Mae Capital, LLC v. Small Business Administration

District Court, District of Columbia·Decided March 26, 2025·No. Civil Action No. 2022-0776·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

MAE CAPITAL LLC, Plaintiff,

v.

Civil Action No. 22-cv-776 (TSC)

SMALL BUSINESS ADMINISTRATION, et al.,

Defendants.

MEMORANDUM OPINION

Plaintiff Mae Capital (“Mae Capital”)—a talent representation company that represents country music performing artists—sued the United States Small Business Administration and its Administrator, Isabella Casillas Guzman (collectively, “SBA”) pursuant to the Administrative Procedure Act (“APA”), 5 U.S.C. § 706 and the Declaratory Judgment Act, 28 U.S.C. §§ 2201 and 2202. Am. Compl. ¶¶ 1, 15, ECF No. 11. Mae Capital sued the SBA after it was denied funding from the “Shuttered Venue Operator Grant” (“SVOG”) program—an emergency relief grant created for operators of shuttered venues during the COVID-19 pandemic. Id. ¶¶ 1, 3. Both parties have moved for summary judgment. Mae Capital Mot. for Summ. J. (“Mae Capital MSJ”), ECF No. 25; SBA Mot. for Summ. J. (“SBA MSJ”), ECF No. 39. Mae Capital also asks the court to complete the administrative record, or in the alternative, to supplement the record with extra-record evidence. Mot. to Complete Admin. R. (“Record Mot.”), ECF No. 23. For the reasons below, Mae Capital’s motion for summary judgment will be DENIED, the SBA’s cross-motion for summary judgment will be GRANTED, and Mae Capital’s motion to complete the administrative record will be DENIED.

I. BACKGROUND

A. Legal and Statutory Background During the COVID-19 pandemic, Congress established the Shuttered Venue Operators Grant (“SVOG”) Program and set aside $15 billion to support shuttered venue operators. Economic Aid to Hard-Hit Businesses, Nonprofits, and Venues Act, Pub. L. 116-260 §§ 323(d)(1)(H), 324, 134 Stat. 1993, 2021, 2022 (2020) (codified at 15 U.S.C. § 9009a). The statute lists several categories of entities that are potentially eligible for a grant, including talent representatives. 15 U.S.C. § 9009a(a)(1)(A). To qualify as a talent representative under the SVOG program, at least 70% of an entity’s operations must involve the representation or management of artists or entertainers who engage in qualifying artistic performances. See 15 U.S.C. § 9009a(a)(10).

To establish eligibility for an SVOG award, an entity must have had “gross earned revenue during the first, second, third, or, . . . fourth quarter in 2020 that demonstrates not less than a 25 percent reduction from [its] gross earned revenue . . . during the same quarter in 2019.” § 9009a(a)(1)(A)(i)(II). An eligible entity receives an initial grant award of 45 percent of its 2019 gross earned revenue. 15 U.S.C. § 9009a(c)(1)(A)(i)(I). SVOG applicants are required to submit certain financial documents to demonstrate eligibility for a grant, including the Internal Revenue Service “IRS” Form 4506-T, which allows the SBA to verify an entity’s tax information and claimed revenue with the IRS. See Administration Record, (“AR”), ECF No. 47 at 19, 439.

B. Mae Capital’s SVOG Award Application On April 26, 2021, Mae Capital applied for a SVOG grant of $738,671.85, claiming eligibility as a talent representative. Am. Compl. ¶ 55; AR at 4–6. The dispute here centers on whether Mae Capital provided sufficient documentation to support its eligibility for a SVOG grant.

First, the parties disagree on whether Mae Capital submitted an acceptable IRS Form 4506-

T. Mae Capital MSJ at 10; SBA MSJ at 7. As part of its initial application, Mae Capital submitted a Form 4506-T, see AR at 4–10, 112, 138, but the form was not submitted in the required PDF format so the SBA could not verify Mae Capital’s tax information. AR at 138–39; SBA MSJ at 7. On June 2, 2021, the SBA informed Mae Capital that “[t]here was a problem processing [its] 4506- T” and directed it to “upload another SVOG-specified 4506-T in pdf format.” AR at 139, 149. Mae Capital re-submitted the Form 4506-T. Mae Capital MSJ at 3. But on July 21, 2021, the SBA again told Mae Capital that its Form 4506-T “cannot be processed as submitted” because Mae Capital’s now third submitted Form 4506-T “was not consistent with the SVOG-specific IRS Form 4506-T guidance.” AR at 136; SBA MSJ at 7. The SBA once again directed Mae Capital to upload a corrected 4506-T, which it did that same day. See AR at 136; Mae Capital MSJ at 3.

On August 12, 2021, the SBA again informed Mae Capital that it could not obtain its tax transcripts from the IRS using its submitted Form 4506-T. AR at 114. This time, the SBA told Mae Capital that if it wished to continue the application process, it needed to submit an alternative verification document. Id. The SBA listed four alternative tax and financial documents that Mae Capital could submit in lieu of the Form 4506-T. Id.

Second, the parties disagree on whether Mae Capital’s alternative verification document complied with the SBA’s instructions, which specified that alternative verification documents, such as a copy of a federal tax return, must include a “letter from a CPA certifying that the attached tax returns were prepared and submitted to the IRS by that CPA on a certain date.” Id. (cleaned up). In response to the SBA’s August 12, 2021, communication, Mae Capital uploaded a Schedule C federal tax return and a letter from Mae Capital’s CPA. AR at 77-111. The letter stated, “To Whom

It May Concern: I prepared [Mae Capital Founder] Brian McElyea’s 2019 tax return, and it was filed on July 16, 2020.” AR at 78.

On August 24, 2021, Mae Capital’s application was denied via the SBA portal. See AR at 4. It is undisputed that this denial did not give a stated reason for the denial. The next day, Mae Capital appealed the SBA’s decision and was again denied on November 8, 2021. AR at 1–3. In affirming its denial, the SBA explained that Mae Capital’s “application was declined, at least in part,” because it (1) is currently suspended or disbarred from contracting with the federal government1, (2) did not meet the principal business activity standard, and (3) did not meet one or more eligibility criteria as a talent representative. See AR at 18–19. The SBA’s published FAQs inform applicants that determinations on appeal are final agency decisions, that applicants “are encouraged to carefully review [] the . . . list of acceptable documents to ensure they upload all relevant documents during the appeals process,” and that there is no secondary appeals process. See ECF No. 41-1, Ex. A, Shuttered Venue Operators Grants FAQ (“SVOG FAQ”) No. 233, Oct. 21, 2021.

C. Procedural Posture On March 21, 2022, Mae Capital filed this action. Compl., ECF No. 1. On May 25, 2022, the SBA rescinded its November 8, 2021, decision and decided to re-evaluate Mae Capital’s application. AR at 437. On August 17, 2022, the SBA once again denied Mae Capital’s application, citing its “failure to submit all the requested documents and [also] the existing discrepancies in its records.” AR at 439. The letter stated that because Mae Capital did not submit the required documents to resolve discrepancies in its records, or to provide the SBA with a

1 The SBA later conceded that Mae Capital was mistakenly classified as being suspended or disbarred from contracting with the federal government and thus did not include this reason in its later denial letter on August 17, 2022. AR at 439.

properly completed Form 4506-T, the SBA could not find that it was eligible for an SVOG award. Id. This August 17, 2022, decision was a final agency action. AR at 441.

On November 15, 2022, Mae Capital filed an Amended Complaint, alleging that the SBA’s decision was arbitrary and capricious (Count I), contrary to law (Count II), and unsupported by substantial evidence (Count III). Mae Capital also alleges that it was deprived of due process and equal protection in violation of the Fifth Amendment to the U.S. Constitution (Count IV). ECF No. 11.

II. LEGAL STANDARD

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