The following excerpt is from Patel v. Reno, 121 F.3d 1277 (9th Cir. 1997):
1 We do not suggest that this is the only exception to the general rule or that it represents the limitation of judicial review of visa denials generally. For example, we note that judicial review exists when the government has denied a visa if the government did not act "on the basis of a facially legitimate and bona fide reason." Kleindienst v. Mandel, 408 U.S. 753, 92 S.Ct. 2576, 33 L.Ed.2d 683 (1972). In addition, as government counsel noted at oral argument, judicial review may also exist under certain circumstances pursuant to the Administrative Procedure Act. However, neither situation is presented in this appeal.
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