Bendis v. Singer

Background

These two related civil actions arose from the college-admissions scheme involving William “Rick” Singer. The complaints alleged that parents paid Singer, his business, or his charity, and that Singer created false athletic profiles and bribed university coaches or athletic-department managers. The alleged bribes were used to place applicants into admissions slots reserved for students who excelled in sports.

The plaintiffs alleged that unqualified applicants were admitted while qualified applicants who followed the rules were denied admission. They claimed economic harm from paying application fees and ideological harm from not receiving a fair and objective admissions process. The defendants included Singer, entities connected to him, and several universities or university-related defendants.

Standing and Jurisdiction

The court explained that standing is the legal requirement that a plaintiff show a concrete, personal injury that was caused by the defendant and likely could be remedied by a favorable court decision. Without standing, a federal court lacks authority to hear the case.

The court held that the plaintiffs had not pleaded an injury that was personal to them. The alleged scheme focused on athletic admissions slots, but no plaintiff alleged being an athlete or applying for, being considered for, or being denied an athletic slot. The plaintiffs’ complaints instead indicated that they competed for general-admission slots, which the court found were separate from the athletic slots affected by Singer’s scheme.

The court also rejected the plaintiffs’ arguments that they were injured because they would not have applied or paid application fees had they known about the fraud, or because they were promised a fair and holistic review. The court characterized those theories as generalized injuries because they did not show that the scheme actually affected the plaintiffs’ own admissions reviews. The court further stated that the allegations did not support a separate theory that the general-admissions process was unfair.

Disposition

The court granted the defendants’ motions to dismiss on jurisdictional grounds. It dismissed the plaintiffs’ claims without leave to amend, meaning the court did not allow the plaintiffs to file another amended complaint in these actions. The court found amendment futile because adding more facts about the plaintiffs’ decision to apply or pay fees would not establish the required connection between the scheme and their admissions reviews. The court also stated that the plaintiffs could not cure the jurisdictional problem by adding new plaintiffs who might have standing.

The opinion did not decide whether the plaintiffs’ underlying legal claims were adequately stated. Instead, the court dismissed because the plaintiffs lacked standing.