American Small Business League v. Small Business Administration

CourtDistrict Court, N.D. California
DecidedAugust 6, 2024
Docket3:20-cv-04619
StatusUnknown

This text of American Small Business League v. Small Business Administration (American Small Business League v. Small Business Administration) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Small Business League v. Small Business Administration, (N.D. Cal. 2024).

Opinion

1 2 3 4 IN THE UNITED STATES DISTRICT COURT 5 FOR THE NORTHERN DISTRICT OF CALIFORNIA 6 7 AMERICAN SMALL BUSINESS Case No. 20-cv-04619-MMC LEAGUE, 8 Plaintiff, ORDER GRANTING IN PART 9 PLAINTIFF’S MOTION FOR v. ATTORNEY’S FEES AND COSTS 10 SMALL BUSINESS ADMINISTRATION, Re: Dkt. No. 74 11 Defendant. 12 13 Before the Court is plaintiff American Small Business League’s (“ASBL”) “Motion 14 for Attorney’s Fees and Costs,” filed March 27, 2023. Defendant United States Small 15 Business Administration (“SBA”) has filed opposition, to which ASBL has replied. The 16 motion came on for hearing on July 19, 2024. Aaron R. Field and Karl Olson of Cannata 17 O’Toole & Olson LLP appeared on behalf of ASBL. James Bickford of the United States 18 Department of Justice Civil Division appeared on behalf of the SBA. 19 Having read and considered the parties’ respective written submissions, and 20 having considered the oral arguments made by counsel, the Court, hereby rules as 21 follows. 22 BACKGROUND 23 Plaintiff ASBL is a California organization with the “core mission” of “promot[ing] 24 and advocat[ing] for the interests of small business concerns through public policy 25 change.” (See Complaint (“Compl.” ¶ 6, Doc. No. 1.) During the coronavirus pandemic, 26 Congress passed the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act, 27 under which “the SBA was tasked with administering a new loan program, the PPP 1 businesses.” (See id. ¶ 10.) ASBL submitted several FOIA requests pertaining to the 2 SBA’s administration of such funds. (See id. ¶ 18.) 3 A. FOIA Requests at Issue 4 On April 9, 2020, ASBL submitted a Freedom of Information Act (“FOIA”) Request 5 to the SBA, whereby it sought documents “regarding advisory committees” that have 6 worked with the SBA (“Initial Request”). (See id. ¶ 18.)1 7 On April 16, 2020, ASBL “amended [the initial] FOIA request” (“Amended 8 Request”) to seek: (1) “[r]ecords relating to any committee, advisory group, or panel the 9 SBA has established to administer the $350 billion CARES Act response to the 10 coronavirus pandemic” (“CARES Committee Records”); (2) “[a] list of names and 11 bio[graphies] of members who serve on any of the active SBA advisory committees” 12 (“Committee Biographies”); (3) “[d]ata showing how the appropriated funds from the 13 CARES Act were distributed through [the] PPP program [sic]” (“PPP Loan Data”); (4) 14 “[a]ny communication between the White House, SBA, and Congress regarding requests 15 for additional funding for the CARES Act and PPP Program [sic]” (“Interbranch 16 Communications”). (See id. ¶ 18.) 17 1 The Initial Request reads as follows: 18 All documents indicating, containing, or relating to any committee, advisory 19 panels or groups that currently work or have worked with the Small Business Administration (SBA) between January 1, 2014 and present 20 All documents indicating containing, or relating to the names of each 21 individual on each committee, advisory panel, or group that currently works or has worked with the SBA between January 1, 2014 and present 22 All records of communications (written, oral, or electronic) containing, relating 23 to, or based on any advisory panels or groups that currently work or have worked with the SBA between January 1, 2016 and the present 24 All records of communications (written, oral, or electronic) containing, relating 25 to, or based on the names of each individual on each committee, advisory panel, or group that currently works or has worked with the SBA between 26 January 1, 2014 and present 27 (See Decl. of Eric Benderson in Supp. of Def.’s Opp’n. to Mot. for Fees (“Benderson 1 On July 10, 2020, ASBL filed the instant action seeking declaratory and injunctive 2 relief under FOIA. (See id. ¶¶ 27–34.) 3 B. Procedural History and Washington Post Litigation 4 On May 12, 2020, the Washington Post filed suit in the District of Columbia, 5 seeking “[a]ll public data on every loan made through the [PPP].” (See Def.’s Opp’n. to 6 Pl.’s Mot. for Fees (“Def.’s Opp’n.”) at 2:1–5, Doc. No. 75 and WP Co. LLC v. SBA, No. 7 20-cv-1240 (D.D.C. filed May 12, 2020) (“Washington Post case”).) On July 6, 2020, SBA 8 released loan-level data for PPP loans except for the precise amounts of loans of 9 $150,000 or more, and the names and addresses of borrowers of less than $150,000, 10 which it claimed were exempt. (See id. at 2:6–14.) The parties in the Washington Post 11 case litigated the claimed exemption (see id. at 2:15–21), and, on November 5, 2020, the 12 district court in that action ordered the SBA to produce the withheld information, see WP 13 Co. LLC v. SBA, 502 F.Supp.3d 1 (D.D.C. 2020). 14 On September 4, 2020, ASBL moved for summary judgment (see Pl.’s Mot. for 15 Summ. J., Doc. No. 20), and, on October 26, 2020, this Court, in light of the overlap 16 between ASBL’s request and the requests at issue in the Washington Post case, stayed 17 the instant action pending a decision in the Washington Post case. (See Order, Doc. No. 18 35.) On November 20, 2020, after the ruling in the Washington Post case, this Court lifted 19 the stay. (See Order, Doc. No. 38.) 20 C. SBA’s Productions 21 1. Records Responsive to the Initial Request 22 Within approximately a month after the Initial Request was filed, the SBA informed 23 ASBL that such request returned “250,000 potentially responsive emails” and was 24 “unduly burdensome.” (See Decl. of Eric Benderson in Supp. of Def.’s Opp’n. to Mot. for 25 Fees (“Benderson Decl.”) Ex. E, November 2020 Letter from ASBL to SBA, Doc. No. 76- 26 5 (documenting history of communications between the parties).) On May 22, 2020, 27 ASBL identified its “priorit[y]” documents responsive to its request as those related to the 1 the SBA agreed to produce those documents. (See id.) 2 In January 2021, ASBL agreed to “narrow” what remained of the Initial Request to 3 “documents relating to ASBL, its president Lloyd Chapman, Raytheon Technologies 4 Corporation . . . Secretary of Defense Lloyd Austin, and the Advisory Committee on 5 Veterans’ Affairs” (“the Non-RRFB Documents”). (See Pl.’s Mot. for Fees (“Pl.’s Mot.”) at 6 4:11–15 citing Decl. of Karl Olson in Supp. of Pl.’s Mot. (“Olson Decl.”), Ex. D, January 7 27, 2021, Bickford Email to Olson Doc. No. 74-1 at 36, 39.) On August 20, 2021, the 8 Court ordered SBA to produce the remaining documents responsive to the narrowed 9 Initial Request by December 17, 2021. (See Minute Order, Doc. No. 51.) 10 2. Records Responsive to the Amended Request 11 a. CARES Committee Records 12 The SBA informed ASBL that it “ha[d] not established any committee . . . to 13 administer the CARES Act,” and, consequently, no records pertaining to this category 14 were produced. (See Benderson Decl. Ex. E at 2.) 15 b. Committee Biographies 16 The SBA produced the Committee Biographies on May 18, 2020, prior to the 17 commencement of litigation. (See id.) 18 c. PPP Loan Data 19 The SBA initially published PPP loan data on its website on July 6, 2020 (see 20 Benderson Decl. Ex. C, Manger Washington Post Declaration ¶ 88, Doc. No. 76-3), and, 21 pursuant to the Washington Post order, published the initially withheld data on December 22 1, 2020 (see Joint Status Report of December 12, 2020 at 3:6–8, Doc. No. 39). 23 Thereafter, ASBL contended it was seeking, by the third part of its Amended Request, 24 additional data regarding the PPP loans (see id. at 5–6); upon examination prompted 25 thereby, the “SBA determined that it possessed such data” (see Benderson Decl. ¶ 10), 26 and, on January 25, 2021, published it (see id. ¶ 11, Ex. F, Benderson Washington Post 27 Declaration, Doc. No. 73-6). 1 d. Interbranch Communications 2 On January 22, 2021, the SBA completed its initial production of records 3 responsive to ASBL’s request for interbranch communications (see Benderson Decl. Ex. 4 G, January 22, 2021 SBA Letter to ASBL, Doc. No. 76-7), which production comprised 5 nine pages of documents (see Olson Decl.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Davy v. Central Intelligence Agency
550 F.3d 1155 (D.C. Circuit, 2008)
Welch v. Metropolitan Life Ins. Co.
480 F.3d 942 (Ninth Circuit, 2007)
Kevin Poulsen v. Department of Defense
994 F.3d 1046 (Ninth Circuit, 2021)
Transgender Law Center v. Ice
46 F.4th 771 (Ninth Circuit, 2022)
Angelo v. Armstrong World Industries, Inc.
11 F.3d 957 (Tenth Circuit, 1993)
A.W. v. Humble Independent School District
25 F. Supp. 3d 973 (S.D. Texas, 2014)
New York Times Co. v. Central Intelligence Agency
251 F. Supp. 3d 710 (S.D. New York, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
American Small Business League v. Small Business Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-small-business-league-v-small-business-administration-cand-2024.