Samirkumar Shah was convicted of healthcare fraud in 2019 and sentenced to seventy-eight months in prison. While serving his sentence, he filed a motion under 28 U.S.C. § 2255 to challenge his conviction and sentence, later filing an amended motion in September 2024. Although the District Court reduced his sentence in August 2024 and he was released in November 2024, his § 2255 motions remained pending. In September 2025, Shah requested a status update and was told the motions were still active. He subsequently filed a petition for a writ of mandamus in the Third Circuit, alleging that the delay in adjudicating his motions was extraordinary. Shah also filed a motion to recuse the District Judge, which remained pending at the time of the appeal.
The court applied the standard that a writ of mandamus is warranted only where undue delay is tantamount to a failure to exercise jurisdiction. The panel found that the delay in Shah's case did not meet this high bar. The District Court had recently confirmed in September 2025 that the motions were still pending and that Shah would be notified upon resolution. Furthermore, the court noted that a separate motion for judicial recusal was currently pending before the District Court. The Third Circuit expressed confidence that the District Court would decide the motions in due course and declined to intervene in the recusal matter, as it was properly before the lower court.
The denial of the mandamus petition means the District Court retains jurisdiction to resolve Shah's § 2255 motions and his recusal request. The decision does not preclude Shah from seeking relief again; the court explicitly denied the petition without prejudice, meaning Shah may file a new mandamus petition if the District Court subsequently fails to act without undue delay. The ruling reinforces that appellate courts generally will not intervene in district court delays unless the inaction rises to the level of a failure to exercise jurisdiction.
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