GUTHULA v. JOHNSON, 2:16-cv-02544

Plaintiff Phani K. Guthula, an Indian national, held H-1B status beginning October 1, 2013; his H-1B was extended to September 9, 2018 by a new employer’s approved I-129.
While his initial H-1B was still valid, Guthula applied on February 18, 2015 to change his status to F-1 (Form I-539); that I-539 remained pending for over a year.
During the pendency of the I-539 Guthula accepted new employment; the new employer’s expedited I-129 was approved on October 7, 2015, restoring H-1B status.
USCIS later denied the I-539 on March 5, 2016, concluding he was not a student at the relevant time; Guthula contends that denial effectively shortened his overall authorized stay by about seven months.
Guthula sought declaratory relief that he was in F-1 status during that seven-month period; defendants contend any injury is speculative because future events (e.g., an employer-sponsored green card) could eliminate the asserted harm.
The parties filed cross-motions for summary judgment on a purely legal record; the court dismissed the case without prejudice for lack of Article III jurisdiction (standing/ripeness).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Guthula has Article III standing to challenge denial of I-539	Denial caused a concrete injury: seven months that could have been F-1 will count against his H-1B time, shortening lawful stay	Injury is speculative; future events (e.g., permanent residency) may obviate any harm, so the injury is not certainly impending	No standing—injury too conjectural and not sufficiently imminent
Whether the claim is ripe for judicial review	Denial is a completed agency action causing present legal injury warranting review	Ripeness lacking because the harm depends on future contingencies before H-1B expiry	Not ripe—timing and probability of future harm insufficient for Article III jurisdiction
Whether simultaneous grant of another status (H-1B) affects reviewability	Plaintiff maintains he was nonetheless harmed by the I-539 denial	Defendants emphasize grant of H-1B removal of immediate harm	Court: simultaneous grant undermines immediacy; distinguishes prior cases where only a denial existed
Whether declaratory relief is available absent completed harm	Plaintiff seeks declaration that he was F-1 for the seven months, which would preserve H-1B time	Defendants argue declaratory relief inappropriate for speculative future injury	Court declines to decide merits; declaratory relief unavailable without Article III injury

Lujan v. Defenders of Wildlife, 504 U.S. 555 (injury-in-fact, causation, redressability standing framework)
Whitmore v. Arkansas, 495 U.S. 149 (future injury must be certainly impending; speculative harms insufficient)
Reilly v. Ceridian Corp., 664 F.3d 38 (3d Cir.) (allegations of possible future injury insufficient for standing)
Armstrong World Indus. v. Adams, 961 F.2d 405 (3d Cir.) (ripeness tied to injury-in-fact; contingent claims often unripe)
Steel Co. v. Citizens for a Better Environment, 523 U.S. 83 (court must first resolve Article III jurisdiction)
Storino v. Borough of Point Pleasant Beach, 322 F.3d 293 (3d Cir.) (court must independently assure subject-matter jurisdiction)