Essintial Enterprise Solutions, LLC v. The United States Small Business Administration

CourtDistrict Court, M.D. Pennsylvania
DecidedDecember 30, 2024
Docket1:22-cv-01507
StatusUnknown

This text of Essintial Enterprise Solutions, LLC v. The United States Small Business Administration (Essintial Enterprise Solutions, LLC v. The United States Small Business Administration) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Essintial Enterprise Solutions, LLC v. The United States Small Business Administration, (M.D. Pa. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA ESSINTIAL ENTERPRISE : No. 1:22cv1507 SOLUTIONS, LLC, : Plaintiff : (Judge Munley) V. :

THE UNITED STATES SMALL : BUSINESS ADMINISTRATION; : ISABELLA CASILLAS GUZMAN, : in her official capacity as : Administrator of the Small : Business Administration; JANET : YELLEN, in her official capacity : as United States Secretary of : Treasury; and THE UNITED : STATES OF AMERICA, : Defendants :

MEMORANDUM During the nationwide economic crisis brought on by the coronavirus pandemic, Congress issued a mandate to the Defendant United States Small Business Administration ("SBA") under the CARES Act’ to make hundreds of billions of dollars in Paycheck Protection Program ("PPP") loans available to American small businesses. See 15 U.S.C. § 636(a)(36); (Doc. 34, Defs.’ Stmt.

' The Coronavirus Aid, Relief, and Economic Security Act, Pub. L. No. 116-136, 134 Stat. 281 (2020).

Mat. Fact J 1).2 Loans granted under the PPP may be forgiven if their proceeds were used for certain purposes. 15 U.S.C. § 9005(b). Plaintiff Essintial Enterprise Solutions, Inc. received a PPP loan and then sought forgiveness. Although the SBA did forgive part of the loan, it denied the request for total forgiveness. Plaintiff filed the instant complaint seeking review of the SBA's decision to deny complete forgiveness. Before the court for disposition are cross- motions for summary judgment. The parties have briefed their respective positions, and the matter is ripe for adjudication. Background Plaintiff Essintial applied to receive a PPP loan in the amount of $7,028,000.00 from Berkshire Bank ("the Lender"). (Doc. 26, Pl.’s SOF at § 1). The Lender approved the Loan application on April 10, 2020, and at the time, the SBA made no objection. (Id. 3). The Lender funded the Loan in the amount applied for on April 20, 2020. (Id. 4). Plaintiff alleges that it used the proceeds of the Loan to protect the continued employment of its employees. (Id. J] 5). On January 6, 2021, plaintiff applied for full forgiveness of the Loan. (Id. J 6). The Lender approved the forgiveness application for full forgiveness of the Loan, and in turn, submitted it to the SBA for approval on January 18, 2021. (ld.

2 The court will cite to portions of the Statements of Material Fact which the parties appear to agree upon.

q 7). In its Final Decision on the application for forgiveness, the SBA found the plaintiff ineligible for full forgiveness of the Loan and that only $3,469, 174.00 of the Loan would be forgiven. (Id. J 8). The basis for the lower amount of forgiveness was that the original Loan included compensation to independent contractors which the SBA concluded could not be substantiated as an eligible payroll cost. (Id. 49). Plaintiff appealed the SBA’s final decision through the United States SBA Office of Hearings and Appeals (“OHA”). During this appeal, the SBA increased the amount of forgiveness by $233,837.60, thus bringing the total amount of forgiveness to $3,703,011.60 and an unforgiven amount of $3,325,788.40. (Id. 11). Ultimately, the OHA denied plaintiffs appeal of the SBA’s final decision and affirmed the SBA’s final decision. (Doc. 3-2, Compl. Exh. 4, Decision of Clifford Sturek, Administrative Judge). Plaintiff filed a Petition for Reconsideration with the OHA. (Doc. 3-3, Compl. Exh. 5). The OHA denied the Petition for Reconsideration. (Doc. 3-4, Compl. Exh. 6). Thirty days after the plaintiff's receipt of the Reconsideration Decision, it became the final decision of the SBA which entitled plaintiff to file the instant action in this court for review of the SBA’s decision. See 13 C.F.R. § 134.1211(c) and (g). The plaintiff's complaint contains the following counts:

Count | — Claim for Declaratory and Injunctive Relief on the basis that the defendants acted without authority in defining payroll costs in a manner inconsistent with the CARES Act; Count Il — Claim for Declaratory Relief regarding the retroactive application of the SBA's Interim Final Rule; Count Ill — Application for Temporary Restraining Order and Temporary or Permanent Injunction; and Count IV — Claim for Attorney's Fees under the Equal Access to Justice Act. At the case management conference, the court set deadlines for the disclosure of the final administrative record and objections thereto and for the filing of motions for summary judgment by each party. (Doc. 22, Case Management Order). In due course both parties moved for summary judgment and briefed their respective positions. Since the briefing of the summary judgment motions, the plaintiff has filed three notices of supplemental authority (Docs. 38, 41, and 42), bringing the case to its present posture.°

sone Honorable Jennifer P. Wilson transferred this case to the undersigned on November 7,

Jurisdiction This court has federal question jurisdiction pursuant 28 U.S.C. § 1331 because this case arises under the Constitution, laws, or treaties of the United States, namely the CARES Act and the Administrative Procedures Act, 5 U.S.C. §§ 551 et seq. Standard of Review Granting summary judgment is proper “‘if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if

any, show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law.’” See Knabe v. Boury Corp., 114 F.3d 407, 410 n.4 (3d Cir. 1997) (quoting FED. R. Civ. P. 56(c)). “[T]his standard provides that the mere existence of some alleged factual dispute between the parties will not defeat an otherwise properly supported motion for

summary judgment; the requirement is that there be no genuine issue of materia fact.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247-48 (1986) (emphasis in original). In considering a motion for summary judgment, the court must examine the facts in the light most favorable to the party opposing the motion. Int'l Raw Materials, Ltd. v. Stauffer Chem. Co., 898 F.2d 946, 949 (3d Cir. 1990). The burden is on the moving party to demonstrate that the evidence is such that a

reasonable jury could not return a verdict for the non-moving party. Angerson, 477 U.S. at 248. A fact is material when it might affect the outcome of the suit under the governing law. Id. Where the non-moving party will bear the burden o

proof at trial, the party moving for summary judgment may meet its burden by showing that the evidentiary materials of record, if reduced to admissible evidence, would be insufficient to carry the non-movant's burden of proof at trial. Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986). Once the moving party satisfies its burden, the burden shifts to the nonmoving party, who must go beyond its pleadings, and designate specific facts by the use of affidavits, depositions, admissions, or answers to interrogatories showing that there is a genuine issue for trial. Id. at 324. At issue with the instant summary judgment motions is a decision from the SBA, a federal agency.

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Essintial Enterprise Solutions, LLC v. The United States Small Business Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/essintial-enterprise-solutions-llc-v-the-united-states-small-business-pamd-2024.