9 F.4th 935
D.C. Cir.2021Background
- Gunay Miriyeva, an Azerbaijani national, enlisted in the U.S. Army under the MAVNI program seeking expedited naturalization under 8 U.S.C. § 1440.
- She was discharged for medical reasons during entry-level training with an "uncharacterized" separation (served <180 days); USCIS initially approved her naturalization but later revoked approval because the military did not label her separation "honorable."
- Miriyeva sued in the U.S. District Court for the District of Columbia alleging the Army/USCIS policy violated the APA, the Naturalization Clause, and the Fifth Amendment, and sought declaratory and injunctive relief.
- The district court dismissed for lack of subject-matter jurisdiction, concluding 8 U.S.C. § 1421(c) channels review of naturalization denials to the district court in which the applicant resides and forecloses parallel suits in other districts.
- On appeal, the D.C. Circuit affirmed, applying Thunder Basin framework to hold the INA’s review scheme ( §§ 1421, 1446, 1447 ) is an exclusive channel for claims like Miriyeva’s and that her claims are the type Congress intended to be reviewed there.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 1421(c) precludes suit in D.C. and requires suit in applicant's home district | Miriyeva: she challenges an agency policy, not the denial, so § 1421(c) does not bar her suit in D.C. | Government: INA’s multistep review scheme is exclusive and forecloses parallel district-court jurisdiction outside the statutory path | Held: § 1421(c) channels these claims exclusively; dismissal for lack of jurisdiction affirmed |
| Whether APA and constitutional claims are "wholly collateral" under Thunder Basin / McNary | Miriyeva: McNary allows collateral constitutional/pattern-and-practice challenges outside the statutory review provision | Government: Thunder Basin factors show claims are the type Congress intended to be adjudicated within the § 1421(c) scheme | Held: Claims are not wholly collateral — they are "inextricably intertwined" with the denial and belong in the § 1421(c) forum |
| Whether § 1421(c) leaves open meaningful judicial review if channeled to resident district court | Miriyeva: channelling to home district is inadequate and would impede relief (forum-shopping concerns) | Government: § 1421(c) provides de novo review (and APA-like relief) in the applicant’s district, so meaningful review remains available | Held: Channeling does not foreclose meaningful review — de novo, fact-finding review is available in home district |
| Whether Declaratory Judgment Act or requested injunction supplies independent jurisdiction | Miriyeva: sought declaratory and injunctive relief as standalone claims | Government: DJA is not an independent jurisdictional basis; injunction is a remedy, not a separate claim | Held: DJA cannot confer jurisdiction here; injunctive count is a remedy request — no independent jurisdiction exists |
Key Cases Cited
- Thunder Basin Coal Co. v. Reich, 510 U.S. 200 (1994) (framework for when statutory review schemes preclude parallel district-court jurisdiction)
- Elgin v. Dep't of Treasury, 567 U.S. 1 (2012) (statutory scheme can be exclusive when it painstakingly details review procedures)
- Jarkesy v. SEC, 803 F.3d 9 (D.C. Cir. 2015) (application of Thunder Basin factors to conclude exclusive review in statutory scheme)
- Heckler v. Ringer, 466 U.S. 602 (1984) (procedural challenges tied to benefit denials are not collateral when they seek to reverse agency decisions)
- McNary v. Haitian Refugee Ctr., Inc., 498 U.S. 479 (1991) (permitting collateral constitutional and pattern-and-practice claims where statutory review would be inadequate)
- Am. Fed'n of Gov't Emps. v. Trump, 929 F.3d 748 (D.C. Cir. 2019) (meaningful review exists even if relief is geographically limited; comprehensiveness of scheme counsels abstention)
- Citizens for Responsibility & Ethics in Washington v. DOJ, 846 F.3d 1235 (D.C. Cir. 2017) (de novo district-court review under an alternative statutory remedy can preclude APA review)