1) The 2nd and DC Circuits refuse to accept a petition for review for a
failure to act. They will only accept it as a writ of mandamus,
treating it as an extraordinary writ. Can a petitioner file a petition
for review of an agency action for a failure to act, relying on the
Administrative Procedure Act ("APA ") laws, where petitioner has a
right to request a review?

2) Can an agency completely disregard an entire set of laws designed
by Congress to protect from discrimination? Or should the court
compel agency action that is unreasonable withheld?

Can a petitioner file a petition for review of an agency action for a failure to act, relying on the Administrative Procedure Act (APA)