Mae Capital, LLC v. Small Business Administration

CourtDistrict Court, District of Columbia
DecidedMarch 26, 2025
DocketCivil Action No. 2022-0776
StatusPublished

This text of Mae Capital, LLC v. Small Business Administration (Mae Capital, LLC v. Small Business Administration) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mae Capital, LLC v. Small Business Administration, (D.D.C. 2025).

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.

Page 1 of 17 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.

Page 2 of 17 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

Page 3 of 17 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

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Camp v. Pitts
411 U.S. 138 (Supreme Court, 1973)
Mathews v. Eldridge
424 U.S. 319 (Supreme Court, 1976)
Florida Power & Light Co. v. Lorion
470 U.S. 729 (Supreme Court, 1985)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Amer Bioscience Inc v. Thompson, Tommy G.
269 F.3d 1077 (D.C. Circuit, 2001)
American Wildlands v. Kempthorne
530 F.3d 991 (D.C. Circuit, 2008)
Thomas B. Roelofs v. Secretary of the Air Force
628 F.2d 594 (D.C. Circuit, 1980)
Blue Ocean Institute v. Gutierrez
503 F. Supp. 2d 366 (District of Columbia, 2007)
Hugh Kaufman v. Thomas Perez
745 F.3d 521 (D.C. Circuit, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Mae Capital, LLC v. Small Business Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mae-capital-llc-v-small-business-administration-dcd-2025.