Bean v. Vilsack
Civil Action No. 2017-0140
| D.D.C. | Sep 11, 2017Background
- Plaintiff Robert Oneal Bean, an African American farmer, borrowed FSA funds in 2001 to buy 120 acres and fell behind on payments after a 2011 cancer diagnosis.
- FSA accelerated the loan and pursued foreclosure; Bean submitted medical records and later sought loan servicing/rescheduling in 2016–2017.
- FSA informed Bean he lost the opportunity for loan servicing because he did not submit a required application within the 60-day deadline after receipt of application materials; Bean alleges he does not recall receiving those materials.
- Bean sued USDA/Secretary under the APA and claimed violations related to the 1999 Agricultural Appropriations Act and the 2008 Farm Bill (invoking Pigford-related relief and disability discrimination theories).
- The USDA moved to dismiss under Rule 12(b)(6); the court considered whether Bean pleaded claims under Pigford/2008 Farm Bill, ADA, Rehabilitation Act, ECOA, and the APA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Claim under Pigford / 2008 Farm Bill entitlement | Bean asserts his dispute arises from Pigford and that he's entitled to late-claim relief | USDA: Pigford inapplicable because claims arise from post-1996 conduct | Dismissed: Pigford/2008 Farm Bill not applicable; Bean's facts fall outside Pigford class period |
| Disability-discrimination claim via 1999 Appropriations Act (§741) / ADA | Bean contends §741 implicates ADA protections; seeks relief for disability discrimination | USDA: ADA does not apply to federal agencies/claims against the federal government | Dismissed: ADA inapplicable to federal agencies; §741 does not itself create a private ADA cause of action |
| Rehabilitation Act claim (section 504) | Bean argues he was denied loan servicing because of disability | USDA: Agency followed regulations; denial based on missed deadline | Dismissed: Complaint fails to plead discrimination "solely by reason" of disability; alleges denial due to untimely application |
| ECOA claim (credit discrimination) | Bean invokes §741 and suggests discrimination in credit servicing | USDA: No facts alleging discrimination on protected ECOA grounds (race, etc.) | Dismissed: No factual allegations that denial was based on ECOA-protected characteristics |
| APA arbitrary-and-capricious challenge to loan-servicing denial | Bean alleges denial was arbitrary because he did not receive application materials and thus could not timely apply | USDA: Denial followed FSA loan-servicing regulations requiring timely response to application materials | Denied as to APA: Court finds Bean plausibly alleged failure to receive materials; survives 12(b)(6) and may proceed to review of administrative record |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard requiring plausible claims)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plausibility pleading framework)
- Pigford v. Glickman, 185 F.R.D. 82 (D.D.C. 1999) (class action and consent decree resolving historical USDA race discrimination claims)
- In re Black Farmers Discrimination Litigation, 856 F. Supp. 2d 1 (D.D.C. 2011) (Pigford II settlement and late-claim procedures)
- Motor Vehicle Mfrs. Ass'n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29 (agency must articulate rational connection between facts and choice)
- Citizens to Preserve Overton Park, Inc. v. Volpe, 401 U.S. 402 (agency action review standard under APA)
- Grinstead v. United States, 122 F.3d 1071 (agency foreclosure decisions not arbitrary where statutes/regulations applied)
- Johnson v. City of Shelby, 135 S. Ct. 346 (pleading need not identify the precise statutory basis to survive initial pleading scrutiny)