Sheila Armstrong v. Mich. Bureau of Servs. for Blind Persons, 969 F.3d 337

The Randolph–Sheppard Act requires priority for state‑licensed blind vendors to operate vending services on federal property; states license vendors and administer set‑asides for rest‑stop vending routes.
Sheila Armstrong, a Michigan licensed vendor, lost a 2010 bid for the Grayling (I‑75) rest‑stop vending route; she alleged Michigan miscalculated her "operator points."
A Michigan ALJ ruled for Armstrong and the State later awarded her a different vending route; Armstrong then requested federal arbitration seeking immediate assignment of Grayling plus nearly $250,000 in damages for lost profits.
An arbitration panel found she was wrongfully denied the Grayling location and ordered immediate assignment, but denied damages as too speculative.
Both parties litigated parts of the arbitration award in federal district court; the court upheld the arbitration award and dismissed Armstrong’s § 1983 claims. Michigan subsequently assigned Armstrong the Grayling license.
On appeal the Sixth Circuit reviewed (1) whether the arbitration decision was arbitrary or capricious under the APA and (2) whether Armstrong could pursue damages under § 1983 to enforce the Randolph–Sheppard Act.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the arbitration panel’s denial of damages was arbitrary or capricious under the APA	Arbitration panel found wrongful denial of location, so it should be able to identify and award lost‑profits damages	Panel reasonably found damages too speculative given variables and lack of reliable earnings evidence	Court upheld arbitration; denial of damages not arbitrary or capricious
Whether Armstrong may sue state officials under 42 U.S.C. § 1983 to obtain damages for Randolph–Sheppard violations	§ 1983 permits enforcement of federal statutory rights; no adequate alternative remedy early in the process	Randolph–Sheppard provides a detailed administrative/arbitral/judicial enforcement scheme that precludes additional § 1983 relief	§ 1983 unavailable to obtain relief beyond what Randolph–Sheppard provides; claim dismissed

Motor Vehicle Mfrs. Ass'n of U.S. v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29 (arbitrary and capricious standard for agency action)
FCC v. Fox Television Stations, Inc., 556 U.S. 502 (agencies must provide a reasoned explanation for decisions)
Gonzaga Univ. v. Doe, 536 U.S. 273 (statute must unambiguously confer individual rights to be enforceable under § 1983)
City of Rancho Palos Verdes v. Abrams, 544 U.S. 113 (existence of statutory remedial scheme weighs against implying § 1983 remedy)
Blessing v. Freestone, 520 U.S. 329 (comprehensive enforcement scheme can preclude § 1983)
Smith v. Robinson, 468 U.S. 992 (administrative remedial scheme may bar parallel § 1983 claims)
Middlesex Cnty. Sewerage Auth. v. Nat'l Sea Clammers Ass'n, 453 U.S. 1 (express statutory remedy suggests Congress intended to preclude other remedies)
Pennhurst State Sch. & Hosp. v. Halderman, 465 U.S. 89 (requirement that Spending Clause legislation clearly waive state immunity)
Tenn. Dep't of Hum. Servs. v. U.S. Dep't of Educ., 979 F.2d 1162 (DOE role in oversight and arbitration under Randolph‑Sheppard)
Boler v. Earley, 865 F.3d 391 (recognition that § 1983 enforces constitutional claims; distinguishes statutory enforcement)