United States of America, The, ex rel. v. Holden Farms, Inc.

U.S. District Court, District of Minnesota

United States of America, The, ex rel. v. Holden Farms, Inc.

Trial Court Opinion

                   UNITED STATES DISTRICT COURT                          
                      DISTRICT OF MINNESOTA                              
UNITED STATES OF AMERICA ex rel.                                         
ANIMAL LEGAL DEFENSE FUND,                                               
                                      Civil No. 21-2061 (JRT/DJF)        

                       Plaintiff,                                        

v.                               MEMORANDUM OPINION AND ORDER            
                                 GRANTING DEFENDANT’S MOTION TO          
HOLDEN FARMS, INC.,                         DISMISS                      

                      Defendant.                                         

    Kristen Elise Rau, UNITED STATES ATTORNEY’S OFFICE, 300 South Fourth 
    Street, Suite 600, Minneapolis, MN 55415, for Plaintiff United States of 
    America.                                                             

    Alastair John MacKinnon Findeis and Ross B. Brooks, BROOKS LLC, 173  
    Huguenot Street, Suite 200, New Rochelle, NY 10801; Daniel Waltz, ANIMAL 
    LEGAL DEFENSE FUND, 611 Pennsylvania Avenue Southeast, Number 484,   
    Washington, DC 20003; Emily R. Stewart, ANIMAL LEGAL DEFENSE FUND,   
    767 Broadway, Number 1209, New York, NY 10003; Gerald Charles Pierre 
    Robinson, Matthew H. Morgan, and Rebekah L. Bailey, NICHOLS KASTER   
    PLLP, 4700 IDS Center, 80 South Eighth Street, Minneapolis, MN 55402, for 
    Relator Animal Legal Defense Fund.                                   

    Dustan J. Cross and Matthew C. Berger, GISLASON & HUNTER LLP – NEW   
    ULM, PO Box 458, New Ulm, MN 56073, for Defendant.                   


    Defendant Holden Farms, Inc. (“Holden”), a Minnesota pork producer, applied for 
a loan under the Paycheck Protection Program (“PPP”) during the COVID-19 pandemic.  
When applying, Holden certified that it was “not engaged in any activity that is illegal 
under federal, state or local law.”  Relator Animal Legal Defense Fund (“ALDF”) brought 
this action under the False Claims Act (“FCA”), claiming that Holden’s attestation was false 
because Holden violated two Minnesota statues and the Swine Health Protection Act 

(“SHPA”), 
7 U.S.C. § 3803
, by engaging in inhumane and unsanitary pork production 
practices.                                                                
    The PPP was a widespread, emergency measure designed to secure the economic 
wellbeing  of  businesses  and  employees,  not  police  agricultural  laws.    Accordingly, 

Holden’s alleged legal missteps were not material to the government’s PPP issuance and 
the Court will grant Holden’s motion and dismiss this action with prejudice.  
                          BACKGROUND                                     
I.   FACTS                                                                

    Holden is a family-owned and managed pork producer with 76 employees and a 
herd of 70,000 sows across various Minnesota locations.  (1st Am. Compl. (“Compl.”) 
¶¶ 17, 70, Aug. 11, 2023, Docket No. 30.)  ALDF is an animal advocacy organization whose 
“charitable mission is to protect the lives and advance the interests of animals through 

the legal system.”  (Id. ¶ 22.)                                           
    Holden unwittingly hired and employed for five months an undercover ALDF 
investigator.  (Id. ¶ 88.)  The undercover employee documented animal cruelty, neglect, 
and instances of “feedback” feeding, in which pig corpses and byproducts were fed to live 

pigs.  (Id. ¶¶ 10–15, 88, 90, 143.)  For purposes of this motion, Holden assumes that its 
conduct violated the SHPA and Minnesota’s anti-cruelty and anti-garbage feeding laws. 
    Shortly after ALDF’s undercover investigation concluded, the COVID-19 pandemic 
swept through the United States.  (Id. ¶¶ 3–4, 88.)  In response, Congress enacted the 

Coronavirus Aid, Relief, and Economic Security Act, a centerpiece of which was the PPP.  
(Id. ¶ 3.)  The PPP was adopted to cope with the economic havoc caused by the pandemic, 
providing employees and small businesses with a lifeline.  (See 
id. ¶ 3
); Bam Navigation, 
LLC v. Wells Fargo & Co., No. 20-1345, 
2021 WL 533692
, at *1 (D. Minn. Feb. 12, 2021). 

    Holden applied for a $2.57 million loan under the PPP which the Small Business 
Association (“SBA”) approved and, ultimately, forgave.  (Compl. ¶ 4.)  Holden’s loan 
application contained a certification that “[t]he Applicant is not engaged in any activity 

that is illegal under federal, state or local law.”  (PPP Appl. at 2.)    
II.  PROCEDURAL HISTORY                                                   
    ALDF initiated a qui tam civil action under the FCA, alleging that Holden falsely 
attested to following all laws because its practices violated the SHPA and Minnesota’s 

anti-cruelty and anti-garbage feeding laws.  (Compl. ¶ 7.)  The United States declined to 
intervene.  (See Order, July 13, 2023, Docket No. 23.)1  Holden now moves to dismiss 




    1 Although the government’s notice of non-intervention and the Court’s subsequent order 
indicated the Court would solicit the government’s written consent before dismissing, “the 
Attorney General’s consent is required only where the relator seeks a voluntary dismissal, not 
where, as here, the district court grants a motion by the defendant to dismiss for failure to state 
a claim.”  (Notice of Election to Decline Intervention at 1, July 3, 2023, Docket No. 20.); United 
States ex rel. Shaver v. Lucas W. Corp., 
237 F.3d 932
, 934 (8th Cir. 2001). 
because the alleged false attestation was not material to the government’s lending 
decision.2                                                                

                           DISCUSSION                                    
I.   STANDARD OF REVIEW                                                   
    A.   Rule 12(b)(6)                                                   
    In reviewing a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), the 
Court considers all facts alleged in the Complaint as true to determine if the Complaint 

states a “claim to relief that is plausible on its face.”  Braden v. Wal-Mart Stores, Inc., 
588 F.3d 585, 594
 (8th Cir. 2009) (quoting Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009)).  The 
Court construes the Complaint in the light most favorable to the plaintiff, drawing all 
reasonable inferences in the plaintiff’s favor.  Ashley Cnty. v. Pfizer, Inc., 
552 F.3d 659, 665
 

(8th Cir. 2009).  Although the Court accepts the complaint’s factual allegations as true, it 
is “not bound to accept as true a legal conclusion couched as a factual allegation,” Bell 
Atl. Corp. v. Twombly, 
550 U.S. 544, 555
 (2007), or mere “labels and conclusions or a 

formulaic recitation of the elements of a cause of action,” Iqbal, 
556 U.S. at 678
 (quotation 
omitted).  Instead, “[a] claim has facial plausibility when the plaintiff pleads factual 
content that allows the court to draw the reasonable inference that the defendant is 
liable for the misconduct alleged.”  
Id.
                                  




    2 Because materiality disposes of this action, the Court will not address the parties’ 
disagreements over Holden’s knowledge.                                    
    At the motion to dismiss stage, the Court may consider the allegations in the 
Complaint as well as “those materials that are necessarily embraced by the pleadings.” 

Schriener v. Quicken Loans, Inc., 
774 F.3d 442, 444
 (8th Cir. 2014).  The Court may also 
consider matters of public record and exhibits attached to the pleadings, as long as those 
documents do not conflict with the Complaint.  Porous Media Corp. v. Pall Corp., 
186 F.3d 1077, 1079
 (8th Cir. 1999).                                               

    B.   The False Claims Act and Rule 9(b)                              
    The FCA creates civil liability to the United States for someone who “(A) knowingly 
presents, or causes to be presented, a false or fraudulent claim for payment or approval; 
[or] (B) knowingly makes, uses, or causes to be made or used, a false record or statement 

material to a false or fraudulent claim . . . .”  
31 U.S.C. § 3729
(a)(1).  The FCA allows a 
private person to bring a so-called “qui tam” civil action for violation of this section in the 
name of the United States Government.  
Id.
 § 3730(b)(1).                  

    Claims under the FCA are subject to the heightened pleading standard of Federal 
Rule of Civil Procedure 9(b).  United States ex rel. Roop v. Hypoguard USA, Inc., 
559 F.3d 818, 822
 (8th Cir. 2009).  “In alleging fraud or mistake, a party must state with particularity 
the circumstances constituting fraud or mistake.”  Fed. R. Civ. P. 9(b).  Accordingly, a 

relator must plead facts such as “the time, place, and content of the defendant’s false 
representations, as well as the details of the defendant’s fraudulent acts, including when 
the acts occurred, who engaged in them, and what was obtained as a result.”  Thayer v. 
Planned Parenthood of the Heartland, Inc., 
11 F.4th 934, 939
 (8th Cir. 2021).  At the same 
time, “knowledge, and other conditions of a person’s mind may be alleged generally.”  
Fed. R. Civ. P. 9(b).                                                     

II.  ANALYSIS                                                             
    The alleged false statement was not material; thus, no FCA liability follows.  
31 U.S.C. § 3729
(b)(4) defines as material any statement “having a natural tendency to 
influence, or be capable of influencing, the payment or receipt of money or property.”3  

Notwithstanding the lenient statutory language, the Supreme Court has characterized the 
materiality inquiry as “rigorous” and “demanding.”  See Universal Health Servs., Inc. v. 
United States ex rel. Escobar, 
579 U.S. 176, 181, 194
 (2016).  Materiality may be resolved 
on the pleadings.  See 
id.
 at 195 n.6.                                    

    In Escobar, the Supreme Court engaged in its most fulsome discussion of the 
materiality requirement.  Both the general principles Escobar espoused and its specific 
teachings on how to apply the materiality requirement counsel dismissal of this action. 

    Beginning with broad principles, the unanimous opinion is replete with warnings 
that the FCA “is not ‘an all-purpose antifraud statute,’” nor is it “a vehicle for punishing 
garden-variety breaches of contract or regulatory violations.”   
Id. at 194
 (quotation 
omitted).  Indeed,                                                        

         [a]  misrepresentation  cannot  be  deemed  material  merely    
         because  the  Government  designates  compliance  with  a       
         particular statutory, regulatory, or contractual requirement as 


    3 The materiality requirement applies equally to claims under 
31 U.S.C. §§ 3729
(a)(1)(A) 
and (B).  See Thayer, 
11 F.4th at 938
.                                    
         a condition of payment.  Nor is it sufficient for a finding of  
         materiality that the Government would have the option to        
         decline to pay if it knew of the defendant's noncompliance.     
         Materiality,  in  addition,  cannot  be  found  where           
         noncompliance is minor or insubstantial. . . .  In sum, when    
         evaluating  materiality  under  the  False  Claims  Act,  the   
         Government’s decision to expressly identify a provision as a    
         condition  of  payment  is  relevant,  but  not  automatically  
         dispositive.                                                    
Id.
  The decision proceeds:                                               
         [I]f  the  Government  required  contractors  to  aver  their   
         compliance with the entire U.S. Code and Code of Federal        
         Regulations,  then  under  this  view,  failing  to  mention    
         noncompliance with any of those requirements would always       
         be material.  The False Claims Act does not adopt such an       
         extraordinarily expansive view of liability.                    
Id. 196.                                                                  
    Under Escobar, then, Holden is not liable under the FCA simply by virtue of its 
attestation that it complied with all laws.  ALDF brings precisely the action the Supreme 
Court  warned  against,  using an all-encompassing certification  of  legality to  ensnare 
Holden in FCA liability.  Thus, the Court will proceed with skepticism while still evaluating 
whether, under the totality of the circumstances, Holden’s noncompliance was material.  
See United States ex rel. Int’l Bhd. of Elec. Workers Local Union No. 98 v. Farfield Co., 
5 F.4th 315, 342
 (3d Cir. 2021) (materiality is a “holistic, totality-of-the-circumstances” 
inquiry).  Escobar establishes a non-exclusive list of factors a court may consider when 
evaluating materiality.  See Escobar, 579 U.S. at 194–95.  Particularly relevant to this 
action are whether the violated condition went to the essence of the bargain, and the 
government’s response in like cases.                                      

    A.   Essence of the Bargain                                          
    Rather than going “to the very essence of the bargain,” the violation alleged here 
was entirely unrelated.  
Id.
 at 193–94 & n.5.  That is, Holden’s noncompliance with 
agricultural laws was too far afield from the purpose of the PPP to sustain an FCA claim. 

    The PPP was implemented to support employees and businesses through the early 
stages  of  the  COVID-19  pandemic.4    It  was  administered  by  the  Small  Business 
Administration and covered a wide range of enterprises, irrespective of their industries.  
See Keeping American Workers Paid and Employed Act, 
Pub. L. No. 116-136, 134
 Stat. 281 

§ 1102(a)(2)(D) (codified at 
15 U.S.C. § 636
(a)(36)(D)).  As instructed by the purpose of 
the PPP and Holden’s application for the loans, the essence of the bargain was that loans 
would be issued (and ultimately forgiven) in exchange for businesses using the funds to 

keep themselves and their employees afloat.  The general certification of compliance with 
all  laws  does  not  reasonably  insert  considerations  of  agricultural  law  into  the 
contemplated bargain.  Because ALDF does not allege Holden used the PPP funds for 



    4  See,  e.g.,  U.S.  Dep’t  of  the  Treasury,  Paycheck  Protection  Program, 
https://home.treasury.gov/policy-issues/coronavirus/assistance-for-small-businesses/paycheck
-protection-program  (last  accessed  Apr.  16,  2024)  (“The  Paycheck  Protection  Program  is 
providing small businesses with the resources they need to maintain their payroll, hire back 
employees who may have been laid off, and cover applicable overhead.”); U.S. Small Bus. Admin., 
PPP Myth vs. Fact, https://www.sba.gov/document/support-ppp-myth-vs-fact (last accessed 
Apr. 16, 2024) (“Every facet of PPP was designed to keep Americans employed.”) 
anything other than payroll and other covered business expenses, it does not plausibly 
allege that Holden deprived the government of the benefit of the contemplated bargain. 

    ALDF  alleges  that  any  legal  noncompliance  undermines  an  entity’s 
creditworthiness and is thus material to the SBA’s lending decisions.  But that would 
reestablish FCA liability for any violation of “the entire U.S. Code and Code of Federal 
Regulations,” contrary to the Supreme Court’s warnings.  See Escobar, 
579 U.S. at 196
.  

Regardless, where forgiveness was anticipated and the “loans” were, in effect, gifts, 
creditworthiness is of less concern.  See 
15 U.S.C. § 636
(37)(J).         
    ALDF also tries to salvage materiality by tying Holden’s noncompliance with anti-

garbage feeding laws to zoonotic disease prevention efforts.  To be sure, many arms of 
the federal government were vigorously fighting COVID-19, a zoonotic disease, at the 
time.  But there is no evidence whatsoever that the PPP was concerned with promoting 
public health.  It would be passing strange for Congress to assign administration of a 

program that was so concerned to the SBA.  Moreover, ALDF does not provide any reason 
to believe the government was concerned with preventing the emergence of a new 
zoonotic disease as compared to fighting the existing pandemic.  And even if ALDF could 
surmount all of these issues, that would salvage only its claims under the garbage feeding 

laws; ALDF provides no reason to believe allegations of animal cruelty would be material. 
    Ultimately, Holden’s alleged violations of an all-encompassing legal attestation do 
not cut to the heart of the PPP bargain when the violations were unrelated to the 

economic focus of the program.                                            
    B.   Government Response                                             
    Escobar identifies two inverse inferences of materiality based on government 
conduct.  See 
579 U.S. at 195
.  If “the Government consistently refuses to pay claims in 

the mine run of cases based on noncompliance with the particular statutory, regulatory, 
or contractual requirement,” that is strong evidence the requirement is material.  
Id.
  
Conversely, “if the Government regularly pays a particular type of claim in full despite 
actual knowledge that certain requirements were violated, and has signaled no change in 

position, that is strong evidence that the requirements are not material.”  
Id.
 
    Beginning with government refusal to pay claims when it learns of noncompliance, 
ALDF alleges materiality “is evidenced by the fact that the Department of Justice (“DOJ”) 

has brought enforcement actions against PPP borrowers who were in violation of laws 
governing their industry.”  (Compl. ¶ 62.)  ALDF cites two instances in which DOJ took 
action, in part, based on a false certification that the borrower was “not in violation of 
any laws” when applying for a PPP loan.  (Id. ¶ 63.)                      

    Those DOJ actions are hardly evidence of consistent refusals to pay “in the mine 
run of cases based on noncompliance” with the PPP certification.  See Escobar, 
579 U.S. at 195
.  Rather, they are two instances when DOJ tacked on FCA claims to much more 
substantial charges of fraud.  (See Compl. ¶ 63.)  In the first case, the government added 
the PPP fraud allegations onto criminal charges for money laundering and fraudulent 
medical billing.  (See id.)  In the second, the centerpiece was again fraudulent medical 

billing, with the PPP false statement also noted.  (Id.)  ALDF fails to identify any instance, 
nor is the Court able to find one, when the government has pursued a PPP borrower solely 
because a business falsely attested to the general legality of its operations. 
    On the contrary, there is good reason to believe the government regularly paid 

similar claims despite knowing that the legality requirement was violated.  See Escobar, 
579 U.S. at 195
.  The SBA issued approximately 11.5 million PPP loans and forgave 10.6 
million.  See Pandemic Response Accountability Committee, Paycheck Protection Program 

(Oct. 23, 2023), https://www.pandemicoversight.gov/data-interactive-tools/interactive-
dashboards/paycheck-protection-program.  Those loans were issued to “provide relief to 
America’s small businesses expeditiously, which is expressed in the Act by giving all 
lenders delegated authority and streamlining the requirements of the regular 7(a) loan 

program.”  
85 Fed. Reg. 20811
, 20812 (Apr. 15, 2020).  As such, SBA allowed “lenders to 
rely on certifications of the borrower in order to determine eligibility of the borrower 
and . . . to rely on specified documents provided by the borrower to determine qualifying 
loan amount and eligibility for loan forgiveness.”  
Id.
                   

    Even under the most ideal circumstances, it is inconceivable that the government 
would assume that 11.5 million businesses across any number of industries would comply 
with all governing laws and regulations, no matter how significant.  Cf. Nieves v. Bartlett, 
139 S. Ct. 1715, 1730
 (2019) (Gorsuch, J., concurring in part and dissenting in part) 
(“[C]riminal laws have grown so exuberantly and come to cover so much previously 

innocent conduct that almost anyone can be arrested for something.”).  That proposition 
is  even  less  conceivable  when  the  government  adopted  an  expedited  process  that 
bypassed usual diligence.  The government must have known that some loan recipients 
would run afoul of their broad attestation of legal compliance, yet it still dispersed nearly 

$800  billion  under  the  PPP  with  minimal  oversight.5    See  Pandemic  Response 
Accountability Committee, Paycheck Protection Program.  Under these circumstances, 
the government did not view as material regulatory violations that technically ran afoul 

of the loan certification language.                                       
    Finally, there is the matter of this specific loan.  The SBA reserved the right to 
require repayment of misused PPP loans but has not done so here.  See 85 Fed. Reg. at 
20814.6  Even after ALDF’s reporting and lawsuit against Holden, it still forgave Holden’s 

loan.                                                                     


    5 To be sure, Escobar spoke of “actual knowledge” that requirements were violated, while 
the Court’s analysis here is of constructive knowledge.  
579 U.S. at 195
.  But Escobar’s list of 
materiality factors was not exclusive, and the level of constructive knowledge is so high here that 
it is as convincing to the Court as actual knowledge would have been.     
    6 Whether the SBA has declined to recoup the money is a different question than whether 
the United States intervened in this suit.  The parties debate the significance of a recent Eighth 
Circuit decision that notes “[a]t least two of our sister circuits have observed that the United 
States’s refusal to intervene in a qui tam FCA case indicates the relator’s case is weak.”  United 
States ex rel. Kraemer v. United Dairies, L.L.P., 
82 F.4th 595
, 606 n.7 (8th Cir. 2023); but see 
id. at 607
  (Colloton,  J.,  concurring  in  the  judgment)  (observing  that  materiality,  and  thus  the 
significance of the government’s non-intervention, was not properly before the court and should 
                                CONCLUSION 
     In sum, both the general tenor of this action and the totality of the circumstances 
indicate the  alleged  false  claim  was  not  material  to the  government’s  PPP  decisions. 
Because  ALDF  does  not  allege  that  Holden  violated  a  material  term  of  its  PPP  loan 
agreement, the Court will dismiss this action with prejudice. 

ORDER

     Based on the foregoing, and  all the files,  records, and  proceedings herein,  IT IS 
HEREBY ORDERED that Defendant’s Motion to Dismiss [Docket No. 46] is GRANTED and 
this action is DISMISSED with prejudice. 

     LET JUDGMENT BE ENTERED ACCORDINGLY. 

DATED:  May 24, 2024                              Otay    | table 
at Minneapolis, Minnesota.                         JOHN R. TUNHEIM 
                                            United States District Judge 

not have been decided).  The Court will not wade into that debate because it would not alter the 
outcome of this case. 
                                    -13- 

Trial Court Opinion

                   UNITED STATES DISTRICT COURT                          
                      DISTRICT OF MINNESOTA                              
UNITED STATES OF AMERICA ex rel.                                         
ANIMAL LEGAL DEFENSE FUND,                                               
                                      Civil No. 21-2061 (JRT/DJF)        

                       Plaintiff,                                        

v.                               MEMORANDUM OPINION AND ORDER            
                                 GRANTING DEFENDANT’S MOTION TO          
HOLDEN FARMS, INC.,                         DISMISS                      

                      Defendant.                                         

    Kristen Elise Rau, UNITED STATES ATTORNEY’S OFFICE, 300 South Fourth 
    Street, Suite 600, Minneapolis, MN 55415, for Plaintiff United States of 
    America.                                                             

    Alastair John MacKinnon Findeis and Ross B. Brooks, BROOKS LLC, 173  
    Huguenot Street, Suite 200, New Rochelle, NY 10801; Daniel Waltz, ANIMAL 
    LEGAL DEFENSE FUND, 611 Pennsylvania Avenue Southeast, Number 484,   
    Washington, DC 20003; Emily R. Stewart, ANIMAL LEGAL DEFENSE FUND,   
    767 Broadway, Number 1209, New York, NY 10003; Gerald Charles Pierre 
    Robinson, Matthew H. Morgan, and Rebekah L. Bailey, NICHOLS KASTER   
    PLLP, 4700 IDS Center, 80 South Eighth Street, Minneapolis, MN 55402, for 
    Relator Animal Legal Defense Fund.                                   

    Dustan J. Cross and Matthew C. Berger, GISLASON & HUNTER LLP – NEW   
    ULM, PO Box 458, New Ulm, MN 56073, for Defendant.                   


    Defendant Holden Farms, Inc. (“Holden”), a Minnesota pork producer, applied for 
a loan under the Paycheck Protection Program (“PPP”) during the COVID-19 pandemic.  
When applying, Holden certified that it was “not engaged in any activity that is illegal 
under federal, state or local law.”  Relator Animal Legal Defense Fund (“ALDF”) brought 
this action under the False Claims Act (“FCA”), claiming that Holden’s attestation was false 
because Holden violated two Minnesota statues and the Swine Health Protection Act 

(“SHPA”), 
7 U.S.C. § 3803
, by engaging in inhumane and unsanitary pork production 
practices.                                                                
    The PPP was a widespread, emergency measure designed to secure the economic 
wellbeing  of  businesses  and  employees,  not  police  agricultural  laws.    Accordingly, 

Holden’s alleged legal missteps were not material to the government’s PPP issuance and 
the Court will grant Holden’s motion and dismiss this action with prejudice.  
                          BACKGROUND                                     
I.   FACTS                                                                

    Holden is a family-owned and managed pork producer with 76 employees and a 
herd of 70,000 sows across various Minnesota locations.  (1st Am. Compl. (“Compl.”) 
¶¶ 17, 70, Aug. 11, 2023, Docket No. 30.)  ALDF is an animal advocacy organization whose 
“charitable mission is to protect the lives and advance the interests of animals through 

the legal system.”  (Id. ¶ 22.)                                           
    Holden unwittingly hired and employed for five months an undercover ALDF 
investigator.  (Id. ¶ 88.)  The undercover employee documented animal cruelty, neglect, 
and instances of “feedback” feeding, in which pig corpses and byproducts were fed to live 

pigs.  (Id. ¶¶ 10–15, 88, 90, 143.)  For purposes of this motion, Holden assumes that its 
conduct violated the SHPA and Minnesota’s anti-cruelty and anti-garbage feeding laws. 
    Shortly after ALDF’s undercover investigation concluded, the COVID-19 pandemic 
swept through the United States.  (Id. ¶¶ 3–4, 88.)  In response, Congress enacted the 

Coronavirus Aid, Relief, and Economic Security Act, a centerpiece of which was the PPP.  
(Id. ¶ 3.)  The PPP was adopted to cope with the economic havoc caused by the pandemic, 
providing employees and small businesses with a lifeline.  (See 
id. ¶ 3
); Bam Navigation, 
LLC v. Wells Fargo & Co., No. 20-1345, 
2021 WL 533692
, at *1 (D. Minn. Feb. 12, 2021). 

    Holden applied for a $2.57 million loan under the PPP which the Small Business 
Association (“SBA”) approved and, ultimately, forgave.  (Compl. ¶ 4.)  Holden’s loan 
application contained a certification that “[t]he Applicant is not engaged in any activity 

that is illegal under federal, state or local law.”  (PPP Appl. at 2.)    
II.  PROCEDURAL HISTORY                                                   
    ALDF initiated a qui tam civil action under the FCA, alleging that Holden falsely 
attested to following all laws because its practices violated the SHPA and Minnesota’s 

anti-cruelty and anti-garbage feeding laws.  (Compl. ¶ 7.)  The United States declined to 
intervene.  (See Order, July 13, 2023, Docket No. 23.)1  Holden now moves to dismiss 




    1 Although the government’s notice of non-intervention and the Court’s subsequent order 
indicated the Court would solicit the government’s written consent before dismissing, “the 
Attorney General’s consent is required only where the relator seeks a voluntary dismissal, not 
where, as here, the district court grants a motion by the defendant to dismiss for failure to state 
a claim.”  (Notice of Election to Decline Intervention at 1, July 3, 2023, Docket No. 20.); United 
States ex rel. Shaver v. Lucas W. Corp., 
237 F.3d 932
, 934 (8th Cir. 2001). 
because the alleged false attestation was not material to the government’s lending 
decision.2                                                                

                           DISCUSSION                                    
I.   STANDARD OF REVIEW                                                   
    A.   Rule 12(b)(6)                                                   
    In reviewing a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), the 
Court considers all facts alleged in the Complaint as true to determine if the Complaint 

states a “claim to relief that is plausible on its face.”  Braden v. Wal-Mart Stores, Inc., 
588 F.3d 585, 594
 (8th Cir. 2009) (quoting Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009)).  The 
Court construes the Complaint in the light most favorable to the plaintiff, drawing all 
reasonable inferences in the plaintiff’s favor.  Ashley Cnty. v. Pfizer, Inc., 
552 F.3d 659, 665
 

(8th Cir. 2009).  Although the Court accepts the complaint’s factual allegations as true, it 
is “not bound to accept as true a legal conclusion couched as a factual allegation,” Bell 
Atl. Corp. v. Twombly, 
550 U.S. 544, 555
 (2007), or mere “labels and conclusions or a 

formulaic recitation of the elements of a cause of action,” Iqbal, 
556 U.S. at 678
 (quotation 
omitted).  Instead, “[a] claim has facial plausibility when the plaintiff pleads factual 
content that allows the court to draw the reasonable inference that the defendant is 
liable for the misconduct alleged.”  
Id.
                                  




    2 Because materiality disposes of this action, the Court will not address the parties’ 
disagreements over Holden’s knowledge.                                    
    At the motion to dismiss stage, the Court may consider the allegations in the 
Complaint as well as “those materials that are necessarily embraced by the pleadings.” 

Schriener v. Quicken Loans, Inc., 
774 F.3d 442, 444
 (8th Cir. 2014).  The Court may also 
consider matters of public record and exhibits attached to the pleadings, as long as those 
documents do not conflict with the Complaint.  Porous Media Corp. v. Pall Corp., 
186 F.3d 1077, 1079
 (8th Cir. 1999).                                               

    B.   The False Claims Act and Rule 9(b)                              
    The FCA creates civil liability to the United States for someone who “(A) knowingly 
presents, or causes to be presented, a false or fraudulent claim for payment or approval; 
[or] (B) knowingly makes, uses, or causes to be made or used, a false record or statement 

material to a false or fraudulent claim . . . .”  
31 U.S.C. § 3729
(a)(1).  The FCA allows a 
private person to bring a so-called “qui tam” civil action for violation of this section in the 
name of the United States Government.  
Id.
 § 3730(b)(1).                  

    Claims under the FCA are subject to the heightened pleading standard of Federal 
Rule of Civil Procedure 9(b).  United States ex rel. Roop v. Hypoguard USA, Inc., 
559 F.3d 818, 822
 (8th Cir. 2009).  “In alleging fraud or mistake, a party must state with particularity 
the circumstances constituting fraud or mistake.”  Fed. R. Civ. P. 9(b).  Accordingly, a 

relator must plead facts such as “the time, place, and content of the defendant’s false 
representations, as well as the details of the defendant’s fraudulent acts, including when 
the acts occurred, who engaged in them, and what was obtained as a result.”  Thayer v. 
Planned Parenthood of the Heartland, Inc., 
11 F.4th 934, 939
 (8th Cir. 2021).  At the same 
time, “knowledge, and other conditions of a person’s mind may be alleged generally.”  
Fed. R. Civ. P. 9(b).                                                     

II.  ANALYSIS                                                             
    The alleged false statement was not material; thus, no FCA liability follows.  
31 U.S.C. § 3729
(b)(4) defines as material any statement “having a natural tendency to 
influence, or be capable of influencing, the payment or receipt of money or property.”3  

Notwithstanding the lenient statutory language, the Supreme Court has characterized the 
materiality inquiry as “rigorous” and “demanding.”  See Universal Health Servs., Inc. v. 
United States ex rel. Escobar, 
579 U.S. 176, 181, 194
 (2016).  Materiality may be resolved 
on the pleadings.  See 
id.
 at 195 n.6.                                    

    In Escobar, the Supreme Court engaged in its most fulsome discussion of the 
materiality requirement.  Both the general principles Escobar espoused and its specific 
teachings on how to apply the materiality requirement counsel dismissal of this action. 

    Beginning with broad principles, the unanimous opinion is replete with warnings 
that the FCA “is not ‘an all-purpose antifraud statute,’” nor is it “a vehicle for punishing 
garden-variety breaches of contract or regulatory violations.”   
Id. at 194
 (quotation 
omitted).  Indeed,                                                        

         [a]  misrepresentation  cannot  be  deemed  material  merely    
         because  the  Government  designates  compliance  with  a       
         particular statutory, regulatory, or contractual requirement as 


    3 The materiality requirement applies equally to claims under 
31 U.S.C. §§ 3729
(a)(1)(A) 
and (B).  See Thayer, 
11 F.4th at 938
.                                    
         a condition of payment.  Nor is it sufficient for a finding of  
         materiality that the Government would have the option to        
         decline to pay if it knew of the defendant's noncompliance.     
         Materiality,  in  addition,  cannot  be  found  where           
         noncompliance is minor or insubstantial. . . .  In sum, when    
         evaluating  materiality  under  the  False  Claims  Act,  the   
         Government’s decision to expressly identify a provision as a    
         condition  of  payment  is  relevant,  but  not  automatically  
         dispositive.                                                    
Id.
  The decision proceeds:                                               
         [I]f  the  Government  required  contractors  to  aver  their   
         compliance with the entire U.S. Code and Code of Federal        
         Regulations,  then  under  this  view,  failing  to  mention    
         noncompliance with any of those requirements would always       
         be material.  The False Claims Act does not adopt such an       
         extraordinarily expansive view of liability.                    
Id. 196.                                                                  
    Under Escobar, then, Holden is not liable under the FCA simply by virtue of its 
attestation that it complied with all laws.  ALDF brings precisely the action the Supreme 
Court  warned  against,  using an all-encompassing certification  of  legality to  ensnare 
Holden in FCA liability.  Thus, the Court will proceed with skepticism while still evaluating 
whether, under the totality of the circumstances, Holden’s noncompliance was material.  
See United States ex rel. Int’l Bhd. of Elec. Workers Local Union No. 98 v. Farfield Co., 
5 F.4th 315, 342
 (3d Cir. 2021) (materiality is a “holistic, totality-of-the-circumstances” 
inquiry).  Escobar establishes a non-exclusive list of factors a court may consider when 
evaluating materiality.  See Escobar, 579 U.S. at 194–95.  Particularly relevant to this 
action are whether the violated condition went to the essence of the bargain, and the 
government’s response in like cases.                                      

    A.   Essence of the Bargain                                          
    Rather than going “to the very essence of the bargain,” the violation alleged here 
was entirely unrelated.  
Id.
 at 193–94 & n.5.  That is, Holden’s noncompliance with 
agricultural laws was too far afield from the purpose of the PPP to sustain an FCA claim. 

    The PPP was implemented to support employees and businesses through the early 
stages  of  the  COVID-19  pandemic.4    It  was  administered  by  the  Small  Business 
Administration and covered a wide range of enterprises, irrespective of their industries.  
See Keeping American Workers Paid and Employed Act, 
Pub. L. No. 116-136, 134
 Stat. 281 

§ 1102(a)(2)(D) (codified at 
15 U.S.C. § 636
(a)(36)(D)).  As instructed by the purpose of 
the PPP and Holden’s application for the loans, the essence of the bargain was that loans 
would be issued (and ultimately forgiven) in exchange for businesses using the funds to 

keep themselves and their employees afloat.  The general certification of compliance with 
all  laws  does  not  reasonably  insert  considerations  of  agricultural  law  into  the 
contemplated bargain.  Because ALDF does not allege Holden used the PPP funds for 



    4  See,  e.g.,  U.S.  Dep’t  of  the  Treasury,  Paycheck  Protection  Program, 
https://home.treasury.gov/policy-issues/coronavirus/assistance-for-small-businesses/paycheck
-protection-program  (last  accessed  Apr.  16,  2024)  (“The  Paycheck  Protection  Program  is 
providing small businesses with the resources they need to maintain their payroll, hire back 
employees who may have been laid off, and cover applicable overhead.”); U.S. Small Bus. Admin., 
PPP Myth vs. Fact, https://www.sba.gov/document/support-ppp-myth-vs-fact (last accessed 
Apr. 16, 2024) (“Every facet of PPP was designed to keep Americans employed.”) 
anything other than payroll and other covered business expenses, it does not plausibly 
allege that Holden deprived the government of the benefit of the contemplated bargain. 

    ALDF  alleges  that  any  legal  noncompliance  undermines  an  entity’s 
creditworthiness and is thus material to the SBA’s lending decisions.  But that would 
reestablish FCA liability for any violation of “the entire U.S. Code and Code of Federal 
Regulations,” contrary to the Supreme Court’s warnings.  See Escobar, 
579 U.S. at 196
.  

Regardless, where forgiveness was anticipated and the “loans” were, in effect, gifts, 
creditworthiness is of less concern.  See 
15 U.S.C. § 636
(37)(J).         
    ALDF also tries to salvage materiality by tying Holden’s noncompliance with anti-

garbage feeding laws to zoonotic disease prevention efforts.  To be sure, many arms of 
the federal government were vigorously fighting COVID-19, a zoonotic disease, at the 
time.  But there is no evidence whatsoever that the PPP was concerned with promoting 
public health.  It would be passing strange for Congress to assign administration of a 

program that was so concerned to the SBA.  Moreover, ALDF does not provide any reason 
to believe the government was concerned with preventing the emergence of a new 
zoonotic disease as compared to fighting the existing pandemic.  And even if ALDF could 
surmount all of these issues, that would salvage only its claims under the garbage feeding 

laws; ALDF provides no reason to believe allegations of animal cruelty would be material. 
    Ultimately, Holden’s alleged violations of an all-encompassing legal attestation do 
not cut to the heart of the PPP bargain when the violations were unrelated to the 

economic focus of the program.                                            
    B.   Government Response                                             
    Escobar identifies two inverse inferences of materiality based on government 
conduct.  See 
579 U.S. at 195
.  If “the Government consistently refuses to pay claims in 

the mine run of cases based on noncompliance with the particular statutory, regulatory, 
or contractual requirement,” that is strong evidence the requirement is material.  
Id.
  
Conversely, “if the Government regularly pays a particular type of claim in full despite 
actual knowledge that certain requirements were violated, and has signaled no change in 

position, that is strong evidence that the requirements are not material.”  
Id.
 
    Beginning with government refusal to pay claims when it learns of noncompliance, 
ALDF alleges materiality “is evidenced by the fact that the Department of Justice (“DOJ”) 

has brought enforcement actions against PPP borrowers who were in violation of laws 
governing their industry.”  (Compl. ¶ 62.)  ALDF cites two instances in which DOJ took 
action, in part, based on a false certification that the borrower was “not in violation of 
any laws” when applying for a PPP loan.  (Id. ¶ 63.)                      

    Those DOJ actions are hardly evidence of consistent refusals to pay “in the mine 
run of cases based on noncompliance” with the PPP certification.  See Escobar, 
579 U.S. at 195
.  Rather, they are two instances when DOJ tacked on FCA claims to much more 
substantial charges of fraud.  (See Compl. ¶ 63.)  In the first case, the government added 
the PPP fraud allegations onto criminal charges for money laundering and fraudulent 
medical billing.  (See id.)  In the second, the centerpiece was again fraudulent medical 

billing, with the PPP false statement also noted.  (Id.)  ALDF fails to identify any instance, 
nor is the Court able to find one, when the government has pursued a PPP borrower solely 
because a business falsely attested to the general legality of its operations. 
    On the contrary, there is good reason to believe the government regularly paid 

similar claims despite knowing that the legality requirement was violated.  See Escobar, 
579 U.S. at 195
.  The SBA issued approximately 11.5 million PPP loans and forgave 10.6 
million.  See Pandemic Response Accountability Committee, Paycheck Protection Program 

(Oct. 23, 2023), https://www.pandemicoversight.gov/data-interactive-tools/interactive-
dashboards/paycheck-protection-program.  Those loans were issued to “provide relief to 
America’s small businesses expeditiously, which is expressed in the Act by giving all 
lenders delegated authority and streamlining the requirements of the regular 7(a) loan 

program.”  
85 Fed. Reg. 20811
, 20812 (Apr. 15, 2020).  As such, SBA allowed “lenders to 
rely on certifications of the borrower in order to determine eligibility of the borrower 
and . . . to rely on specified documents provided by the borrower to determine qualifying 
loan amount and eligibility for loan forgiveness.”  
Id.
                   

    Even under the most ideal circumstances, it is inconceivable that the government 
would assume that 11.5 million businesses across any number of industries would comply 
with all governing laws and regulations, no matter how significant.  Cf. Nieves v. Bartlett, 
139 S. Ct. 1715, 1730
 (2019) (Gorsuch, J., concurring in part and dissenting in part) 
(“[C]riminal laws have grown so exuberantly and come to cover so much previously 

innocent conduct that almost anyone can be arrested for something.”).  That proposition 
is  even  less  conceivable  when  the  government  adopted  an  expedited  process  that 
bypassed usual diligence.  The government must have known that some loan recipients 
would run afoul of their broad attestation of legal compliance, yet it still dispersed nearly 

$800  billion  under  the  PPP  with  minimal  oversight.5    See  Pandemic  Response 
Accountability Committee, Paycheck Protection Program.  Under these circumstances, 
the government did not view as material regulatory violations that technically ran afoul 

of the loan certification language.                                       
    Finally, there is the matter of this specific loan.  The SBA reserved the right to 
require repayment of misused PPP loans but has not done so here.  See 85 Fed. Reg. at 
20814.6  Even after ALDF’s reporting and lawsuit against Holden, it still forgave Holden’s 

loan.                                                                     


    5 To be sure, Escobar spoke of “actual knowledge” that requirements were violated, while 
the Court’s analysis here is of constructive knowledge.  
579 U.S. at 195
.  But Escobar’s list of 
materiality factors was not exclusive, and the level of constructive knowledge is so high here that 
it is as convincing to the Court as actual knowledge would have been.     
    6 Whether the SBA has declined to recoup the money is a different question than whether 
the United States intervened in this suit.  The parties debate the significance of a recent Eighth 
Circuit decision that notes “[a]t least two of our sister circuits have observed that the United 
States’s refusal to intervene in a qui tam FCA case indicates the relator’s case is weak.”  United 
States ex rel. Kraemer v. United Dairies, L.L.P., 
82 F.4th 595
, 606 n.7 (8th Cir. 2023); but see 
id. at 607
  (Colloton,  J.,  concurring  in  the  judgment)  (observing  that  materiality,  and  thus  the 
significance of the government’s non-intervention, was not properly before the court and should 
                                CONCLUSION 
     In sum, both the general tenor of this action and the totality of the circumstances 
indicate the  alleged  false  claim  was  not  material  to the  government’s  PPP  decisions. 
Because  ALDF  does  not  allege  that  Holden  violated  a  material  term  of  its  PPP  loan 
agreement, the Court will dismiss this action with prejudice. 

ORDER

     Based on the foregoing, and  all the files,  records, and  proceedings herein,  IT IS 
HEREBY ORDERED that Defendant’s Motion to Dismiss [Docket No. 46] is GRANTED and 
this action is DISMISSED with prejudice. 

     LET JUDGMENT BE ENTERED ACCORDINGLY. 

DATED:  May 24, 2024                              Otay    | table 
at Minneapolis, Minnesota.                         JOHN R. TUNHEIM 
                                            United States District Judge 

not have been decided).  The Court will not wade into that debate because it would not alter the 
outcome of this case. 
                                    -13- 

Reference

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