CASE NAME

Samuels v. Small Business Administration

Overview

Plaintiff, a Black man, alleges that the Small Business Administration (SBA) has policies that require businesses to be at least 51% owned by women to qualify for certain programs. He argues that this requirement constitutes an Equal Protection violation.

Details

Defendant filed a , arguing that Plaintiff filed the case in the wrong court, lacked to sue because he never applied for SBA programs, and failed to provide sufficient facts to support his claim that the SBA's policies violated the Equal Protection Clause.

On August 12, 2025, the court granted Defendant's motion to dismiss and denied Plaintiff leave to amend their . The court held that Plaintiff lacked standing due to not establishing any particular injury that could be traced to Defendant's alleged misconduct. Additionally, Plaintiff filed the case in the wrong court because he did not reside in the Southern District of N.Y. (district), nor did he allege that a substantial part of the events occurred in the district. Lastly, the court denied Plaintiff leave to amend because even with a liberal reading of his allegations, there was no indication that he may be able to plead a viable claim.

Court

U.S. District Court, Southern District of New York

Status

Filed September 10, 2023 | Decided