“Legacy claims” for U.S. Department of Agriculture (USDA) farm-lending discrimination under § 22007(e) of the Inflation Reduction Act; Eligibility criteria deeming applications alleging only discrimination against deceased individuals “facially ineligible”; Challenges under the Administrative Procedure Act (APA); “Arbitrary, capricious [or] an abuse of discretion”; 5 USC § 706(2)(A); Whether Congress gave the USDA discretionary authority to accept claims based on discrimination faced by deceased farmers; “Compensation” versus “assistance”; Statutory right to inherit property on the “same” basis as other U.S. citizens (42 USC § 1982); Fifth Amendment’s Due Process Clause claim

The court held that plaintiffs (collectively referred to as the Farmers) were not entitled to bring “legacy claims” under a program to address discriminatory USDA farm-lending practices because Congress did not give the USDA discretion to accept those claims. The court further found that its “reading of § 22007(e) creates no conflict with § 1982” and that their claim under the Fifth Amendment’s Due Process Clause also failed. The Farmers sued defendant-USDA, challenging its policy of disallowing applications to one of its programs filed on behalf of deceased relatives (legacy claims). The program (the Discrimination Financial Assistance Program) was created by § 22007(e) of the Inflation Reduction Act and was enacted to provide financial aid to farmers who were discriminated against in the USDA’s farm-lending programs. The program established eligibility requirements. Its Validation Review Guide provided: “Applications ‘[r]eport[ing] only discrimination against an individual who was deceased at the time of the application’ were deemed ‘facially ineligible.’” The Farmers sought to have the district court issue a preliminary injunction forcing the USDA to accept their legacy claims under the APA and Fifth Amendment Due Process Clause. The district court dismissed the case, ruling that the “statute required the USDA to accept applications from living farmers only.” The court agreed that “the Program may not accept claims made on behalf of deceased farmers[,]” explaining that “a deceased farmer is not engaged in an activity that money can help complete, nor does the farmer suffer any need that money can help relieve. Money, in short, cannot ‘assist[]’ a deceased farmer.” Rather than “assistance,” as provided for in § 22007(e), the Farmers were seeking “compensation’ for past harm to deceased farmers[.]” As the USDA “could not have accepted claims made on behalf of deceased farmers,” the Farmers were not entitled to relief under the APA. The court also rejected their § 1982 argument, finding that “§ 22007(e) impairs no one’s right to inherit property.” They forfeited their Fifth Amendment claim, and the court noted that they had “no due-process-protected property interest in the ‘benefit’ program created here, given that the governing statute . . . affords them no ‘claim of entitlement to th[at] benefit.’” Affirmed.