The U.S. immigration system, notorious for its backlogs, just saw the addition of a new, deliberately manufactured class of processing delays. On December 2, 2025, U.S. Citizenship and Immigration Services (USCIS) issued a sweeping internal policy memorandum, PM-602-0192, directing its officers to place an immediate, system-wide hold on broad categories of applications.
This is not a typical backlog driven by high volume. This is an intentional “adjudicative hold” driven by national security concerns, and it has profound implications: for hundreds of thousands of applicants, the Writ of Mandamus is now the only viable legal tool to challenge an indefinite stall.
The Scope of the Freeze: Who is Affected by PM-602-0192?
USCIS’s new mandate effectively freezes two major groups of applicants:
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All Asylum Applications: The memo directs officers to immediately stop adjudicating all pending asylum applications (Form I-589), regardless of the applicant’s country of nationality. This national pause is pending a comprehensive, mandated security review process.
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Nationals of Designated “High-Risk” Countries: USCIS has placed an immediate hold on all pending immigration benefit requests for individuals whose country of birth or citizenship is among the 19 designated “high-risk” nations (as outlined in the June 2025 Presidential Proclamation).
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Affected Benefits: This hold is not limited to asylum. It impacts critical filings like Form I-485 (Adjustment of Status/Green Card), Form I-751 (Removal of Conditions), and Form N-400 (Naturalization).
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Re-Review of Approvals: Furthermore, the policy directs a comprehensive re-review of previously approved benefits for individuals from these countries who entered the U.S. on or after January 20, 2021, which may trigger new interviews and potential revocations.
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The Mandamus Impact: Challenging a Deliberate Hold
The most legally challenging aspect of this policy is that USCIS has explicitly acknowledged and justified the resulting delays. The agency stated that the consequence of processing delays is “necessary and appropriate” when weighed against the “urgent need for the agency to ensure that applicants are vetted and screened to the maximum degree possible” to protect national security.
This justification creates a new frontier for Mandamus litigation:
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The Clear Duty to Act: A Writ of Mandamus compels a government agency to perform a non-discretionary duty. While USCIS has discretion over the outcome (approval or denial), it still has a clear, non-discretionary duty to adjudicate applications within a reasonable time.
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The Unreasonable Delay Argument: For applicants, especially those with no derogatory information, the nationality-based or asylum-wide halt amounts to an indefinite, arbitrary hold. Attorneys must now argue in federal court that, even under the national security rationale, the suspension of all action for an indefinite period—exceeding published processing times—is an unreasonable failure to act under the Administrative Procedure Act (APA).
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The Only Remedy: Since USCIS has instructed its officers not to proceed with these cases until a subsequent memo lifts the hold, administrative inquiries and standard agency contact methods are futile. The federal court is often the sole avenue to force the agency to prioritize a stalled case and compel a decision.
The Legal Crossroads
The new policy sets up a direct legal clash between an applicant’s right to timely adjudication and the government’s broad claim of national security discretion. Individuals caught in the PM-602-0192 freeze face prolonged uncertainty, potential gaps in employment authorization (EADs), and severe disruption to family unity. Litigation via Mandamus is no longer just a tool for slow cases; it is now the primary legal defense against an explicit administrative freeze.
Conclusion
The USCIS Policy Memorandum PM-602-0192 represents a calculated administrative measure that sacrifices timely processing for certain applicants in the name of security, creating a backlog that traditional administrative means cannot resolve. If your asylum application is frozen, or if your adjustment of status or naturalization case is stalled due to your country of origin falling under the new “high-risk” classification, you are now facing an indefinite delay that only aggressive federal litigation can address. To assess whether your case meets the standard for an unreasonable delay and to pursue a Writ of Mandamus challenge against this new policy-driven freeze, contact Lforlaw today to connect with expert attorneys specializing in federal immigration litigation and administrative law.
Sources
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USCIS Policy Memorandum PM-602-0192: Hold and Review of all Pending Asylum Applications and all USCIS Benefit Applications Filed by Aliens from High-Risk Countries (Issued December 2, 2025).
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28 U.S.C. § 1361 (The Mandamus Act): Federal statute granting courts the power to compel federal officers to perform a duty.
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5 U.S.C. § 706(1) (The Administrative Procedure Act): Authorizes courts to review and compel agency action that is unreasonably delayed.
