Shop Rite Inc v. U S Small Business Administration

CourtDistrict Court, W.D. Louisiana
DecidedDecember 19, 2024
Docket6:23-cv-00456
StatusUnknown

This text of Shop Rite Inc v. U S Small Business Administration (Shop Rite Inc v. U S Small Business Administration) is published on Counsel Stack Legal Research, covering District Court, W.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shop Rite Inc v. U S Small Business Administration, (W.D. La. 2024).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAFAYETTE DIVISION

SHOP RITE INC CASE NO. 6:23-CV-00456 VERSUS JUDGE ROBERT R. SUMMERHAYS U.S. SMALL BUSINESS ADMINISTRATION MAGISTRATE JUDGE CAROL □□□ WHITEHURST

MEMORANDUM RULING AND ORDER The present matters before the Court are cross motions for summary judgment filed by the plaintiff, Shop Rite, Inc. [ECF No. 25], and the defendant, the United States Small Business Administration [ECF No. 33]. Both motions are opposed. I. BACKGROUND Shop Rite, Inc. (“Shop Rite”) challenges the decision of the United States Small Business Administration (the “SBA”) denying its application to forgive loans advanced to Shop Rite under the Paycheck Protection Program (“PPP”) created by the Coronavirus Aid, Relief, and Economic Security Act of 2020 (the “CARES Act” or “the Act”). Under Section 7(a) of the Small Business

Act, codified at 15 U.S.C. § 636(a), the SBA is authorized to make business loans to eligible small business concerns.! SBA regulations establish the eligibility requirements for SBA small business loans, including size, location, and demonstrated need for credit. These regulations set “size standards” that “define whether a business entity is small and, thus, eligible for Government

1 ECF Nos. 24-2 at 3-6; 35-2 at 1-10. 213 C.F.R. § 120.101.

programs and preferences reserved for ‘small business’ concerns.”* These size standards turn, in

part, on the industry in which a borrower operates.* The SBA classifies industries using the North American Industry Classification System (“NAICS”), which assigns codes to various categories of economic activity.° The SBA then sets size limits for the maximum revenue or number of

employees to qualify as an eligible “small business” by NAICS code.® The employee size limit

ranges from 125 to 1,500 employees, depending on the NAICS category.’ The regulations place businesses in the relevant NAICS category based on the borrower’s “primary industry”: In determining the primary industry in which a concern or a concern combined with its affiliates is engaged, SBA considers the distribution of receipts, employees and costs of doing business among the different industries in which business operations occurred for the most recently completed fiscal year. SBA may also consider other factors, such as the distribution of patents, contract awards, and assets.® The SBA’s regulations also include “affiliation” rules governing when related business are grouped together for purposes of applying the size limits.” In 2020, Congress passed, and the President signed, the CARES Act which, inter alia, created the PPP.!° The CARES Act directed the SBA to administer the PPP under the agency’s pre-existing Section 7(a) small business loan program, and provided that PPP loans could be

forgiven if used for certain authorized purposes.'' In this regard, the CARES Act states that “Te]xcept as otherwise provided in [the PPP], the [SBA] may guarantee covered loans under the

3 Id 4 Td.

613 CFR. § 121.201.

813 CFR. § 121.107. 913 CER. § 121.103. 10 CARES Act, Pub. L. No. 116-136, 134 Stat. 281. The PPP is codified at 15 U.S.C. § 636(a)(36). 11 Id.

same terms, conditions, and processes as a loan made under this subsection [Section 7(a)].”!* The CARES Act expanded eligibility for PPP loans in certain respects compared to traditional Section 7(a) loans.!3 One of the areas where the CARES Act expanded eligibility for PPP loans is relevant here—the waiver of the affiliation rules for restaurant and hospitality businesses.'* Specifically, the CARES Act provides that: [dJuring the covered period, the provisions applicable to affiliations under section 121.103 of title 13, Code of Federal Regulations, or any successor regulation, are waived with respect to eligibility for a covered loan for— (I) any business concern with not more than 500 employees that, as of the date on which the covered loan is disbursed, is assigned a North American Industry Classification System code beginning with 72....!° NAICS codes beginning with “72” include hotels and motels, casino hotels, bed and breakfast inns, and other similar types of hospitality businesses.'® The category also includes full and limited-service restaurants, caterers, “drinking places,” snack and nonalcoholic beverage bars, and other food service-related businesses. The CARES Act directed the SBA to promulgate regulations implementing the PPP within fifteen (15) days of enactment, “without regard to the notice requirements under section 553(b) of [T]itle 5, United States Code.”!8 On April 15, 2020, the SBA issued an Interim Final Rule (“First IFR”), which Plaintiffs refer to as the “Exclusion Rule,” detailing the SBA’s interpretation of the PPP provisions in the CARES Act and how the SBA would administer the new program.'? The

12 CARES Act, 134 Stat. 287; 15 U.S.C. § 636(a)(36)(B) (emphasis added). 3 15 U.S.C. § 636(a)(36)(D). 415 U.S.C. § 636(a)(36)(D)(iv). 15 15 U.S.C. § 636(a)(36)(D)(iv)(). 1613 CFR. §121.201. 17 Id. 18 CARES Acct, Sec. 1114, 134 Stat. at 312; 15 U.S.C. § 9012. 19 Business Loan Program Temporary Changes; Paycheck Protection Program, 85 FR 20811-01.

First IFR stated that the PPP is a “new [Section] 7(a) program.””° The First IFR declared SBA’s understanding that “[t]he intent of the [CARES] Act is that SBA provide relief to America’s small businesses expeditiously ... by giving all lenders delegated authority and streamlining the requirements of the regular [Section] 7(a) loan program.””! As part of that “streamlining,” the First IFR stated that businesses identified in Section 120.110 as ineligible for traditional Section 7(a) loans were also not eligible for PPP loans, “except that nonprofit organizations authorized under the [CARES] Act are eligible.””” On April 3, 2020, Shop Rite applied for a PPP loan with the First National Bank of Louisiana (“FNB”) and, on April 15, 2020, the bank approved the loan and disbursed $2,502,750 to Shop Rite.”? Shop Rite filed an application for PPP loan forgiveness on June 23, 2021, and FNB recommended that the loan be forgiven.”4 Shop Rite’s initial application for forgiveness included

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