Schultz v. The Harry S. Truman Scholarship Foundation

Background

Brendan Schultz alleged in his third amended complaint that The Harry S. Truman Scholarship Foundation violated his rights under the Fifth Amendment and the Administrative Procedure Act, 5 U.S.C. § 701 et seq. He claimed discrimination in the review of his application for a Harry S. Truman Scholarship and in the Foundation’s review of his later grievance. He sought a permanent injunction requiring enrollment in the 2019 Truman Scholarship Program and providing all program benefits. The opinion also states that Schultz sought damages.

The court had previously dismissed Schultz’s Fifth Amendment and Administrative Procedure Act claims as alleged in his second amended complaint because he had not adequately pleaded standing. Standing is the requirement that a plaintiff show an injury, a connection between that injury and the defendant’s conduct, and a likelihood that the requested court order would remedy the injury.

Arguments

The Foundation again argued that Schultz lacked standing to seek the requested injunctive relief. It relied on regulations stating that the Foundation does not add new Truman Scholars at the graduate level. It also noted that scholarship recipients must work in public service for three of the seven years after completing funded graduate education, and argued that Schultz had not alleged that he intended to work in the public sector.

Schultz stated that he intended to attend graduate school but was not currently enrolled. He also stated that he would comply with the scholarship’s requirements, including dedicating three of the first seven years of his career after obtaining a graduate degree to public service.

Court’s Analysis

The court applied the constitutional requirements for standing: injury in fact, traceability to the challenged conduct, and likely redressability through a favorable decision. At the pleading stage, Schultz was required to clearly allege facts supporting each element.

The court agreed with the Foundation that Schultz had not adequately alleged facts showing that the court could grant the requested relief. Although the Foundation argued that further amendment should not be allowed because Schultz had already been notified of the pleading deficiencies, the court found that another amendment would not be futile. The court therefore granted Schultz one final opportunity to amend.

Because the court found that Schultz lacked standing, it did not address the Foundation’s separate argument that the complaint failed to state a claim for relief. The opinion also states that Schultz’s damages claims, which had previously been dismissed under the court’s screening authority, would again be dismissed.

Disposition

Judge Maxine M. Chesney granted the Foundation’s motion to dismiss. The court dismissed the third amended complaint with leave to amend and set December 12, 2022, as the deadline for any fourth amended complaint. The court stated that failure to amend, or failure to cure the deficiencies identified in the order and the Foundation’s motion, would result in dismissal of Schultz’s deficient claims with prejudice.