Lea v. Secretary of Agriculture, Thomas Vilsack

CourtDistrict Court, M.D. Tennessee
DecidedFebruary 10, 2025
Docket3:23-cv-00340
StatusUnknown

This text of Lea v. Secretary of Agriculture, Thomas Vilsack (Lea v. Secretary of Agriculture, Thomas Vilsack) is published on Counsel Stack Legal Research, covering District Court, M.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lea v. Secretary of Agriculture, Thomas Vilsack, (M.D. Tenn. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF TENNESSEE AT NASHVILLE

COREY LEA ) ) v. ) Case No. 3:23-cv-00340 ) ACTING SECRETARY OF AGRICULTURE, ) GARY WASHINGTON, et al. )

TO: Honorable Aleta A. Trauger, United States District Judge

R E P O R T A N D R E C O M E N D A T I O N

By Order entered April 17, 2023 (Docket Entry No. 6), this pro se case was referred to the Magistrate Judge for pretrial proceedings under 28 U.S.C. § 636(b)(1)(A) and (B), Rule 72 of the Federal Rules of Civil Procedure, and the Local Rules of Court. Pending before the Court is the motion to dismiss (Docket Entry No. 61) filed by Defendants Thomas Vilsack, Secretary of Agriculture, and the United States Department of Agriculture. Since the filing of the motion, then Secretary of Agriculture Vilsack was replaced by Acting Secretary of Agriculture Gary Washington, whom the Court ordered substituted as the party defendant pursuant to Fed. R. Civ. P. 25(d). (Docket Entry No. 80.) Plaintiff opposes the motion. For the reasons set out below, the undersigned respectfully recommends that the motion be granted. I. BACKGROUND Corey Lea (“Plaintiff”) is a Black “rancher and entrepreneur” who resides in Arrington, Tennessee. During approximately the last 15 years, he has brought numerous lawsuits against the United States Department of Agriculture (“USDA”) and its officials based on alleged wrongdoings by the USDA. In addition to the instant lawsuit, he has filed three other lawsuits against the USDA in this Court.1 Generally, Plaintiff has not been successful in his lawsuits. On April 13, 2023, he initiated this lawsuit by filing a pro se complaint against Thomas Vilsack (“Vilsack”), the Secretary of Agriculture at the time,2 and the USDA. Complaint (Docket

Entry No. 1). Seeking various forms of relief, Plaintiff’s complaint raises five claims based on allegations of racial discrimination in the manner in which the USDA had, or had not, resolved administrative claims and discrimination complaints brought by Black farmers and in the manner in which the USDA and then-Secretary Vilsack administered and implemented Section 1006 of the American Rescue Plan Act (“ARPA”), Pub. L. No. 117-2, 135 Stat. 4 (2021), and Sections 22006 and 22007 of the Inflation Reduction Act (“IRA”), Pub. L. 117-169, 136 Stat. 1818 (2022). The ARPA and IRA are two multi-trillion dollar stimulus bills passed by Congress in the wake of the COVID-19 pandemic and the resulting economic downturn. Each bill contains provisions authorizing the USDA to provide financial and other assistance in the agricultural sector of the economy. Section 1006 of ARPA, as subsequently amended by Section 22007 the IRA

(“Section 22007”), establishes a variety of programs and funding to assist farmers, ranchers, or forest landowners. One of those programs provides that: In addition to amounts otherwise available, there is appropriated to the Secretary of Agriculture for fiscal year 2022, to remain available until September 30, 2031, out of any money in the Treasury not otherwise appropriated, $2,200,000,000 for a program to provide financial assistance, including the cost of any financial assistance, to farmers, ranchers, or forest landowners determined to have experienced discrimination prior to January 1, 2021, in Department of Agriculture

1 Lea v. Farmers Nat’l Bank, et al., No. 3:15-cv-00595 (M.D. Tenn 2015); Lea v. United States Dep’t of Agric., et al., 3:16-cv-00735 (M.D. Tenn 2016); Lea, et al v. United States Dep’t of Agric., et al., 3:21-cv-00468 (M.D. Tenn. 2021). 2 As noted above, by order entered January 31, 2025, the Court substituted the acting Secretary of Agriculture for Vislack. (Docket Entry No. 80.) farm lending programs, under which the amount of financial assistance provided to a recipient may be not more than $500,000, as determined to be appropriate based on any consequences experienced from the discrimination, which program shall be administered through 1 or more qualified nongovernmental entities selected by the Secretary subject to standards set and enforced by the Secretary.

Section 1006(e) of the ARPA (as amended by Section 22007 of the IRA) (“Section 1006(e)”). The IRA provides for additional financial relief for distressed farm loan borrowers in Section 2006, which provides: In addition to amounts otherwise available, there is appropriated to the Secretary for fiscal year 2022, out of amounts in the Treasury not otherwise appropriated, $3,100,000,000, to remain available until September 30, 2031, to provide payments to, for the cost of loans or loan modifications for, or to carry out section 331(b)(4) of the Consolidated Farm and Rural Development Act (7 U.S.C. 1981(b)(4)) with respect to distressed borrowers of direct or guaranteed loans administered by the Farm Service Agency under subtitle A, B, or C of that Act (7 U.S.C. 1922 through 1970). In carrying out this section, the Secretary shall provide relief to those borrowers whose agricultural operations are at financial risk as expeditiously as possible, as determined by the Secretary.

Section 22006 of the IRA (“Section 22006”). In response to Plaintiff’s complaint, the original Defendants sought dismissal of the lawsuit. (Docket Entry No. 22.) In support of their motion, Defendants pointed out that much of Plaintiff’s complaint was simply a recasting of claims and allegations related to the foreclosure of his farm in Kentucky and a subsequent administrative discrimination complaint that he filed, claims and allegations that were extensively litigated by Plaintiff in other cases in this District and in the United States District Court for the Western District of Kentucky. (Id.) Defendants specifically noted that the Western District of Kentucky, in Lea v. U.S. Dep’t of Agric., 2014 WL 2435903, at *1 (W.D. Ky. May 29, 2014), enjoined Plaintiff from filing any additional civil lawsuits in the Western District of Kentucky that alleged or asserted factual or legal claims based upon or arising out of the Kentucky foreclosure. Defendants further noted that this Court had twice dismissed lawsuits brought Plaintiff against Vilsack and the USDA in the Middle District of Tennessee that were premised in some manner upon claims related to the Kentucky foreclosure and the administrative discrimination complaint that he filed. See Lea v. USDA, et al., No. 16- 00735, 2018 WL 721381 (M.D.Tenn. Feb. 6, 2018); aff'd, No. 18-5535, 2019 WL 2246555 (6th Cir. Feb. 5, 2019); Lea, et al. v. Vilsack, et al., No. 3:21-CV-00468, 2023 WL 1141833 (M.D.Tenn.

Jan. 30, 2023), aff'd sub nom. Lea v. U.S. Dep't of Agric., 2024 WL 841436 (6th Cir. Feb. 28, 2024). Prior to resolution of the motion to dismiss, Plaintiff made multiple filings that sought to add new claims, allegations, defendants, and requests for relief to this lawsuit, and that, in some instances, seemed to contradict his original pleading. Construing these filings as requests by Plaintiff to amend his complaint, the Court determined that an amended complaint from Plaintiff was necessary to clarify his case, and directed Plaintiff to file “a comprehensive, amended complaint that encompasses the entirety of his allegations and that clearly and distinctly sets out his claims.” February 12, 2024 Order (Docket Entry No. 42) at 4.

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Lea v. Secretary of Agriculture, Thomas Vilsack, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lea-v-secretary-of-agriculture-thomas-vilsack-tnmd-2025.