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Home Court filings MomoCon, LLC v. Small Business Administration Memorandum Opinion and Order Denying Motion to Stay — MomoCon v. SBA (D.D.C.)

Court filing

Memorandum Opinion and Order Denying Motion to Stay — MomoCon v. SBA (D.D.C.)

Filed December 22, 2023 in Momocon v. SBA; one of 5 filings from this case.

Record facts

CourtU.S. District Court for the District of Columbia
Filed2023-12-22

U.S. District Court for the District of Columbia · No. 1:21-cv-02386-RC · Doc. 72 · 2023-12-22 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 
MOMOCON, LLC, 
: 
 
 
: 
 
Plaintiff, 
: 
Civil Action No.: 
21-2386 (RC) 
 
 
: 
 
v. 
: 
Re Document No.: 
59, 68, 69 
 
 
: 
SMALL BUSINESS ADMINISTRATION, 
: 
et al.,   
: 
 
 
: 
 
Defendants. 
: 
 
MEMORANDUM OPINION & ORDER 
DENYING DEFENDANTS’ MOTION TO STAY  
This is an action between Plaintiff MomoCon, LLC (“MomoCon”) and Defendants U.S. 
Small Business Administration and its Administrator, Isabella Casillas Guzman (collectively, 
“SBA”).  MomoCon seeks review of the SBA’s denial of its application for Shuttered Venue 
Operators Grant (“SVOG”) funds.  The Court previously granted summary judgment for 
MomoCon and remanded the case to the SBA.  On remand, the SBA denied MomoCon’s 
application for a second time.  The parties then moved for summary judgment again.  
After summary judgment briefing concluded, the SBA made a motion to stay the case, 
arguing that the case was moot because the SBA no longer possessed any SVOG funds.  The 
SBA later recouped some SVOG funding and withdrew its mootness argument.  The SBA 
nonetheless continued to argue that the Court should stay proceedings until the D.C. Circuit 
resolved Concert Investor, LLC v. Small Business Administration, No. 22-5233 (D.C. Cir. filed 
Sept. 29, 2022).  MomoCon opposes the motion to stay, arguing that the Court should decide this 
case without further delay.  For the reasons stated below, the Court denies the SBA’s motion. 
Case 1:21-cv-02386-RC     Document 72     Filed 12/22/23     Page 1 of 6

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I.  BACKGROUND 
MomoCon first applied for a SVOG award on April 26, 2021, the first day that the SBA 
began accepting applications.  Pl.’s Mem. of P. & A. in Opp’n to Defs.’ Mot. to Stay 
(“MomoCon’s Opp’n”), Ex. 1 (Decl. of Christopher Stuckey (“Stuckey Decl.”)) ¶ 5, ECF No. 
61-1.  The SBA denied the application and MomoCon filed an application for judicial review on 
September 9, 2021.  See Compl., ECF No. 1.  On February 10, 2022, the Court granted summary 
judgment in favor of MomoCon, holding that the SBA’s denial was arbitrary and capricious (1) 
for “failure to explain why similar companies’ applications were granted” and (2) in its 
“determination that MomoCon does not have the right principal business activity.”  Mem. Op. at 
10, ECF No. 32.  The Court remanded the matter to the SBA to address these issues.  Id. at 20. 
On remand, the SBA again denied the application on August 1, 2022.  MomoCon filed an 
amended complaint to challenge this denial, see Am. Compl., ECF No. 14-1, and moved for 
summary judgment on November 4, 2022, arguing that the SBA’s second denial was arbitrary 
and capricious, Pl.’s Mem. P. & A. Supp. Mot. Summ. J. (“Pl.’s Mem.”), ECF No. 53.  The SBA 
also moved for summary judgment, arguing that this denial was consistent with the statute and 
supported by the evidence.  Defs.’ Combined Mem. in Supp. of Its Mot. for Summ. J. & Opp’n 
to Pl.’s Mot. for Summ. J. (“Defs.’ Opp’n & Mem.”) at 10–16, ECF No. 55.  
On January 24, 2023, the SBA moved for a stay of the case until the D.C. Circuit 
resolved Concert Investor, because, in that case, the government argued that challenges to SVOG 
denials were moot because Congress had rescinded the program’s remaining funds.  Defs.’ Mot. 
to Stay, ECF No. 59.  MomoCon opposed the motion.  See MomoCon’s Opp’n.  Later, the SBA 
recouped a significant amount of funds from entities that were not actually eligible for an award, 
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or did not spend their whole grant award.  Therefore, on July 28, 2023, the SBA withdrew its 
mootness argument.  Defs.’ Notice Regarding Mootness, ECF No. 68. 
In that same notice, however, the SBA renewed its request for a stay, arguing that “the 
D.C. Circuit likely will address an issue that may be dispositive in this case—whether or not the 
Agency must issue Plaintiff an award even if it is ineligible, merely because it previously issued 
an award to an ostensibly similarly-situated entity later determined to be ineligible for an award, 
and has not yet recouped that entity’s award.”  Id. at 2.  On September 13, 2023, MomoCon filed 
a response opposing the stay.  Pl. Resp. to Defs.’ Notice Regarding Mootness, ECF No. 69. 
MomoCon argued that it would be harmed by any additional delay in deciding the case, and that 
other courts handling similar SVOG cases have lifted their stays.  Id. at 5–9. 
II.  LEGAL STANDARD 
 “The District Court has broad discretion to stay proceedings as an incident to its power 
to control its own docket.”  Clinton v. Jones, 520 U.S. 681, 706 (1997).  “[T]he party requesting 
a stay bears the burden of showing that the circumstances justify an exercise of that discretion.” 
Ind. State Police Pension Tr. v. Chrysler LLC, 556 U.S. 960, 961 (2009) (internal quotation 
marks omitted).  But “[o]nly in rare circumstances will a litigant in one cause be compelled to 
stand aside while a litigant in another settles the rule of law that will define the rights of both.”  
Belize Soc. Dev. Ltd. v. Gov’t of Belize, 668 F.3d 724, 732 (D.C. Cir. 2012) (quoting Landis v. N. 
Am. Co., 299 U.S. 248, 255 (1936)). 
In considering a request to stay litigation, courts “‘weigh competing interests and 
maintain an even balance’ between the court’s interests in judicial economy and any possible 
hardship to the parties.”  Id. at 732–33 (quoting Landis, 299 U.S. at 255) (internal citation 
omitted).  Courts “make such determinations in . . . light of the particular circumstances of the 
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case,” SEC v. Dresser Indus., Inc., 628 F.2d 1368, 1375 (D.C. Cir. 1980), including potential 
hardships arising from delay caused by a stay, see Nat’l Indus. for Blind v. Dep’t of Veterans 
Affs., 296 F. Supp. 3d 131, 137 (D.D.C. 2017).  Other factors that bear on whether to issue a stay 
include whether (1) “determination of the appeal in the first action will . . . preclude the entire 
second action” or instead, the second case involves “claims or issues that must be tried regardless 
of the outcome of the first action,” and (2) there are “cogent reasons to fear the effects of delay.”  
18A Arthur Wright et al., Fed. Prac. & Proc. Juris. § 4433 (3d ed. Apr. 2022 update); accord 
Univ. of Colo. Health at Mem’l Hosp. v. Burwell, 233 F. Supp. 3d 69, 88 (D.D.C. 2017) (same). 
III.  ANALYSIS 
While the mootness issue that originally motivated the SBA’s motion to stay is now 
ironically a moot point, the Court still must consider whether the case should be stayed pending 
resolution of the D.C. Circuit’s decision in Concert Investor.  The Court finds that the Circuit’s 
decision would at most resolve only one of the issues being contested in the summary judgment 
motions, and therefore denies the motion to stay. 
Defendants argue that the D.C. Circuit’s Concert Investor opinion will sort out whether 
MomoCon is entitled to a SVOG award because the SBA had previously issued an award to 
allegedly similarly-situated entities.  Defendants emphasize that their position in Concert 
Investor is that “the APA does not require the Agency to extend the benefit of its prior mistake in 
granting an ineligible entity an award to all newcomers” and that “so long as the Agency 
explains during litigation that its previous issuance of an award to an entity later determined to 
be ineligible was simply a mistake, the fact that an award denial letter issued to a plaintiff does 
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not itself contain such explanation amounts, at most, to harmless error under 5 U.S.C. § 706.”1  
Defs.’ Notice Regarding Mootness at 2.  And indeed, MomoCon argues in its motion for 
summary judgment that the SBA’s second denial does not rectify its differential treatment versus 
its competitors, because the denial only stated that the SBA would recommend recoupment of 
awards to competitors rather than the SBA actually recouping those awards.  Pl.’s Mem. at 10. 
But while this issue is important to this litigation, it is not necessarily dispositive.  
MomoCon’s “argument about similarly situated entities is but one argument it asserts in this 
action.”  Pl. Resp. to. Defs.’ Notice Regarding Mootness at 5.  Beyond that argument, the Court 
must also complete its arbitrary and capricious analysis by deciding (1) whether the SBA was 
obligated to assess the “significance” of MomoCon’s live events and (2) whether the SBA 
correctly calculated the proportional hours of live events at MomoCon 2019.  Id. at 5–6.  The 
Court thus disagrees with the SBA’s argument that a stay is warranted because the decision in 
Concert Investor “whether favorable or adverse to Defendants, likely will render unnecessary 
any resources that this Court expends addressing the issue on its own.”  Defs.’ Notice Regarding 
Mootness at 3.  That may be true for one issue, but not all.  
Moreover, as MomoCon shows, “other judges in this District have lifted stays pertaining 
to other SVOG cases where the SBA withdrew its mootness argument.”  Pl. Resp. to. Defs.’ 
Notice Regarding Mootness at 5; see e.g., Min. Order, Creation Ent., Inc. v. Small Bus. Admin., 
No. 1:22-cv-00684-ABJ (lifting stay and setting briefing schedule); Min. Order, Atl. Arts Found. 
v.  Small Bus. Admin., No. 1:22-cv-02109-DLF (D.D.C. Aug. 8, 2023) (lifting stay and setting  
briefing schedule); Min. Order, Monkey Jungle, Inc. v. Small Bus. Admin., No. 1:22-cv-02537-
 
1 Of note, the Court has listened to the oral argument in Concert Investor and that issue 
was barely mentioned by the panel or the parties. 
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JDB (D.D.C. Aug. 11, 2023) (lifting stay and finding that the D.C. Circuit’s decision in Concert 
Investor is not likely to be “dispositive” or to “significantly narrow the issues” (quoting Fonville 
v. District of Columbia, 766 F. Supp. 2d 171, 173–74 (D.D.C. 2011))). 
Finally, although the D.C. Circuit recently held oral argument in Concert Investor on 
November 16, 2023, it is unclear when the Circuit will issue its opinion in that case.  This action 
and the current motions for summary judgment have been pending for quite some time, and the 
Court agrees that a stay would increase uncertainty and harm MomoCon as it addresses its post-
pandemic financial operations.  See generally Stuckey Decl. ¶¶ 7–17 (detailing MomoCon’s 
revenue shortfalls).  Even if the eventual D.C. Circuit decision in Concert Investor may bear 
upon on the ultimate outcome of this litigation, the parties would benefit from no further delay 
on receiving the Court’s view of the SBA’s second denial.  See En Fuego Tobacco Shop LLC v. 
U.S. Food & Drug Admin., 356 F. Supp. 3d 1, 11–12 (D.D.C. 2019) (declining to issue stay 
when defendants argued that a D.C. Circuit decision would likely control the outcome of central 
claims in the case).  Thus, the SBA has failed to meet its burden of demonstrating a stay is 
appropriate here.  
IV.  CONCLUSION 
For the foregoing reasons, it is hereby ORDERED that Defendants’ motion to stay (ECF 
No. 59), as supplemented in Defendants’ Notice Regarding Mootness (ECF No. 68), is 
DENIED.   
SO ORDERED. 
Dated:  December 22, 2023 
RUDOLPH CONTRERAS 
 
United States District Judge 
Case 1:21-cv-02386-RC     Document 72     Filed 12/22/23     Page 6 of 6

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