Wong v. Federal Trade Commission

CourtDistrict Court, W.D. Louisiana
DecidedMarch 25, 2025
Docket6:24-cv-01410
StatusUnknown

This text of Wong v. Federal Trade Commission (Wong v. Federal Trade Commission) 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
Wong v. Federal Trade Commission, (W.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAFAYETTE DIVISION

JONATHAN WONG CASE NO. 6:24-CV-01410

VERSUS JUDGE TERRY A. DOUGHTY

FEDERAL TRADE COMMISSION ET AL MAG. JUDGE DAVID J. AYO

MEMORANDUM RULING

Before the Court is a Motion to Dismiss Or, In the Alternative, To Hold Case in Abeyance Pending Supreme Court Proceedings (R. Doc. 27) filed first by one of the defendants, the Horseracing Integrity and Safety Authority, Inc. (the “Authority”), and later “join[ed] in full” by the remaining defendant, the Federal Trade Commission (the “FTC”) (collectively “Defendants”). See R. Doc. 29. The plaintiff, Jonathan Wong (“Mr. Wong”), opposes (R. Doc. 34), and the Authority has filed a Reply (R. Doc. 35). After careful consideration of the pleadings, the parties’ memoranda, and the applicable law, the Motion is GRANTED. I. BACKGROUND Mr. Wong trains thoroughbred racehorses. R. Doc. 1 at 16–17. He is apparently pretty good at it, too. See id. Trouble began for Mr. Wong, however, when a racehorse under his tutelage—named Heaven and Earth—tested positive for a banned substance following a race in Indiana. Id. at 17–18. Heaven and Earth, like any other professional athlete, gets regularly drug tested. Id. at 18. And, as the “Responsible Person” for Heaven and Earth, it is Mr. Wong’s “duty . . . to ensure that no Banned Substance is present in the body of his . . . Covered Horse.” Id. at 6 (quoting HISA Rule 3212). But not just “[r]esponsible” for Heaven and Earth’s sobriety, Mr. Wong is “strictly liable for any Banned Substance . . . found to be present in a Sample collected from his . . . Covered Horse(s).” Id. (citing HISA Rule 3212(a);

and 15 U.S.C. § 3057(a)(2)). It follows, then, that when Heaven and Earth tested positive for metformin—a diabetes drug prohibited by the Authority—Mr. Wong suffered penalties. Id. at 26. The Authority suspended Mr. Wong from thoroughbred horseracing for two years, made him forfeit $21,600 of Heaven and Earth’s winnings, fined him $25,000, and took another $8,000 for “adjudication costs.” Id. Newly suspended, Mr. Wong had to transfer 150 horses to other trainers, including a horse

that went on to compete at the Kentucky Derby. Id. at 19. Not all was lost, however. As will be discussed in greater detail below, the Authority does not operate in Louisiana. See Nat’l Horsemen’s Benevolent & Protective Ass’n v. Black, 107 F.4th 415 (5th Cir. 2024). So, Louisiana provided Mr. Wong with an opportunity to continue his vocation. Now, living and training horses in Louisiana, Mr. Wong brings this suit to vindicate himself. R. Doc. 1 at 31. Mr. Wong’s case is twofold. He first challenges the constitutionality of the

statute creating the Authority, the Horseracing Integrity and Safety Act (“HISA”). Id. at 2. Second, he appeals the administrative adjudication and civil penalties levied against him by the Authority. Id. The day after filing suit, Mr. Wong moved for a preliminary injunction to prohibit enforcement of the civil penalties against him. R. Doc. 6. The Authority thereafter filed the instant Motion, averring that dismissal is warranted (1) because this is an improper venue, (2) because the Court lacks personal jurisdiction over the Authority, and (3) because the case cannot proceed without the

Authority. See R. Doc. 27-1 at 8. The Authority alternatively contends that the case should be stayed pending the outcome of relevant Supreme Court litigation. Id. Mr. Wong opposes dismissal, averring that venue is proper, personal jurisdiction exists over the Authority, and that the Authority is dispensable. See R. Doc. 34. Once it was somewhat apparent to the Court that personal jurisdiction did not exist over the Authority, we called a status conference to explore some alternatives

to dismissal. See R. Doc. 37. The parties did not agree on alternatives. See R. Doc. 43. But the next day, Mr. Wong voluntarily dismissed the Authority under Federal Rule of Civil Procedure 41(a)(1)(A)(i). R. Doc. 42. With the Authority gone, the FTC reiterated its stance that this case should be dismissed, and that the Authority is an indispensable party. See R. Doc. 44. II. LAW AND ANALYSIS Despite Mr. Wong’s last-minute jurisdictional shell game, see R. Doc. 42, the

Court must still determine whether the Authority is an indispensable party. He cannot simply assign all his jurisdictional flaws to the Authority, voluntarily dismiss the Authority, and keep his case. See Fed. R. Civ. P. 19(a)-(b) (explaining that a court must dismiss a civil action if it lacks personal jurisdiction over any “necessary” and “indispensable” party). That said, we begin our analysis with Federal Rule of Civil Procedure 19(a), where necessity is outlined. A. Rule 19(a) Analysis Federal Rule of Civil Procedure 19 “seeks to bring into a lawsuit all those persons who ought to be there by requiring joinder.” Pulitzer–Polster v. Pulitzer, 784

F.2d 1305, 1308 (5th Cir. 1986). The first step of a Rule 19 analysis is to determine whether an absent party is necessary to the litigation. Fed. R. Civ. P. 19(a). If the Court finds that an absent party is necessary, it must analyze whether that party can be joined. Id. If the Court cannot gain jurisdiction over the necessary party, the Court must address certain factors under Rule 19(b) to determine whether adjudicating the dispute in the absence of the necessary party can be done “in equity

and good conscience,” or if the case should be dismissed due to the inability to join the indispensable party. Fed. R. Civ. P. 19(b). A party is deemed necessary under Rule 19(a)(1) if in its absence (1) “the court cannot accord complete relief among existing parties”; (2) disposition of the action may, as a practical matter, “impair or impede” the ability of the absent party to protect “an interest relating to the subject of the action”; or (3) those parties presently in the case will be “subject to a substantial risk of incurring double, multiple or

otherwise inconsistent obligations.” See Fed. R. Civ. P. 19(a)(1); Pulitzer–Polster, 784 F.2d at 1308–09. The nature of Rule 19 requires that courts make “highly practical, fact-based decision[s].” Pulitzer–Polster, 784 F.2d at 1309. We begin with the first factor. To determine whether complete relief is available without the absent party, “the Court looks to the relief prayed for by the claimant.” Cain v. City of New Orleans, 184 F. Supp. 3d 349, 358 (E.D. La. 2016). Here, the FTC is simply not answerable for much of the relief Mr. Wong seeks. Easiest first, Mr. Wong seeks money damages, R. Doc. 1 at 1, and Mr. Wong seeks a jury trial. Id. An Administrative Procedure Act (“APA”) claim against the FTC,

which Mr. Wong now contends is the only claim that matters, R. Doc. 34 at 8–9, 11, does not contemplate either of these. “[T]he Administrative Procedure Act’s waiver of sovereign immunity … applies only to actions seeking relief other than money damages, 5 U.S.C. § 702

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Wong v. Federal Trade Commission, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wong-v-federal-trade-commission-lawd-2025.