The district court's order granting the Government's motion to dismiss a claim for a writ of mandamus filed by petitioner, a United States citizen, to adjudicate the visa application she filed on behalf of her husband, is reversed, where: 1) the Government's citation to terrorism grounds under 8 U.S.C. section 1182(a)(3)(B), in the absence of any allegations of proscribed conduct, was not a facially legitimate reason to deny petitioner's husband's visa; 2) the Government did not put forth a facially legitimate reason to deny the visa; and 3) petitioner had standing to seek a declaratory judgment that the visa denial notice provision under section 1182(b)(3) was unconstitutional as applied to her.