National Association of Blind Merchants v. The Army & Air Force Exchange Service

CourtDistrict Court, N.D. Texas
DecidedJanuary 28, 2025
Docket3:24-cv-00277
StatusUnknown

This text of National Association of Blind Merchants v. The Army & Air Force Exchange Service (National Association of Blind Merchants v. The Army & Air Force Exchange Service) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
National Association of Blind Merchants v. The Army & Air Force Exchange Service, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

NATIONAL ASSOCIATION OF § BLIND MERCHANTS, et al., § § Plaintiffs, § § v. § No. 3:24-CV-277-L § THE ARMY & AIR FORCE § E XCHANGE SERVICE, et al., § § Defendants. §

FINDINGS, CONCLUSIONS, AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE On July 1, 2024, Defendants moved to dismiss this action pursuant to Fed. R. Civ. P. 12(b)(1) based on lack of subject matter jurisdiction or, alternatively, for failure to state a claim under Fed. R. Civ. P. 12(b)(6). (Dkt. No. 15 (“Mot.”).) Plaintiffs filed a response in opposition on August 12, 2024, (Dkt. No. 20 (“Resp.”)), and Defendants filed their reply on August 26, 2024, (Dkt. No. 22 (“Reply”)). U.S. District Judge Sam A. Lindsay referred the motion to a magistrate judge for a hearing, if necessary, and to submit proposed findings and recommendations for disposition of the motion. (Dkt. No. 17.) By Special Order 3-354, the motion was transferred and reassigned to the undersigned magistrate judge on August 23, 2024. (Dkt. No. 21.) Upon consideration of the briefs and relevant caselaw, the undersigned recommends that the District Judge GRANT Defendants’ motion and DISMISS this action. I. BACKGROUND Enacted in 1936, the Randolph-Sheppard Act (“RSA”) creates a program

whereby blind individuals can be licensed to operate vending facilities on federal properties and given priority in operating such facilities. See 20 U.S.C. § 107(b). Under the RSA, the Secretary of Education is assigned responsibility for promulgating regulations and designating an agency in each state to administer the program in that state. See Patten v. District of Columbia, 9 F.4th 921, 923 (D.C. Cir.

2021). The administering entity—referred to by statute as the “state licensing agency” (“SLA”)—is responsible for licensing blind vendors, finding appropriate placements for them, and monitoring vendors’ performance for compliance with program requirements. Id. One of the features of the RSA is a prescribed grievance procedure. The Act

creates two avenues for addressing grievances. First, “[a]ny blind licensee who is dissatisfied with any action arising from the operation or administration of the vending facility program may submit to a[n SLA] a request for a full evidentiary hearing, which shall be provided by such agency[.]” 20 U.S.C. § 107d-1(a). If the blind licensee is dissatisfied with the SLA’s action or the decision resulting from that

hearing, he may file a complaint with the Secretary of Education, “who shall convene a panel to arbitrate the dispute[.]” Id. A second grievance procedure enables SLAs to challenge a federal agency’s failure to comply with the RSA and implementing regulations. See 20 U.S.C. § 107d- 1(b). If an SLA believes a federal agency is failing to fulfill its obligations, the SLA may file a complaint with the Secretary of Education, and the Secretary is then obligated to convene an arbitration panel to decide the matter. Id. The statute provides that, in the event an arbitration panel determines that a federal agency’s

actions violate the RSA, the agency head “shall cause such acts or practices to be terminated promptly and shall take such other action as may be necessary to carry out the decision of the panel.” Id. § 107d-2(b)(2)(C). The results of both grievance procedures are subject to appeal and judicial review as a final agency action under the Administrative Procedures Act (“APA”), 5 U.S.C. § 704. See 20 U.S.C. § 107d-

2(a). Plaintiff National Association of Blind Merchants is a Section 501(c)(3) organization comprised of blind vendors licensed under the RSA. (See Dkt. No. 2 (“Compl.”) ¶ 9.) Individual Plaintiffs Alicia Morris, Edgar Mendez, Shannon

Shelton, and Steven Hickey are blind vendors who reside in various states and operate a vending facility at a base, hospital, or other installation maintained by the Department of Defense (“DoD”). (See Compl. ¶¶ 10-13.) Plaintiffs bring this action against Defendant Army & Air Force Exchange Service (“AAFES”)—a “non-appropriated fund instrumentality” of the United States

that provides goods and services on Army and Air Force installations—and individual Defendants in their official capacities as director of AAFES, Secretary of the Army, Secretary of the Air Force, and Secretary of Defense. (Compl. ¶¶ 14-18.) Plaintiffs allege that AAFES refuses to comply with its obligations under the RSA, including by refusing to give priority to blind vendors at DoD installations and by modifying or expanding vending facilities without giving proper notice and required opportunities to blind vendors. According to Plaintiffs, AAFES’s refusal to comply with its obligations under the RSA emanate from an apparent belief that certain DoD

policies guiding AAFES supersede obligations it has under the RSA. (See Compl. ¶¶ 2-8.) Plaintiffs allege specific consequences they contend violate or potentially violate the RSA as a result of AAFES policies: Mr. Shelton is at risk of having his vending machines reduced at Tyndall Air Force Base; AAFES removed some of Mr. Hickey’s vending machines at a community hospital on Fort Carson; AAFES

precluded Ms. Morris from providing vending services on Fort Gordon; and Mr. Mendez has been deprived of opportunities at the Corpus Christi Army Depot based on AAFES’s expansion of vending facilities without giving priority to blind vendors. (Compl. ¶¶ 64, 71, 77, 79-81.) Defendants move to dismiss the action because Plaintiffs have not grieved

their claims under the procedures established by the RSA or, alternatively, because Plaintiffs do not have standing to bring the challenges presented here because a favorable decision is unlikely to provide redress. Plaintiffs contend first that their claims are not subject to the mandatory grievance procedures under the RSA. They argue alternatively that, even if they were supposed to exhaust administrative

remedies, the Court should excuse them from that requirement because the administrative process was inadequate and futile and would yield absurd results. Plaintiffs also contend that they have standing to maintain their challenge. (Resp. at 18-21.) II. LEGAL STANDARDS Defendants move to dismiss under Fed. R. Civ. P. 12(b)(1). A motion to

dismiss under Rule 12(b)(1) challenges a federal court’s jurisdiction to adjudicate the claim before it. See Fed. R. Civ. P. 12(b)(1). Being courts of limited jurisdiction, a federal court must have jurisdiction conferred by statute vesting the power to adjudicate claims. See Texas v. Travis Cnty., Texas, 910 F.3d 809, 811 (5th Cir. 2018). When a Rule 12(b)(1) motion is made in conjunction with other motions to dismiss,

it should first address the jurisdictional attack. Ramming v.

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