Astria Health v. United States Small Business Administration

CourtDistrict Court, E.D. Washington
DecidedMarch 9, 2022
Docket1:20-cv-03098
StatusUnknown

This text of Astria Health v. United States Small Business Administration (Astria Health v. United States Small Business Administration) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Astria Health v. United States Small Business Administration, (E.D. Wash. 2022).

Opinion

1 FILED IN THE U.S. DISTRICT COURT 2 EASTERN DISTRICT OF WASHINGTON Mar 09, 2022 3 SEAN F. MCAVOY, CLERK 4

5 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 6

7 ASTRIA HEALTH, et al., NO: 1:20-CV-3098-RMP 8 Appellees/Counter-Appellants, ORDER DISMISSING APPEALS AS 9 EQUITABLY MOOT v.

10 UNITED STATES SMALL 11 BUSINESS ADMINISTRATION; and JOVITA CARRANZA, in her 12 official capacity as Administrator for the United States Small Business 13 Administration,

14 Appellants/Counter-Appellees. 15

16 BEFORE THE COURT are the consolidated appeals of Appellants and 17 Counter-Appellees U.S. Small Business Administration (the “SBA”) et al. 18 (“Appellants”) and by Counter-Appellants and Appellees Astria Health et al.1 19

1 Astria Health (“Astria”), SHC Medical Center-Toppenish, doing business as 20 Astria Toppenish Hospital (“Toppenish”), both Washington nonprofit corporations 21 under 26 U.S.C. § 501(c)(3); Yakima HMA Home Health LLC, a Washington 1 (“Appellees” or “Debtors”) from a final order of the U.S. Bankruptcy Court for the 2 Eastern District of Washington (“Bankruptcy Court”). Having reviewed all briefing, 3 the relevant portions of the Bankruptcy Court record, the supplemental authority 4 submitted by the Appellants, and the relevant law, the Court is fully informed. See

5 ECF Nos. 11, 13, 14, 15, 18, 24, 25, 26, and 28. Although the parties requested oral 6 argument in their initial briefs, the Court finds that oral argument would not be 7 helpful in light of the parties’ thorough briefing of the matter, as well as ample

8 discussion of the legal issues by federal courts throughout the United States, as 9 discussed below. See LCivR 7(i)(3)(B)(iii). 10 BACKGROUND 11 Bankruptcy Case and Adversary Proceeding

12 The Debtors are tax-exempt non-profit corporations, primarily healthcare 13 facilities, pursuing Chapter 11 bankruptcy that filed an adversary proceeding against 14 Appellants SBA et al. in the Bankruptcy Court. The Debtors sought in their

15 Adversary Complaint to enjoin the SBA Administrator, and Banner Bank acting 16 through the SBA Administrator, from considering the Debtors’ involvement in 17

corporation doing business as Astria Home Health & Hospice-Yakima (“Astria 18 Home Health”), and affiliated entities Glacier Canyon, LLC; Kitchen and Bath 19 Furnishing, LLC; Oxbow Summit, LLC; SHC Holdco, LLC; Sunnyside Community Hospital Association; Sunnyside Community Hospital Home Medical 20 Supply, LLC; Sunnyside Home Health; Sunnyside Professional Services, LLC; and Yakima Home Care Holdings, LLC. 21 1 bankruptcy in deciding the Debtors’ applications for PPP funds, and refrain from 2 conditioning the approval of any PPP funds to the Debtors contingent on the Debtors 3 “not being ‘presently involved in bankruptcy.’” ECF No. 13-1 at 10. In addition, 4 the Debtors sought declaratory relief for allegedly unlawful agency action in

5 violation of section 706(a) of the Administrative Procedure Act (“APA”), 5 U.S.C. § 6 701 et seq., and alleged discriminatory treatment by the SBA Administrator in 7 violation of Section 525(a) of the Bankruptcy Code. Id. at 10, 30, 33. The Debtors

8 also sought damages and an award of their costs and attorneys’ fees against the 9 United States generally, or against the SBA Administrator specifically, pursuant to 10 the Equal Access to Justice Act, 28 U.S.C. § 2412. Id. at 11. 11 SBA, CARES Act, and PPP

12 Congress created the SBA, and vested management of the SBA in a single 13 Administrator, to carry out the imperatives of the Small Business Act of 1953, 14 codified as amended at 15 U.S.C. §§ 631−57. Congress imbued the SBA with

15 “broad powers to accomplish [its] important objectives, including that of lending 16 money to small businesses whenever they could not get necessary loans on 17 reasonable terms from private lenders.” SBA v. McClellan, 364 U.S. 446, 447

18 (1960) (footnote omitted). 19 Toward that end, “[t]he SBA is ‘empowered’ to make loans to any qualified 20 small business, either directly or through financial institutions on an immediate or 21 deferred (guarantee) basis.” Agaña v. SBA (In re Archbishop of Agaña), Nos. 19- 1 00010, 20-00002, 2021 Bankr. LEXIS 460, at *7 (Bankr. D. Guam Feb. 23, 2021) 2 (citing 15 U.S.C. § 636(a)). The Small Business Act’s loan program is set forth at 3 15 U.S.C. § 636(a) and generally is referred to as the Section 7(a) program. By 4 statute, the SBA must ensure that its loans are “of such sound value or so secured as

5 reasonably to assure repayment[.]” 15 U.S.C. § 636(a)(6). 6 To address developments related to the novel coronavirus (COVID-19) 7 pandemic, Congress enacted the Coronavirus Aid, Relief, and Economic Stimulus

8 Act (“CARES Act”), Public Law 116-136, on March 27, 2020. One of the relief 9 measures provided by the CARES Act is the Paycheck Protection Program (“PPP”), 10 which provides for loans to eligible small businesses through the long-standing 11 Section 7(a) loan program. CARES Act § 1102(a)(2), 134 Stat. 281; 15 U.S.C. §

12 636(a)(36). The PPP loans are funded by various financial institutions, guaranteed 13 by the SBA, and may be forgiven if the borrower demonstrates that the loan was 14 used according to the PPP program’s terms, such as using the loan for payroll, rent,

15 utilities, mortgage interest, in which cases the loan may be fully forgiven. See Brady 16 v. United States, SBA (In re Specialty's Café & Bakery, Inc.), Nos. 20-40954 RLE, 17 20-4039, 2022 Bankr. LEXIS 269, at *4 (Bankr. N.D. Cal. Feb. 2, 2022).

18 To implement the PPP, Congress required the SBA Administrator to issue, 19 within fifteen days after the enactment of the CARES Act, “regulations to carry out 20 [title I of the Act] and the amendments made by this title without regard to the notice 21 requirements under [5 U.S.C. § 553(b)].” CARES Act § 1114, 134 Stat. 281. The 1 United States District Court for the District of New Mexico thoroughly outlined the 2 SBA’s relevant rulemaking following the CARES Act: 3 Pursuant to this mandate, in April 2020, the SBA Administrator promulgated four interim rules about the PPP. See Business Loan 4 Program Temporary Changes; Paycheck Protection Program, 85 Fed. Reg. 20,811 (Apr. 15. 2020) (to be codified at 13 C.F.R. pt. 120) 5 (hereinafter “First Rule”); Business Loan Program Temporary Changes; Paycheck Protection Program, 85 Fed. Reg. 20,817 (Apr. 15, 6 2020) (to be codified at 13 C.F.R. pt. 120) (hereinafter "Second Rule"); Business Loan Program Temporary Changes; Paycheck Protection 7 Program—Additional Eligibility Criteria & Requirements for Certain Pledges of Loans, 85 Fed. Reg. 21,747 (Apr. 20, 2020) (to be codified 8 at 13 C.F.R. pt. 120) (hereinafter “Third Rule”); Fourth Rule, 85 Fed. Reg. 23,450. 9 Among other things, the First Rule modifies several general Section 10 7(a) loan eligibility criteria as to PPP loans and reduced lenders' underwriting obligations. See First Rule, 85 Fed. Reg.

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

Related

Small Business Administration v. McClellan
364 U.S. 446 (Supreme Court, 1960)
Barton v. Clancy
632 F.3d 9 (First Circuit, 2011)
In Re Roberts Farms, Inc.
652 F.2d 793 (Ninth Circuit, 1981)
Blausey v. U.S. Trustee
552 F.3d 1124 (Ninth Circuit, 2009)
Diamond Enters., Ltd. v. Younessi (In Re Younessi)
601 B.R. 815 (Ninth Circuit, 2019)
East Bay Sanctuary Covenant v. William Barr
994 F.3d 962 (Ninth Circuit, 2020)
Voorhles v. Bridgeford
10 Ky. 26 (Court of Appeals of Kentucky, 1820)
Alliance for Wild Rockies v. Cottrell
632 F.3d 1127 (Ninth Circuit, 2011)
Samson Energy Resources Co. v. Semcrude, L.P.
728 F.3d 314 (Third Circuit, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Astria Health v. United States Small Business Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/astria-health-v-united-states-small-business-administration-waed-2022.