Valentina Riffel v. The Regents of The University of California

Background

Valentina Riffel brought claims for herself and a proposed class of people who paid or reimbursed an application fee to the University of California, Los Angeles (UCLA). She focused on statements on UCLA’s admissions website describing a comprehensive, merit-based review process. Riffel alleged that UCLA did not disclose that applicants could receive preferential treatment by being designated as student-athlete recruits in exchange for payment.

Riffel alleged that she relied on UCLA’s statements when she paid or reimbursed an application fee. She claimed that, had she known about UCLA’s participation in the college-admissions scheme associated with William “Rick” Singer, she would not have paid the fee or applied. She characterized the fee as a loss of property.

The Regents moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), which permits dismissal when the federal court lacks subject-matter jurisdiction. The court considered whether Riffel had standing, meaning a sufficiently concrete and personal injury that a federal court is permitted to address.

Standing Analysis

The court explained that constitutional standing requires an injury-in-fact that is concrete, particularized, and actual or imminent; a causal connection between the injury and the defendant’s conduct; and a likelihood that a favorable decision would remedy the injury.

The court compared Riffel’s allegations with claims in a prior related proceeding involving the same admissions scandal. In that earlier round, the court had found that applicants who did not allege seeking, being considered for, or being denied an athletic position had not shown a sufficiently personal injury. The court found Riffel’s alleged economic harm materially the same.

Riffel did not allege that she sought admission as a student-athlete or that the admissions scheme prevented UCLA from evaluating her application on its merits. The court therefore found no sufficient connection between the alleged misconduct and Riffel personally. Her allegation that she would not have paid the application fee if she had known about the scheme was, without more, a generalized grievance rather than a concrete and particularized injury.

The court distinguished cases in which consumers alleged that they paid for property or goods that lacked represented features or value. It found that Riffel had not plausibly alleged that she was deprived of a specific benefit that UCLA had represented and failed to provide.

The court separately held that Riffel lacked standing to seek injunctive relief because she did not allege a sufficient likelihood that she would be harmed in the same way in the future. The court stated that the underlying admissions scandal had ceased.

The court also concluded that Riffel lacked standing under California’s Unfair Competition Law because that claim requires an injury-in-fact and lost money or property resulting from the alleged unfair competition.

Disposition

The court held that Riffel failed to establish an injury-in-fact, so she lacked constitutional standing and the court lacked jurisdiction. It granted The Regents’ motion to dismiss on jurisdictional grounds.

The court considered whether Riffel should be allowed to amend her complaint. It concluded that amendment would be futile because she would need to allege a connection between the admissions scheme and her own admissions review, and the court did not believe she could plead such facts. The court dismissed the complaint without leave to amend.