Roland Ramos-Cardona v. United States Department of Education, et al.

CourtDistrict Court, E.D. Pennsylvania
DecidedMarch 26, 2026
Docket5:24-cv-04073
StatusUnknown

This text of Roland Ramos-Cardona v. United States Department of Education, et al. (Roland Ramos-Cardona v. United States Department of Education, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Roland Ramos-Cardona v. United States Department of Education, et al., (E.D. Pa. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA ROLAND RAMOS-CARDONA : CIVIL ACTION : : v. : NO. 24-4073 : UNITED STATES : DEPARTMENT OF : EDUCATION, et al. : : MEMORANDUM OPINION Henry, J. March 26, 2026 Pending before the Court are the cross-Motions for Summary Judgment by Plaintiff Roland Ramos-Cardona (ECF No. 30) and Defendants United States Department of Education (the “Department”) and Miguel Cardona, in his official capacity as Secretary of Education (ECF No. 29). Also pending is Defendants’ Motion to Strike the Waterman Affidavit (ECF No. 31). This case arises out of the Department’s decision to deny Plaintiff’s request for Public Service Loan Forgiveness (“PSLF”). Plaintiff is employed as a trial attorney in the office of Scott F. Waterman, Chapter 13 Standing Trustee. He applied for PSLF after completing what he believed were 120 qualifying payments toward his student loans. The Department rejected his application, finding that Waterman’s office was a for-profit entity. Plaintiff is now asking the Court to review the Department’s decision under the Administrative Procedures Act (“APA”). The case is before me on the parties’ cross-Motions for Summary Judgment and the Department’s Motion to Strike the Affidavit of Scott F. Waterman. Because I find that the Department’s decision denying PSLF application was arbitrary and capricious, I will grant Plaintiff’s Motion for Summary Judgment in part1 and deny Defendants’ Motion for Summary Judgment. And because I reach the conclusion that the decision was arbitrary and capricious on grounds other than those supported by the Waterman Affidavit, I will grant Defendants’ Motion to Strike the Waterman Affidavit.

I. Background The PSLF program requires the Department to forgive the federal student loans of borrowers who make 120 monthly loan payments while employed in a “public service job.” 20 U.S.C. § 1087e(m)(1). A “public service job” is defined, in relevant part, as “a full-time job in . . . government (excluding time served as a member of Congress), . . . public interest law services (including prosecution or public defense or legal advocacy on behalf of low-income communities at a nonprofit organization), . . . or at an organization that is described in section 501(c)(3) of title 26 and exempt from taxation under section 501(a) of such title.” 20 U.S.C. § 1087e(3)(B)(i). In 2008, the Department issued a regulation further defining program eligibility criteria.

The regulation defined a PSLF “qualifying employer” as, in relevant part, a “government organization, agency, or entity,” “[a]n organization under section 501(c)(3) of the Internal Revenue Code of 1986 that is exempt from taxation under section 501(a) of the Internal Revenue Code,” or “[a] nonprofit organization that (A) Provides a non-governmental public service as defined in this section, attested to by the employer on a form approved by the Secretary; and (B) Is not a business organized for profit, a labor union, or a partisan political organization.” 34 C.F.R. § 685.219(b). It further defined “non-governmental public service” as “services provided by employees of a non-governmental qualified employer where the employer has devoted a majority

1 Plaintiff would have me direct the Department to classify Plaintiff’s employment as “public interest law services” and his employer as a “qualifying employer,” but I decline to go that far at this time. of its full-time equivalent employees to working in . . . public interest law services.” Id. Public interest law services is defined as “legal services that are funded in whole or in part by a local, State, Federal, or Tribal government.” Id. On June 16, 2022, Plaintiff submitted a PSLF application to the Department in order to determine whether he had made 120 PSLF-qualifying payments toward his student loans,

certifying that he was employed by the Pennsylvania Office of Attorney General from January 2014 to December 2017. AR0010-12.2 On September 13, 2022, Plaintiff submitted the same form again, this time including employment certification for the Pennsylvania Office of Attorney General and Scott F. Waterman, Standing Chapter 13 Trustee, with an EIN of 20-0720359. AR0013-0021. On that form, Plaintiff indicated that the Pennsylvania Office of Attorney General is a “government organization, agency, or entity.” AR0015. The Department determined that the payments Plaintiff made toward his student loan debt during the period he worked for the Pennsylvania Office of Attorney General were qualifying payments for the purposes of the PSLF

program. AR0006-0008. As for the Waterman employment form, Plaintiff indicated that he began working for Waterman’s Standing Chapter 13 Trustee office in January 2018 and was still employed there. AR0016. Plaintiff and Waterman certified in the form that Waterman’s Standing Chapter 13 Trustee office was a not-for-profit organization that was not tax-exempt under Section 501(c)(3) of the Internal Revenue Code and that the office provided public interest legal services. Id. Also included with the application was a June 15, 2022 letter from Mr. Waterman asserting that his office is a “public service organization,” that his office “provide[s] a public service by

2 Citations to the administrative record (“AR”) refer to the Bates stamped pages as they appear in ECF No. 24-2, omitting the introductory “RRC_”. administering chapter 13 cases . . . in the Eastern District of Pennsylvania and [is] required to report and account to the Bankruptcy Court, the United States Trustee and all additional stake holders,” that his office is not required to file Federal or state income tax returns, see AR0017, and attaching his Appointment and Designation from the Department of Justice, see AR0018, and a memorandum from the Department of Justice confirming that Chapter 13 Standing Trustee offices

are not required to file income taxes, see AR0019. The Department of Justice memorandum, dated October 28, 2004, stated that “interest earned on post-confirmation and expense accounts is not taxable to the chapter 13 standing trustee, and that these accounts are not taxable trusts for which the standing trustee must file a fiduciary income tax return.” Id. Finally, attached to the Form was Plaintiff’s 2021 W-2, listing his employer as Scott F. Waterman, with an EIN of 20-0720359. AR0020. On September 30, 2022, Plaintiff submitted an updated PSLF application. AR0022-30. The cover page indicated that after faxing the September 13, 2022 application, Plaintiff “noticed that [he] made a mistake on the certification of [his] current employer Scott F. Waterman. The

employer should have been classified as a governmental organization.” The September 30 application now included a certification that the Waterman Standing Chapter 13 Trustee office is a governmental organization, agency, or entity, not a not-for-profit organization. AR0025. It included all of the same attachments as the September 13 application. AR0026-30. Plaintiff was notified on February 18, 2023 that servicing of his loans was transferred to the Higher Education Loan Authority of the State of Missouri (“MOHELA”). AR0031-34; AR0171-172. That same day, he received a notification from MOHELA that he had not yet made the required 120 qualifying payments necessary to be eligible for PSLF. AR0035-39. On March 31, 2023, MOHELA informed Plaintiff that it had approved the 48 payments toward his student loans he made while employed for the Pennsylvania Office of Attorney General. AR0040-43.

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Roland Ramos-Cardona v. United States Department of Education, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/roland-ramos-cardona-v-united-states-department-of-education-et-al-paed-2026.