Rajanikanth v. Joseph B. Edlow

Background

Plaintiffs Adarsh Rajanikanth and Shivi Bhatt, identified in the complaint as non-citizens and natives of India residing in Santa Clara County, brought this action against federal immigration officials. The suit challenges inaction by U.S. Citizenship and Immigration Services (USCIS) on the plaintiffs' Form I-485 applications — the standard form used to apply for lawful permanent resident status (a "green card") within the United States.

Relationship to the Agrawal Case

The court noted that this case is substantially similar to a parallel matter it was also handling: a related proceeding before the same judge, No. 26-cv-01400-EKL. The plaintiffs in both cases are non-citizens from India seeking adjudication of their Form I-485 applications, and the same counsel represents both sets of plaintiffs and both sets of defendants. Defendants moved to dismiss both complaints on the same grounds. The court held consolidated oral argument on both motions on July 1, 2026, and prior to the hearing asked counsel to identify any relevant factual differences between the two sets of plaintiffs. None were identified.

On August 14, 2026, the court issued a written opinion in the related proceeding, granting in part the government's motion to dismiss there. Because the arguments and facts were identical, the court expressly adopted that prior reasoning in full for purposes of resolving the motion to dismiss in this case.

Motions Ruled Upon

Plaintiffs' Motion for Leave to File a Sur-Reply (ECF No. 10) A sur-reply is an additional brief filed after the standard reply brief, typically requiring court permission. The plaintiffs moved for leave to file one. Because the government did not oppose the motion, the court granted it.

Defendants' Motion to Dismiss (ECF No. 7) The government moved to dismiss the complaint under standards that the court resolved by incorporating its reasoning from the related proceeding. The court's ruling here has two components:

1. Due process claim dismissed without leave to amend. The plaintiffs' constitutional due process claim was dismissed, and the court did not permit the plaintiffs to try to fix it by filing an amended complaint. This claim is therefore concluded against the plaintiffs.

2. Remainder of the motion to dismiss denied. All other grounds for dismissal raised by the defendants were denied, meaning the remaining claims survive and the case proceeds on those claims.

What the Court Did Not Decide Here The court's reasoning — including the specific legal analysis of any surviving claims and the precise basis for dismissing the due process claim — is contained in the August 14, 2026 opinion in the related proceeding, which the court adopted by reference rather than restating in full in this order.