Valentina Riffel v. University of Southern California

Background

Valentina Riffel sued the University of Southern California and other defendants, asserting claims on behalf of herself and people who paid or reimbursed an application fee to USC. Riffel focused on USC’s website statement that it conducted a comprehensive, holistic review considering applicants’ academic and personal characteristics.

Riffel alleged that this statement was misleading because USC did not disclose that applicants could receive preferential treatment by being designated as student-athlete recruits in connection with the college admissions scandal. She alleged that she relied on USC’s statement and would not have paid or reimbursed an application fee if she had known about the alleged system. She characterized the application fees as a loss of property.

USC moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), which allows dismissal when the federal court lacks subject-matter jurisdiction. USC argued that Riffel’s alleged economic injury was the same type of injury the court had previously found insufficient in related proceedings involving the admissions scandal.

Standing and the Court’s Analysis

Article III standing requires a plaintiff to show an injury that is concrete and particularized, actual or imminent, fairly traceable to the defendant’s conduct, and likely to be remedied by a favorable decision. The court found that Riffel had not alleged the required injury-in-fact.

The court compared Riffel’s allegations with those in the related proceedings. It noted that Riffel did not allege that she applied for, was considered for, or was denied an athletic position. She also did not allege that the admissions scandal prevented USC from evaluating her application on its merits. Without a connection between the alleged misconduct and Riffel’s own application, the court found that her allegations amounted to a generalized grievance rather than a concrete, personal injury.

The court also rejected Riffel’s argument that she had suffered a benefit-of-the-bargain injury. It found that she had not plausibly alleged that USC represented that her application fee would purchase a particular admissions process or benefit that USC failed to provide. Her allegation that she would not have paid the fee if she had known about the alleged misconduct was not enough by itself.

Because Riffel did not establish an injury-in-fact, the court concluded that she lacked standing and that the court lacked jurisdiction. The court separately determined that she lacked standing to seek injunctive relief because she had not alleged a sufficient likelihood of being harmed in the same way again. The court also concluded that Riffel lacked standing to bring her California Unfair Competition Law claim because that claim required an injury-in-fact and loss of money or property resulting from the alleged unfair competition.

Judicial Notice

Without opposition from Riffel, the court granted USC’s request for judicial notice of three exhibits: court orders in related proceedings, a complaint from one related proceeding, and a plea agreement filed in a criminal case involving William Rick Singer. The court stated that it could notice the existence of court filings and its own records, but not disputed facts within those records for their truth.

Disposition

The court found that allowing Riffel to amend would be futile because she would need to allege a connection between the admissions scheme and the review of her own application, and the court did not believe she could plead such facts. The court therefore granted USC’s motion to dismiss on jurisdictional grounds without leave to amend.