Guthrie v. Hegseth

District Court, District of Columbia·Decided August 5, 2026·No. Civil Action No. 2025-2179·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JACOB GUTHRIE, Plaintiff,

v. Case No. 25-cv-2179-MJS

PETE HEGSETH, et al., Secretary of Defense

Defendants.

MEMORANDUM OPINION AND ORDER Plaintiff Jacob Guthrie was all set to join the U.S. Air Force. But when he disclosed his prior weight-loss surgery, he was barred from enlistment under a Department of Defense (“DoD”) policy that disqualifies from military service anyone with a history of bariatric surgery. Suing the Secretary of Defense and other military leaders in their official capacities, Guthrie challenges that policy (and the surrounding decision-making as to his disqualification) as a violation of his Fifth Amendment equal protection rights and the Administrative Procedure Act (“APA”). Defendants move to dismiss in part, seeking dismissal of the constitutional claim only. (See ECF No. 19.) Agreeing that Guthrie fails to state a cognizable equal protection claim because he fails to plausibly allege the absence of any rational basis for the challenged policy, the Court GRANTS the motion.

BACKGROUND

The Court derives the following facts, accepted as true for present purposes, from the operative complaint. Joyner v. Morrison & Foerster, LLP, 140 F.4th 523, 530 (D.C. Cir. 2025).

DoD applies certain medical standards to applicants for military service and enlisted service members. Relevant here, one of those standards categorically disqualifies individuals from

military enlistment if they have undergone bariatric surgery. 1 See Dep’t of Def. Instruction (“DoDI”) 6130.03, Vol. 1, Medical Standards for Military Service: Appointment, Enlistment, or Induction, § 6.12(b)(5) at 25 (Feb. 3, 2026), https://perma.cc/4HM6-6JCK. As a branch of the military, the U.S. Air Force adheres to and implements that policy and thus bars applicants with a medical history of bariatric surgery. See Dep’t of the Air Force Manual (“DAFMAN”) 48-123, Medical Examination and Standards, § 3.2 at 25 (Dec. 8, 2020), https://perma.cc/5MQY-4QXE. According to Guthrie’s complaint, DoD’s rationale behind the policy is that bariatric procedures cause “permanent anatomical changes that require strict dietary compliance, thereby potentially interfering with operational deployability.” (See ECF No. 2 (“Am. Compl.”) ¶¶ 13, 61.)

In 2022, Guthrie underwent a successful laparoscopic sleeve gastrectomy—a form of bariatric surgery. (Id. ¶ 16.) About a year later, he attempted to join the Air Force. (Id. ¶¶ 16–17.) Guthrie passed the required screening, “including aptitude screening, moral background checks, and fitness metrics” (id. ¶ 17), but when he disclosed his history of bariatric surgery, the Air Force recruiter advised that he was disqualified from service by the policy. (Id. ¶ 18.) Undeterred, Guthrie sought medical waivers—three times over—but each time, his waiver was denied. (Id. ¶¶ 19, 55.) According to Guthrie, the only thing preventing him from enlisting is the DoD policy’s categorical bar on military recruits who have undergone bariatric surgery. (See id. ¶ 53 (“Guthrie has been categorically barred from enlistment solely due to his surgical history[.]”); id. ¶ 64 (same).)

So, Guthrie filed this lawsuit against the Secretary of Defense, the Secretary of the Air Force, and the Air Force’s Commander of Air Education and Training Command. Guthrie alleges that: (1) the policy violates his equal protection rights guaranteed by the Fifth Amendment’s Due

1 In simple terms, “[g]astric bypass and other types of weight-loss surgery—also called bariatric or metabolic surgery—involve making changes to [the] digestive system to help [a person] lose weight.” Bariatric surgery, Mayo Clinic (July 5, 2024), https://perma.cc/FAP2-Z8DU.

Process Clause (Count I); (2) the policy runs afoul of the APA because it is arbitrary, capricious, contrary to law, and unsupported by substantial evidence (Count II); and (3) the Air Force’s handling of Guthrie’s requested medical waivers from the policy was arbitrary, capricious, and otherwise improper under the APA (Count III). (Am. Compl. ¶¶ 75–99.)

Invoking Rule 12(b)(6), Defendants now move to dismiss Guthrie’s equal protection claim in Count I for failure to state a claim. (ECF No. 19 (“Mot.”).) The matter is fully briefed and ripe for decision. (See ECF No. 20 (“Opp’n”); ECF No. 26 (“Reply”).)

LEGAL STANDARD

On a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), courts ask whether the complaint “contain[s] sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “[F]acial plausibility” means the complaint’s facts must allow for a “reasonable inference that the defendant is liable for the misconduct alleged.” Id. Under Rule 12(b)(6), courts construe the complaint “in favor of the plaintiff” and afford the plaintiff “the benefit of all inferences that can be derived from the facts alleged.” Hettinga v. United States, 677 F.3d 471, 476 (D.C. Cir. 2012) (quoting Schuler v. United States, 617 F.2d 605, 608 (D.C. Cir. 1979)). But courts need not accept as true “legal conclusions couched as factual allegations.” Nurriddin v. Bolden, 818 F.3d 751, 756 (D.C. Cir. 2016). Further, mere “recitals of the [legal] elements of a cause of action” cannot “suffice” to forestall a motion to dismiss. L. Xia v. Tillerson, 865 F.3d 643, 650 (D.C. Cir. 2017) (quoting Iqbal, 556 U.S. at 678).

ANALYSIS

Broadly speaking, “[t]he Fifth Amendment’s guarantee of equal protection requires state actors to treat similarly situated persons alike.” XP Vehicles, Inc. v. Dep’t of Energy, 118 F. Supp.

3d 38, 75 (D.D.C. 2015) (citation and quotation marks omitted). 2 “The first step in analyzing” a Fifth Amendment equal protection claim “is to determine the proper level of scrutiny.” Hedgepeth ex rel. Hedgepeth v. Wash. Metro. Area Transit Auth., 386 F.3d 1148, 1153 (D.C. Cir. 2004). Governmental classifications that implicate a suspect or quasi-suspect class—i.e., race, alienage, national origin, or gender—trigger some form of heightened scrutiny, see City of Cleburne, Tex. v. Cleburne Living Ctr., 473 U.S. 432, 440 (1985), whereas classifications that do not “proceed[] along suspect lines [or] infringe[] fundamental constitutional rights” are subject only to rational basis review, Mark v. Republic of the Sudan, 77 F.4th 892, 897 (D.C. Cir. 2023) (quoting Hettinga, 677 F.3d at 478). To pass muster “[u]nder rational basis review, a classification need only be rationally related to a legitimate governmental interest.” Hedgepeth, 386 F.3d at 1153 (citing Kimel v. Florida Bd. of Regents, 528 U.S. 62, 83–84 (2000)). These principles generally apply to “governmental classifications that affect some groups of citizens differently than others.” Enquist v. Oregon Dep’t of Agr., 553 U.S. 591, 601 (2008) (citation and quotation marks omitted). But the Supreme Court has held that “even if the plaintiff has not alleged class-based discrimination,” whether as against a protected class or not, “an equal protection claim can in some circumstances be sustained” through a “class of one” claim. Id.; see also Vill. Of Willowbrook v. Olech, 528 U.S. 562, 564–65 (2000). To properly state a so-called “class of one” claim, a plaintiff must show they were “intentionally treated differently from others similarly situated and that there is no rational basis for the difference in treatment.” Olech, 528 U.S. at 564.

2 Although the Fifth Amendment does not expressly include an equal protection guarantee, courts have long recognized that “the Fifth Amendment’s Due Process Clause incorporates equal protection principles” that apply to the federal government. Hill v. United States Dep’t of Interior, 151 F.4th 420, 435 (D.C. Cir. 2025).

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