Cantu v. United States
2012 WL 6137032
D.C. Cir.2012Background
- Plaintiffs are Hispanic farmers alleging USDA discrimination in farm benefit programs against race/ethnicity/gender.
- The action challenges the defendants' administrative claims process for Hispanic farmers as compared to Pigford/Keepseagle settlements for African-American and Native American farmers.
- Pigford I and Keepseagle settled via class actions with administrative claims processes; Pigford II and Keepseagle involved later settlements.
- Garcia and Love pursued class-action denials; the defendants did not offer Rule 23 class settlements in Garcia/Love but created an administrative process for Hispanics.
- The plaintiffs allege the Hispanic process imposes additional factual/documentary requirements not required of others, creating unequal treatment.
- Court previously stayed proceedings as unripe; after finalizing the process, plaintiffs amended the complaint and moved to dismiss for lack of jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do plaintiffs have standing to challenge the process? | Plaintiffs allege injury from unequal treatment in settlement process. | Participation is optional; no injury-in-fact from a non-mandatory process. | Standing fails due to lack of redressability. |
| Does redressability exist to grant requested relief? | Court should invalidate process or compel equivalent settlements for Hispanics. | Courts cannot compel government settlements or guarantee identical terms. | Redressability lacking; relief could not redress injury. |
Key Cases Cited
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (U.S. 1992) (standing requires injury, causation, redressability)
- Newdow v. Roberts, 603 F.3d 1002 (D.C.Cir. 2010) (redressability essential to standing)
- Jacobs v. Barr, 959 F.2d 313 (D.C.Cir. 1992) (two remedial alternatives for equal protection injury)
- Heckler v. Mathews, 465 U.S. 728 (U.S. 1984) (remedies in equal protection context)
- Swan v. Clinton, 100 F.3d 973 (D.C.Cir. 1996) (redressability and injunctive relief considerations)
- Gevas v. Ghosh, 566 F.3d 717 (7th Cir. 2009) (judicial power to compel settlement restrictions)