NOTICE by Jerry Scott Ammons, Joseph B. Edlow, Kristi Noem, US Citizenship and Immigration Services, US Department of Homeland Security re 20 Memorandum & ORDER,,,,,, (Attachments: # 1 Exhibit Exhibit A)(Fitzgerald, Michael) (Entered: 03/02/2026)

1 Exhibit Exhibit A

View on PACER

March 2, 2026

March 2, 2026

22

Notice of Appearance

March 24, 2026

March 24, 2026

23

Extension of Time to File Answer

March 24, 2026

March 24, 2026

Order on Motion for Extension of Time to Answer

March 24, 2026

March 24, 2026

Case Details

State / Territory:

Massachusetts

Case Type(s):

Immigration and/or the Border

Special Collection(s):

Trump Administration 2.0: Challenges to the Government

Key Dates

Filing Date: Jan. 27, 2026

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

A Venezuelan national lawfully residing and working in the U.S., along with her U.S.-citizen spouse

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Federal

Department of Homeland Security

United States Citizenship and Immigration Services

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.

Mandamus, 28 U.S.C. § 1361

Other Dockets:

District of Massachusetts 1:26-cv-10382

Available Documents:

Complaint (any)

Trial Court Docket

Outcome

Prevailing Party: None Yet / None

Relief Sought:

Attorneys fees

Declaratory judgment

Injunction

Relief Granted:

None yet

Source of Relief:

None yet

Issues

Immigration/Border:

Employment

Work authorization - procedures

Recommended Citation