Schultz v. The Harry S. Truman Scholarship Foundation

Summary

The United States District Court for the Northern District of California ruled on the Harry S. Truman Scholarship Foundation’s motion to dismiss Brendan Schultz’s Fourth Amended Complaint. The court denied dismissal of Schultz’s Fifth Amendment equal-protection claim and his APA claim insofar as it was based on an alleged constitutional violation, but dismissed APA theories concerning candidate qualifications and the alleged failure to establish a grievance procedure. The court also dismissed requests for monetary damages and struck the jury demand.

Holdings

1. The Fourth Amended Complaint plausibly alleged intentional discrimination because its allegations were susceptible of an inference that Schultz was treated differently because of his Jewish, ethnic, or religious identity.
2. The APA claim was not subject to dismissal insofar as it challenged the Foundation's selection decision as a constitutional violation.
3. The APA claim was dismissed to the extent it challenged the Foundation's determination that Schultz lacked the comparative qualifications or potential for selection.
4. The APA claim based on the Foundation's alleged failure to establish a grievance procedure was dismissed because the record showed that a procedure existed and, in any event, any procedural deficiency was harmless.
5. The requests for compensatory and punitive damages were dismissed.
6. The jury demand was stricken because sovereign immunity had not been waived to permit a jury trial on the APA or implied constitutional claims against the federal government.

Questions Presented

1. Whether Schultz plausibly alleged intentional discrimination in violation of the equal-protection component of the Fifth Amendment's Due Process Clause.
2. Whether the APA permits review of the Foundation's alleged constitutional discrimination in selecting Truman Scholars.
3. Whether the Foundation's determination that Schultz was less qualified than selected candidates was committed to agency discretion by law and therefore unreviewable under the APA.
4. Whether the Foundation's alleged failure to establish a grievance procedure under Executive Order 13160 warranted APA relief.
5. Whether Schultz could pursue monetary damages or a jury trial on his Fifth Amendment and APA claims against the federal agency.

Disposition

other