American Near East Refugee Aid v. United States Agency for International Development

CourtDistrict Court, District of Columbia
DecidedMay 24, 2024
DocketCivil Action No. 2021-3184
StatusPublished

This text of American Near East Refugee Aid v. United States Agency for International Development (American Near East Refugee Aid v. United States Agency for International Development) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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American Near East Refugee Aid v. United States Agency for International Development, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

AMERICAN NEAR EAST REFUGEE AID,

Plaintiff, Case No. 21-cv-03184 (CRC) v.

UNITED STATES AGENCY FOR INTERNATIONAL DEVELOPMENT,

Defendant.

MEMORANDUM OPINION AND ORDER

This opinion marks the third time the Court has weighed in on a dispute between

American Near East Refugee Aid (“Anera”), an organization that provides humanitarian

assistance to refugees in the Middle East, and the United States Agency for International

Development (“USAID”). As detailed in previous opinions, the parties agreed in 2013 that

USAID would fund Anera—and, through Anera, local sub-contractors—to build water and

sanitation infrastructure in the West Bank and Gaza. In 2018, however, USAID decided that

Anera could no longer use the agency’s funds to pay one of the chosen sub-contractors for work

performed on a West Bank water system. Anera challenged the agency’s decision through the

administrative appeals process and then filed this suit under the Administrative Procedure Act

(“APA”).

In its first foray into this case, the Court denied without prejudice USAID’s motion to

dismiss Anera’s original complaint. In its second, the Court granted leave for Anera to file an

amended complaint, finding the amendment would not be futile because it established that

subject matter jurisdiction lay in this Court, rather than the Court of Federal Claims. Now, the

Court turns to the agency’s contention that the amended complaint fails to state a claim. Finding that the complaint does not adequately allege that the agency’s conduct was “unwarranted by the

facts” in violation of 5 U.S.C. § 706(2)(F), the Court will grant USAID’s motion to dismiss as to

that claim. But the same result does not hold for Anera’s claim that the agency’s decision was

arbitrary and capricious. Because the present record does not establish that USAID’s decision

was backed by substantial evidence and Anera has plausibly alleged that such evidence does not

exist, the Court finds dismissal of Anera’s arbitrary-and-capricious claim premature.

I. Background

As the Court has already detailed the factual background in its previous opinions, it will

pick up where the second opinion left off. See Am. Near E. Refugee Aid v. U.S. Agency for

Int’l Dev. (“Anera I”), No. 21-cv-3184 (CRC), 2023 WL 10669678, at *1–2 (D.D.C. Mar. 21,

2023); Am. Near E. Refugee Aid v. U.S. Agency for Int’l Dev. (“Anera II”), No. 21-cv-03184

(CRC), 2023 WL 10669682, at *1–3 (D.D.C. Nov. 28, 2023). In that opinion, the Court decided

it had subject matter jurisdiction over the amended complaint and gave USAID another

opportunity to file a motion to dismiss for failure to state a claim. Anera II, 2023 WL 10669682,

at *3. USAID did so and now argues that both of the claims presented in Anera’s amended

complaint fall short. Though Anera included the two claims under the umbrella of a single

count, Anera’s complaint lists two sub-counts that invoke separate prongs of 5 U.S.C. § 706,

which governs the scope of judicial review under the APA. Anera claims USAID’s action was

both “arbitrary, capricious, and otherwise not in accordance with the law” under § 706(2)(A) and

“unwarranted by the facts” under § 706(2)(F). Am. Compl. ¶¶ 100–01 (citing 5 U.S.C. §§

706(2)(A), (F)). USAID moves to dismiss both sub-counts under Federal Rule of Civil

Procedure 12(b)(6).

2 II. Legal Standard

Dismissal under Rule 12(b)(6) is appropriate when the complaint “fail[s] to state a claim

upon which relief can be granted.” Fed. R. Civ. P. 12(b)(6). In reviewing a motion to dismiss

for failure to state a claim, the Court must “accept all the well-pleaded factual allegations of the

complaint as true and draw all reasonable inferences from those allegations in the plaintiff’s

favor.” Banneker Ventures, LLC v. Graham, 798 F.3d 1119, 1129 (D.C. Cir. 2015). “[D]etailed

factual allegations” are not necessary, but the complaint must provide “more than labels and

conclusions” or “a formulaic recitation of the elements of cause of action.” Bell Atl. Corp. v.

Twombly, 550 U.S. 544, 555 (2007). Accordingly, “[t]o survive a motion to dismiss, a

complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is

plausible on its face.” Banneker Ventures, 798 F.3d at 1129 (cleaned up) (quoting Ashcroft v.

Iqbal, 556 U.S. 662, 678 (2009)).

When evaluating a Rule 12(b)(6) motion, “a court generally does not consider matters

beyond the pleadings.” R.J. Reynolds Tobacco Co. v. Dep’t of Agric., 130 F. Supp. 3d 356, 369

(D.D.C. 2015). The court may, however, “consider a document that a complaint specifically

references,” Banneker Ventures, 798 F.3d at 1133, or “documents upon which the plaintiff’s

complaint necessarily relies,” Ward v. D.C. Dep’t of Youth Rehab. Servs., 768 F. Supp. 2d 117,

119–20 (D.D.C. 2011) (cleaned up).

III. Analysis

The present motion—a motion to dismiss APA claims on 12(b)(6) grounds—is an

unusual one as “[s]ummary judgment is [ordinarily] the proper mechanism for deciding, as a

matter of law, whether an agency action is supported by the administrative record and consistent

with the APA standard of review.” R.J. Reynolds Tobacco Co., 130 F. Supp. 3d at 369

3 (alteration in original) (cleaned up). But that is not to say a 12(b)(6) motion is never appropriate

in the APA context. The D.C. Circuit has instructed that district courts can “reach[] the merits at

the 12(b)(6) stage” if the issue “on review is a question of law, and only a question of law.”

Marshall Cty. Health Care Auth. v. Shalala, 988 F.2d 1221, 1226 (D.C. Cir. 1993). And, of

course, a 12(b)(6) motion is also the proper mechanism to evaluate whether the factual

allegations in the complaint state an APA violation. See, e.g., Voinche v. Obama, 428 F. App’x

2, 4–5 (D.C. Cir. 2011) (per curiam) (affirming the district court’s dismissal of APA claims

because the complaint “fail[ed] to state a claim upon which relief c[ould] be granted”).

USAID’s motion invokes both grounds for dismissal. The agency maintains that, as a

matter of law, its conduct was not arbitrary and capricious or unwarranted by the facts and that,

in any event, Anera has not adequately pled violations of either prong of § 706. See generally

Renewed Mot. Dismiss at 10 (“Anera has not and cannot plausibly allege that USAID’s

decision[s]” were “arbitrary and capricious” under § 706(2)(A) or “unwarranted by the facts”

under § 706(2)(F).). The Court agrees with USAID as to Anera’s § 706(2)(F) claim; the

organization failed to allege that the agency’s action was “unwarranted by the facts” in violation

of the APA. But the Court finds review of the administrative record necessary to resolve

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