Tatum v. United States of America et al

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
VERNON J. TATUM, JR. 	CIVIL ACTION
VERSUS 	No. 25-178
UNITED STATES OF AMERICA, ET AL. 	SECTION I
ORDER & REASONS
Before the Court is defendant’s unopposed motion 1 to dismiss pro se plaintiff
Vernon J. Tatum, Jr.’s (“Tatum”) complaint2 for failure to state a claim upon which
relief can be granted or, alternatively, for summary judgment. Also before the Court
is Tatum’s motion3 to “pause” defendant’s motion. For the reasons that follow, the
Court DENIES Tatum’s motion to “pause” and GRANTS defendant’s motion to
dismiss or, alternatively, for summary judgment.
I. 	FACTUAL BACKGROUND
On January 17, 2025, Tatum filed a complaint against the Small Business
Administration (“SBA”),4 alleging improper garnishment of his Social Security
payments based on two disaster loans, one approved by the SBA on February 1, 2006,
1 R. Doc. No. 33.
2 R. Doc. No. 1.
3 R. Doc. No. 43.
4 The caption to Tatum’s complaint lists the “United States of America” as the
defendant, but also includes a handwritten addition of “Small Business
Administration” to the defendant’s name. See R. Doc. No. 1, at 1. Paragraph 1 of
Tatum’s complaint states “Made defendant herein, is the United States Small
Business Administration.” See id. ¶ 1. The Court thus construes Tatum’s complaint
as arising against defendant SBA alone.
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and one approved by the SBA on June 8, 2006. 5 Tatum alleges that the SBA began to
use “deceptive billing and mailing practices” in November 2009, 6 in which the SBA
sent Tatum “delinquent dates of notices”7 a number of days after each payment’s due
date.8 He then filed two grievances—on October 3, 2010, and November 1, 2010—in
an attempt to resolve the issue. 9 Tatum further alleges that shortly after these
grievances were filed, the SBA stopped issuing billing notices for the aforementioned
loans.10
Beginning in 2023, Tatum noticed that his Social Security payments were
being garnished by forty-eight dollars per month, with the garnishment increasing to
seventy-four dollars per month in 2024 and ninety-five dollars per month in 2025. 11
Tatum contends that the garnishment of his Social Security benefits is barred by a
ten-year statute of limitations provision, found in 31 U.S.C. § 3716 and 31 C.F.R.
§ 901.3(a)(4).12 Tatum also argues that the SBA’s “deceptive billing practices . . . in
forwarding delinquent dates of notices unto Tatum” were 	“designed to generate
additional monetary interest.”13 Tatum requests $69,970 in damages—$2,508 in
5 R. Doc. No. 18 ¶ 2; R. Doc. No. 33-3, at 1, 3.
6 See R. Doc. No. ¶ 2.
7 Id. ¶ 8.
8 Id. ¶ 2.
9 R. Doc. No. 1 ¶ 2–3.
10 Id. ¶ 4.
11 Id. ¶ 5.
12 Id. ¶ 6.
13 Id. ¶ 7.
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reimbursement for the garnishments of his Social Security paychecks, and $66,970
in punitive damages.14
On December 3, 2025, the SBA filed its motion15 to dismiss Tatum’s complaint
for failure to state a claim upon which relief can be granted pursuant to Federal Rule
of Civil Procedure 12(b)(6) or, alternatively, for summary judgment pursuant to Rule
56. It argues that Tatum is required to exhaust his administrative remedies before
this Court can adjudicate Tatum’s claims16 and that the two grievance letters Tatum
sent the SBA in 2010 are insufficient for purposes of exhaustion.17
The SBA also explains that it mailed three letters to Tatum beginning
December 12, 2010, to April 16, 2024, regarding the delinquency of his debt and
notifying him that his loans may be referred to the U.S. Department of Treasury’s
Treasury Offset Program for an administrative offset collection action.18 The SBA’s
motion also states that the letters it mailed to Tatum described the administrative
remedies he could pursue to challenge the decision, 19 and it proffers evidence that
Tatum has not pursued any such administrative remedies.20
Furthermore, the SBA argues that 37 U.S.C. § 3716 does not contain a ten-
year statute of limitations for the collections of debts by administrative offset, as
Tatum claims it does, and that this is sufficient to dismiss Tatum’s complaint for
14 Id. ¶ 9.
15 R. Doc. No. 33.
16 Id. at 9–11.
17 See generally id.
18 Id. at 2.
19 Id.
20 See R. Doc. No. 33-3, at 3.
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failure to state a claim pursuant to Rule 12(b)(6).21 Importantly, the SBA also points
out that Tatum has not, at any time, attempted to pay his debt and does not claim
that he in fact paid the debt.22
Tatum did not respond to the SBA’s motion to dismiss, however, on December
23, 2025, Tatum filed a motion23 to “pause” SBA’s motion. His motion to “pause” asks
this Court to withhold ruling on SBA’s motion to dismiss until the Fifth Circuit can
rule on his interlocutory appeal of this Court’s order24 denying his motion for judicial
disqualification. The SBA has not responded to Tatum’s motion to “pause”, although,
in its response25 in opposition to Tatum’s notice of appeal it argued that the order
denying judicial qualification is not immediately appealable. Because the Court
agrees that the order is not immediately appealable, 26 the Court finds it proper to
rule on SBA’s motion.
21 Id. at 11–12.
22 R. Doc. No. 33, at 4.
23 R. Doc. No. 43.
24 R. Doc. No. 24.
25 R. Doc. No. 40.
26 “An order denying a motion to recuse is not immediately appealable.” Barnes v. BP
Expl. & Prod. Inc., No. 17-3036, 2022 WL 3924317, at *1 n.1 (E.D. La. Aug. 30, 2022)
(Ashe, J.) (“Because the . . . Order & Reasons denying plaintiff’s motion to recuse was
interlocutory and not immediately appealable, this Court retains jurisdiction over
this case.”) aff’d sub nom. St. v. BP Expl. & Prod., Inc., 85 F.4th 266 (5th Cir. 2023)
(citing In re Burch, 2022 WL 1117701, at *2 (5th Cir. Apr. 14, 2022) (“[Q]uestions
concerning the disqualification of judges are not immediately appealable.”)); see also
Nobby Lobby, Inc. v. City of Dall., 970 F.2d 82, 86 n.3 (5th Cir. 1992) (“[T]he
[defendant] must await final judgment to appeal the judge’s refusal to recuse
himself.”); In Re Corrugated Container Antitrust Litig., 614 F.2d 958, 960-61 (5th Cir.
1980) 	(“Disqualification 	questions 	are 	fully 	reviewable 	on 	appeal 	from 	final
judgment.”).
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II. 	STANDARD OF LAW
a. Rule 12(b)(6) Motion to Dismiss
Federal 	Rule 	of 	Civil 	Procedure 12(b)(6) 	allows 	defendants 	to 	move 	for
dismissal of a complaint for “failure to state a claim upon which relief can be granted.”
To survive a motion to dismiss pursuant to Rule 12(b)(6), a plaintiff’s complaint must
meet the requirement in Rule 8(a)(2) that the complaint contain “a short and plain
statement of the claim showing that the pleader is entitled to relief.” Wampler v. Sw.
Bell Tel. Co., 597 F.3d 741, 744 (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555
(2007)). While this short and plain statement does not require detailed factual
allegations, it “must contain sufficient factual matter, accepted as true, to state a
claim to relief that is plausible on its face.” Waller v. Hanlon, 922 F.3d 590, 599 (5th
Cir. 2019) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)).
A claim is facially plausible when the plaintiff “pleads factual content that
allows the court to draw the reasonable inference that the defendant is liable for the
misconduct alleged.” Gonzalez v. Kay, 577 F.3d 600, 603 (5th Cir. 2009) (citation
modified). “The plausibility standard is not akin to a probability requirement, but it
asks 	for 	more 	than 	a 	sheer 	possibility 	that 	a 	defendant 	has 	acted
unlawfully.” Culbertson 	v. 	Lykos, 	790 	F.3d 	608, 	616 	(5th 	Cir. 	2015) 	(citation
modified).
The face of the complaint must contain enough factual matter to raise a
reasonable expectation that discovery will reveal evidence of each element of the
plaintiff’s claim. Lormand v. US Unwired, Inc., 565 F.3d 228, 255–57 (5th Cir. 2009).
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A complaint is insufficient if it contains “only labels and conclusions, or a formulaic
recitation of the elements of a cause of action.” Whitley v. Hanna, 726 F.3d 631, 638
(5th Cir. 2013) (citation modified). The complaint “must provide the defendant with
fair notice of what the plaintiff’s claim is and the grounds upon which it rests.” Pub.
Emps. Ret. Sys. of Miss. v. Amedisys, Inc., 769 F.3d 313, 320 (5th Cir. 2014).
When considering a motion to dismiss, a court views the complaint “in the light
most favorable to plaintiff, accepting as true all well-pleaded factual allegations and
drawing all reasonable inferences in plaintiff’s favor.” Lovick v. Ritemoney Ltd., 378
F.3d 433, 437 (5th Cir. 2004). In the case of a pro se plaintiff, courts “hold pro se
plaintiffs to a more lenient standard than lawyers when analyzing complaints.”
Chhim v. Univ. of Tex. at Austin, 836 F.3d 467, 469 (5th Cir. 2016).
A court must limit its review to “the complaint, any documents attached to the
complaint, and any documents attached to the motion to dismiss that are central to
the claim and referenced by the complaint.” Lone Star Fund V (U.S.), L.P. v. Barclays
Bank PLC, 594 F.3d 383, 387 (5th Cir. 2010) (citing Collins v. Morgan Stanley Dean
Witter, 224 F.3d 496, 498–99 (5th Cir. 2000)).
b. Rule 56 Motion for Summary Judgment
Summary 	judgment 	is 	proper 	when, 	after 	reviewing 	the 	pleadings, 	the
discovery and disclosure materials on file, and any affidavits, a court determines that
there is no genuine dispute of material fact and the movant is entitled to judgment
as a matter of law. Fed. R. Civ. P. 56(a). “A party seeking summary judgment always
bears the initial responsibility of informing the district court of the basis for its
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motion, and identifying those portions of [the record] which it believes demonstrate
the absence of a genuine issue of material fact.” Ukpong v. Int’l Leadership of Tex.,
No. 21-11111, 2022 WL 6935140, at *2 (5th Cir. Oct. 12, 2022) (quoting Celotex Corp.
v. Catrett, 477 U.S. 317, 323 (1986)). The party seeking summary judgment need not
produce evidence negating the existence of a material fact; it need only point out the
absence of evidence supporting the other party’s case. Barefoot v. Weyerhaeuser NR
Co., 729 F. App’x 300, 304 (5th Cir. 2018) (“There is no sound reason why conclusory
allegations should suffice to require a trial when there is no evidence to support them
even if the movant lacks contrary evidence.”) (quoting Fontenot v. Upjohn Co., 780
F.2d 1190, 1195–96 (5th Cir. 1986)).
Once 	the 	party 	seeking 	summary 	judgment 	carries 	that 	burden, 	the
nonmoving party must come forward with specific facts showing that there is a
genuine dispute of material fact for trial. Ukpong, 2022 WL 6935140, at *2; see also
Matsushita Elec. Indus. v. Zenith Radio Corp., 475 U.S. 574, 587 (1986). The showing
of a genuine issue is not satisfied by creating “some metaphysical doubt as to the
material facts, by conclusory allegations, by unsubstantiated assertions, or by only a
scintilla of evidence.” Winans v. McKay, 23-30199, 2025 WL 3092771, at *4 (5th Cir.
Nov. 5, 2025) (quoting Little v. Liquid Air Corp., 37 F.3d 1069, 1075 (5th Cir. 1994)).
Rather, a genuine issue of material fact exists when the evidence is such that “a
reasonable jury could return a verdict for the nonmoving party.” Faulk v. Owens
Corning Roofing & Asphalt, LLC, No. 25-10356, 2025 WL 3678430 (5th Cir. Dec. 18,
2025) (quoting Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986)). If the
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nonmovant fails to meet their burden of showing a genuine issue for trial that could
support a judgment in favor of the nonmovant, summary judgment must be granted.
See Ukpong, 2022 WL 6935140, at *2.
“Although the substance or content of the evidence submitted to support or
dispute a fact on summary judgment must be admissible . . . the material may be
presented in a form that would not, in itself, be admissible at trial.” Lee v. Offshore
Logistical & Transp., L.L.C., 859 F.3d 353, 355 (5th Cir. 2017) (citations omitted).
The party responding to the motion for summary judgment may not rest upon the
pleadings but must identify specific facts that establish a genuine issue. See
Anderson, 477 U.S. at 248. The nonmoving party’s evidence, however, “is to be
believed, and all justifiable inferences are to be drawn in [the nonmoving party’s]
favor.” Id. at 255.
III. 	ANALYSIS
a. Subject Matter Jurisdiction
“A plaintiff may only sue the United States if its sovereign immunity is
explicitly waived in a federal statute.” Canada v. United States Small Bus. Admin.,
No. 	21-91, 	2021 	WL 	8442058, 	at 	*3 	(W.D. 	Tex. 	Oct. 	13, 	2021), 	report 	and
recommendation adopted sub nom. Canada v. Small Bus. Admin., No. 21-91, 2021
WL 8442057 (W.D. Tex. Dec. 28, 2021) (internal alterations omitted). “Because the
SBA is an agency of the United States, it enjoys sovereign immunity except to the
extent waived, and the terms of its consent to be sued in any court define that court’s
jurisdiction to entertain the suit.” Id.
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Title 15, United States Code, section 634(b) permits the administrator of the
SBA to “sue and be sued . . . in any United States district court,” and states that
“jurisdiction is conferred upon such district court to determine such controversies
without 	regard 	to 	the 	amount 	in 	controversy; 	but 	no 	attachment, 	injunction,
garnishment, or other similar process, mesne or final, shall be issued against the
Administrator or his property[.]” This provision “waives sovereign immunity . . . and
confers jurisdiction on United States district courts to hear such suits.” Oldham v.
United States Small Bus. Admin., No. 19-10644, 2025 WL 1393867, at *4 (5th Cir.
May 14, 2025). But this waiver is limited in that “all injunctive relief directed at the
SBA is absolutely prohibited.” In re Hidalgo Cnty. Emergency Serv. Found., 962 F.3d
838, 840 (5th Cir. 2020). Additionally, because “only the Administrator may be named
as the proper party in a cause of action alleging claims against the Small Business
Administration,” a plaintiff’s “claims against the Small Business Administration”
alone may be “properly dismissed.” Canada, 2021 WL 8442058, at *3.
Tatum has named only the SBA, and not the SBA Administrator, as a
defendant in this action,27 meaning, Tatum’s claims could be properly dismissed on
that ground alone. See id. In addition, it seems that Tatum’s complaint mainly seeks
reimbursement from the SBA of the money collected through the Treasury Offset
Program, 28 which other courts have found “is not in itself a claim” viable under
§ 634(b). See Canada, 2021 WL 8442058, at *4. Nevertheless, because the Court
27 See R. Doc. No. 1, at 1.
28 See id. at 5.
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interprets pro se pleadings liberally, the Court finds that it has subject matter
jurisdiction over this matter. See Shumaker v. Guzman, No. 21-477, 2022 WL
2902843, at *1 (S.D. Tex. Apr. 4, 2022), aff’d, No. 22-40409, 2023 WL 1434276 (5th
Cir. Feb. 1, 2023); see also Tatum v. United States, 465 F. App’x 313, 315 n.1 (5th Cir.
2012) (interpreting Tatum’s complaint as arising under § 634(b) where Tatum had
named the SBA and United States of America as defendants but had served the suit
on the SBA Administrator).
b. Exhaustion of Administrative Remedies
The SBA Administrator “may collect by administrative offset only after giving
the debtor”
(1) written notice of the type and amount of the claim, the intention of
the head of the agency to collect the claim by administrative offset,
and an explanation of the rights of the debtor under this section;
(2) an opportunity to inspect and copy the records of the agency related
to the claim;
(3) an opportunity for a review within the agency of the decision of the
agency related to the claim; and
(4) an opportunity to make a written agreement with the head of the
agency to repay the amount of the claim.
31 	U.S.C.A. 	§ 	3716(a). 	Pursuant 	to 	31 	U.S.C. 	§ 	3716(b), 	the 	SBA 	has 	also
“promulgated agency-specific administrative offset regulations.” Canada, 2021 WL
8442058, at *4; see also 13 C.F.R. § 140.3. These regulations “set forth the steps [the]
agency must take in order to collect a debt by withholding money from a government
payment,” id. at 5, which include offering a debtor an opportunity to “present
evidence that all or part of the debt is not past due or not legally enforceable” and
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allowing a debtor the opportunity to request a hearing before the SBA’s Office of
Hearings and Appeals (“OHA”), see 13 C.F.R. § 140.3(e).
SBA submits that it complied with its statutory requirements by mailing
Tatum three different notice letters between the two loans, dated December 12,
2010, 29 January 30, 2011, 30 and April 16, 2024. 31 These letters contained the requisite
notices set forth in § 3716(a), 32 including Tatum’s right to present evidence and
request an OHA hearing. 33 SBA argues that by not “pursu[ing] any of the four options
available to him to avoid an administrative offset by the Department of Treasury,”
Tatum has failed to exhaust his administrative remedies and, therefore, his claims
must be dismissed.34
Caselaw within and outside of this circuit supports the SBA’s position that
administrative exhaustion is required before Tatum may seek judicial review of the
SBA’s referral of his debt to the Treasury Offset Program. See, e.g., Canada, 2021 WL
8442058, at *4 (“A debtor must exhaust her administrative remedies by utilizing [the
SBA’s] 	agency 	review 	process 	before 	seeking 	judicial 	relief 	with the courts.”);
Benjamin v. United States, No. 13-313, 2014 WL 3900220, at *5 (M.D. Pa. Aug. 8,
2014) (“[I]f at the end of this administrative process a [debtor-plaintiff] remains
29 R. Doc. No. 33-3, at 1.
30 Id. at 3.
31 Id. at 5–8.
32 See id. at 5, 7–8; see also id. at 1–2, 3 (explaining that copies of the letters sent on
December 12, 2010, and January 30, 2011, are no longer available “due to SBA
document retention policies,” but also stating that the letters were “substantially
similar” to the April 16, 2024, letter attached to SBA’s motion).
33 See id. at 8.
34 R. Doc. No. 33, at 11.
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displeased 	with 	a 	Treasury 	offset 	decision, 	that 	[debtor-plaintiff] 	may, 	upon
exhaustion of his administrative remedies, file an action in federal court challenging
this offset decision.”); United States v. Mayer, No. 04-100, 2010 WL 4916561, at *1
(D.N.H. Dec. 3, 2010) (“While government counsel hyperbolically (and incorrectly)
argues that ‘the offset process is an administrative process beyond the jurisdiction of
this Court,’ still, [the debtor] must, in the first instance, seek administrative relief as
prescribed by the statute and implementing regulations.”); United States v. Beulke,
892 F. Supp. 2d 1176, 1187 (D.S.D. 2012) (“[D]ebtors challenging their referral to the
[Treasury Offset Program] are expected to address their concerns to the referring
agency before coming to court.”).
Although Tatum’s complaint states that he filed two grievance letters, on
October 3, 2010, and November 1, 2010, respectively,35 the SBA is correct to conclude
that these “alleged grievances were not made in response to the notice letters and
could not have been intended to pursue any of the administrative remedies described
in the notice letters,” because the notice letters were all mailed to Tatum after he sent
his grievance letters.36 Because the evidence proffered by the SBA represents that
Tatum did not pursue any administrative remedies prior to filing suit, and because
Tatum does not represent in his complaint or otherwise present evidence to the
contrary, the Court finds it could dismiss Tatum’s claims for failure to exhaust.
However, given the ambiguity around whether those administrative remedies are
35 R. Doc. No. 1, at 2.
36 See R. Doc. No. 33-1, at 11.
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currently available to Tatum, 37 	the Court rests its dismissal on Tatum’s failure to
state a claim upon which relief can be granted.
c. 	Failure to State a Claim Upon Which Relief Can Be Granted
Tatum’s claims fail on the merits. Tatum’s challenge to the garnishment of his
benefits is based on his contention that the administrative offset is barred by a 10-
year statute of limitations.38 He cites 31 U.S.C. § 3716 in support of his contention,
however, § 3716(e)(1) states: “Notwithstanding any other provision of law, regulation,
or administrative limitation, no limitation on the period within which an offset may
be initiated or taken pursuant to this section shall be effective.” The Fifth Circuit has
already told Tatum in another case that he is incorrect in this regard. See Tatum v.
United States, No. 24-30555, 2025 WL 1201874, at *1 (5th Cir. Apr. 25, 2025) (per
curiam) 	(“Tatum 	incorrectly 	argues 	that 	the 	SBA’s 	collection 	efforts 	[via
administrative offset] were barred by a 10-year statute of limitations.”).
The only case Tatum cites in support, Lee v. Paige,39 predates Congress’s
amendment to § 3716(e), which eliminated the ten-year statute of limitations. See
37 The Court notes that the time periods for pursuing the administrative processes
that the SBA contends that Tatum must exhaust prior to filing suit seem to have all
expired. See R. Doc. No. 33-3, at 8 (explaining that for Tatum to avoid referral to the
Treasury Offset Program he must pursue certain remedies within 60 days of the
notice and, in the case of requesting an OHA hearing, within 15 days of receipt of the
notice); see also 13 C.F.R. 140.3 (same). However, the SBA, by arguing that Tatum’s
claims 	should 	be 	dismissed 	for 	failure 	to 	exhaust, 	seems 	to 	suggest 	that
administrative remedies are still available to Tatum. See R. Doc. No. 33-1, at 9–11.
38 See R. Doc. No. 1, at 3–4.
39 376 F.3d 1179 (8th Cir. 2004), cert. granted, judgment vacated sub nom. Spellings
v. Lee, 546 U.S. 1072 (2005), and abrogated by Lockhart v. United States, 546 U.S.
142 (2005).
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Food, Conservation, and Energy Act of 2008, Pub. L. No. 110–246, 122 Stat. 1651
(“Sec. 14219. Elimination of Statute of Limitations Applicable to Collection of Debt
By Administrative Offset.”). And while Tatum correctly points out that portions of
the 	Code 	of 	Federal 	Regulations 	seem 	to 	retain 	the 	10-year 	limitation 	for
administrative offset,40 Fifth Circuit precedent is clear that “where an agency has
promulgated a regulation or adopted an interpretation that is in conflict with a
statute’s plain meaning, the reviewing court is not required to give deference to the
agency’s interpretation.” First Am. Bank v. Resol. Tr. Corp., 30 F.3d 644, 647 (5th Cir.
1994). Consequently, the SBA’s unopposed motion is dismissed as the Court finds
that Tatum’s complaint fails to state a cognizable claim.
IV. CONCLUSION
For the foregoing reasons,
IT IS ORDERED that the SBA’s motion41 is GRANTED.
IT IS FURTHER ORDERED that Tatum’s motion42 to pause is DENIED.
IT IS FURTHER ORDERED that Tatum’s complaint 43 is DISMISSED
WITH PREJUDICE.
40 See R. Doc. No. 1 (quoting 31 C.F.R. § 901.3(a)(4)), at 4; see also, e.g., 47 C.F.R.
§ 1.1912(a)(4), 10 C.F.R. § 1015.203(a)(4), 13 C.F.R. § 140.3(f) (“Non-judgment debts
are enforceable for ten years.”).
41 R. Doc. No. 33.
42 R. Doc. No. 43.
43 R. Doc. No. 1.
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New Orleans, Louisiana, January 5, 2026.
_______________________________________
LANCE M. AFRICK
UNITED STATES DISTRICT JUDGE
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