Ginger Mae, Inc. v. Cisneros

946 F. Supp. 441, 1996 U.S. Dist. LEXIS 18200, 1996 WL 705597
CourtDistrict Court, M.D. Louisiana
DecidedDecember 5, 1996
DocketCivil Action No. 95-678-A
StatusPublished
Cited by1 cases

This text of 946 F. Supp. 441 (Ginger Mae, Inc. v. Cisneros) is published on Counsel Stack Legal Research, covering District Court, M.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ginger Mae, Inc. v. Cisneros, 946 F. Supp. 441, 1996 U.S. Dist. LEXIS 18200, 1996 WL 705597 (M.D. La. 1996).

Opinion

RULING ON CROSS MOTIONS FOR SUMMARY JUDGMENT

JOHN V. PARKER, Chief Judge.

This matter is before the court on a motion by defendants, Henry Cisneros, as Secretary, [443]*443and the United States Department of Housing and Urban Development for summary judgment. Pending also are motions by plaintiff, Ginger Mae, to supplement the administrative record and for summary judgment. All motions are opposed. Jurisdiction is based on 28 U.S.C. § 1881 and the Administrative Procedure Act (APA), 5 U.S.C. § 701 et seq.1

Background

The following facts are undisputed. The Government National Mortgage Association, commonly known as GNMA or Ginnie Mae, is a corporation of the United States within the Department of Housing and Urban Development (“HUD”). Ginnie Mae administers a mortgage-backed securities program in which it authorizes certain qualifying private entities, typically mortgage companies and banks, to issue securities backed by pools of federally insured or guaranteed home mortgage loans. Ginnie Mae guarantees the timely payment of the “pass-through” principal and interest payments to the holders of these mortgage-backed securities.

Plaintiff, Ginger Mae, a subsidiary of United Companies Financial Corporation, also administers a mortgage-backed securities program. Ginger Mae purchases “B” and “C” home mortgage loans made to borrowers with troubled credit histories and pools these loans for sale on the securities market. Plaintiff calls this.program the “Good Neighbor Reinvestment Mortgage Assistance Loan Program” or “Ginger Mae.” Ginger Mae, through its affiliate United Companies Lending Corporation, obtained a federal registration for the service mark “GINGER MAE” for mortgage lending services on October 18, 1994.

On October 10, 1994, plaintiff submitted an application to HUD seeking approval to do business as a “HUD-FHA Investing Mortgagee.” An investing mortgagee is generally defined as an organization that may purchase, hold or sell federally insured mortgages and has lawful authority to purchase federally insured mortgages in its own name. Defendants denied plaintiff’s application for approval as an investing mortgagee.

On May 5, 1995, plaintiff exercised its right to a final review of the denial by appealing to the Deputy Assistant Secretary for Single Family Housing. HUD denied plaintiffs appeal on June 8, 1995. Pursuant to the Administrative Procedure Act (APA), plaintiff seeks from this court a declaratory judgment that HUD’s denial of plaintiffs application was arbitrary, capricious, and in violation of law. Plaintiff also seeks an injunction requiring the defendants to approve plaintiff as an investing mortgagee.

Arguments

Defendants argue that its disapproval of Ginger Mae as an investing mortgagee was rationally based upon its conclusion that “Ginger Mae” could be confused with “Ginnie Mae” and that the name suggests an association with the federal program that does not exist. Defendants also argue that the agency denied plaintiffs application because use of the name “Ginger Mae” by plaintiff violates 18 U.S.C. § 709.2 Defendants contend there are no genuine issues of material fact because the documents contained in the administrative record speak for themselves and provide a factual basis for the court’s review of this matter.

Plaintiff contends that defendants did not deny plaintiffs application on the basis that the name Ginger Mae is confusingly similar [444]*444to Ginnie Mae or because the name suggests an association with the federal government, but only on the basis of its violation of 18 U.S.C. § 709. Plaintiff argues, therefore, the court must refrain from giving weight to these “post hoc” justifications that do not reflect the actual considerations deliberated upon by HUD when deciding to reject Ginger Mae’s application. Additionally, plaintiff argues that the administrative record contains no facts to support defendants purported reasons for denying the application. Accordingly, the plaintiff argues that the defendants acted arbitrarily or capriciously in its denial of plaintiff’s application.

Law

Summary judgment is the proper mechanism for review of agency decisions. Girling Health Care, Inc. v. Shalala, 85 F.3d 211 (5th Cir.1996).

The explanation for this lies in the relationship between the summary judgment standard of no genuine issue as to any material fact and the nature of judicial review of administrative decisions.... The administrative agency is the fact finder. Judicial review has the function of determining whether the administrative action is consistent with law—that and no more. Id. at 215.

Both sides agree that the proper scope of review is provided by Section 706(2) of the Administrative Procedure Act (APA), 5 U.S.C. § 706(2). Under this section, a district court should not reverse the agency’s decision unless it is arbitrary, capricious, an abuse of discretion or not in accordance with law.

The duty of a court reviewing agency action under the “arbitrary and capricious” standard is to ascertain whether the agency examined the relevant data and articulated a satisfactory explanation for its action including a “rational connection between the facts found and the choice made.” Motor Vehicle Manufacturers Association of the United States, Inc. v. State Farm Mutual Automobile Insurance Company, 463 U.S. 29, 42, 103 S.Ct. 2856, 2866, 77 L.Ed.2d 443 (1983). The court may not substitute its judgment for that of the agency. Id.

Because the central focus of the arbitrary and capricious standard is on the rationality of the agency’s decision making, rather than its actual decision, it is well-established that an agency’s action must be upheld if at all, on the basis articulated by the agency itself. United States v. Garner, 767 F.2d 104, 116 (5th Cir.1985). Post hoc explanations are simply an inadequate basis for the exercise of substantive review of an administrative decision. Id. at 117.

Discussion

As a preliminary matter, the court must rule on plaintiff’s motion to supplement the administrative record. Plaintiff contends that defendants’ position in a separate proceeding before the United States Patent and Trademark Office is “diametrically opposed” to the position taken in matters before this court. More specifically, plaintiff contends that in matters before this court, defendants assert that the administrative record eon-tains sufficient facts to show confusion, but in matters before the Patent Office, defendants concede that the administrative record is not sufficient.

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Related

Ginger Mae Inc v. Cisneros
124 F.3d 192 (Fifth Circuit, 1997)

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Bluebook (online)
946 F. Supp. 441, 1996 U.S. Dist. LEXIS 18200, 1996 WL 705597, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ginger-mae-inc-v-cisneros-lamd-1996.