Benoit v. USDA, No. 08-5434, concerned an action by Fourteen African American farmers alleging that the U.S. Department of Agriculture discriminated against them on the basis of race (and, in one case, gender) in administering the agency's federally funded credit and benefit programs. The D.C. Circuit affirmed summary judgment for defendants, on the grounds that 1) in order to exhaust their administrative remedies, the plaintiffs would have had to request a formal hearing before an Administrative Law Judge; and 2) plaintiffs suggested no reason to think a formal hearing of that nature would not have proceeded expeditiously.
As the court wrote: "Fourteen African American farmers allege the United States Department of Agriculture discriminated against them on the basis of race (and, in one case, gender) in administering the agency's federally funded credit and benefit programs. They assert claims under the Equal Credit Opportunity Act, 15 U.S.C. §§ 1691 et seq. (ECOA); the Civil Rights Act of 1866, 42 U.S.C. § 1981; the Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.; the common law; and the Fifth and Fourteenth Amendments to the Constitution of the United States. In this appeal we consider not the merits of the plaintiffs' claims but only whether the district court erred by entering summary judgment against the plaintiffs on their claims under the ECOA because they failed to exhaust their administrative remedy or by dismissing the plaintiffs' other claims as barred by sovereign immunity."
- Full Text of Benoit v. USDA, No. 08-5434