The Eleventh Circuit has determined that the doctrine of consular nonreviewability does not deprive a federal court of subject matter jurisdiction over a challenge to a visa denial. However, the court also determined that the government is not required to proffer a factual predicate for a visa denial if the consular officer cites a ground of inadmissibility that specifies discrete factual predicates.

The full text of Del Valle v. Secretary of State can be found here:

https://media.ca11.uscourts.gov/opinions/pub/files/201914889.pdf

Comment