Court of Petty Appeals: FRACK-PAC v. SBA

FRACK-PAC v. SBA
77 U.Va 20 (2025)

Dᴇᴍɪᴛʀʏ, C.J., delivers the opinion of the Court, in which Bᴇʀᴋʟɪᴄʜ, Bᴇᴄᴋᴇʀ, Wᴜ, and Vᴀɴɢᴇʀ, JJ., join.

Gʀᴀꜰꜰ, J., concurring in the judgment and dissenting in part.

Aʟʟᴀʀᴅ, C.J. Emeritus, concurs in part and concurs in the judgment.

Dᴇᴍɪᴛʀʏ, C.J., delivering the opinion of the Court.

The Court is, yet again, dragged into a quagmire of political theater, prompted by the self-styled “Friends of Ryan Keane for 3L Senator Political Action Committee,” which, much like Ryan’s campaign promises, appears to consist entirely of Ryan Keane. We commend Appellant Keane for preparing this petition pro se, though we note that “pro se” is not Latin for “without merit,” despite the filing’s valiant effort to redefine it.

Let us begin with the facts as alleged. Ryan, in a bid to “radically” change SBA governance, proposed policies ranging from logistical chaos (halving parking) to outright academic sabotage (grading LRW softball participation). These proposals were greeted with “broad positivity,” which we take to mean either GroupMe sarcasm or Stockholm Syndrome.

We pause to recognize that Ryan’s particular brand of whimsy—overly elaborate, fueled by joie de vivre and pure entropy—is not without its charms. There is something undeniably refreshing about someone having this much energy to commit to satire, civic engagement, or possibly both. It is, dare we say, the kind of boldness and unbothered mischief more often observed in men, who historically have had the luxury of treating institutions like playgrounds instead of fortresses.

Ryan’s ability to run a joke into the ground and build a subterranean garage beneath it is, frankly, impressive.

Nevertheless, the Court cannot ignore that this enthusiasm crashed headlong into the SBA’s hard, cold reality: bureaucratic paperwork. Indeed, Ryan’s chief legal argument boils down to "I forgot to fill out a form, but have you considered that I'm funny and people like me?" And while we appreciate the sentiment, we feel compelled to point out that the SBA’s grievous act of enforcing the basic filing deadline for candidate paperwork is not tantamount to a grand conspiracy. The Court notes that while Ryan’s campaign garnered 133 likes in the GroupMe, one must consider that GroupMe is also a place where students routinely “like” a photo of free pizza crumbs in Hunton & Williams. The bar is low, Ryan. The bar is subterranean.

Still, Ryan raises a point worth considering. It is, objectively, hilarious that while he wages this mock-heroic battle against red tape, several 3L Senator seats remain vacant—untouched by even the faintest whiff of competition. It seems the SBA, in its zeal to regulate, forgot the simple truth that no one actually wants to be in the SBA. Perhaps a system so convoluted that it accidentally filters out the only candidates with the free time and chaotic spirit to run is one in need of recalibration. The Court suggests that if the SBA wishes to attract more than the occasional résumé maximizer or future HOA tyrant, it might consider lowering the drawbridge a tad.

As for Appellant’s argument based on precedent—namely that “1Ls must always lose”—this Court will remind Ryan that the SBA includes not only 1Ls but also 2Ls, 3Ls, 6Ls, ANG, and assorted shadowy upperclassmen who view 1L antics like aging aristocrats watching peasants reenact Shakespeare in the mud. That said, this “1Ls must lose” maxim, though time-honored, does not extend to excusing Appellant’s Olympic-level failure to read a simple election email or complete paperwork. The Court will not grant relief simply because Appellant lost a battle with Outlook and a PDF attachment. Further, 1Ls losing is not mutually exclusive with 2Ls losing—in plainer terms, 1Ls have already lost by deciding to attend law school, a ruinously expensive venture that–at best–grants you entry into a miserable profession rife with substance abuse, broken relationships, and appallingly self-absorbed colleagues. It is true that 1Ls must lose, but really, haven’t we all already lost?

Turning to Appellant’s final argument—thinly veiled bribery regarding the release of the coveted “VLW” acronym—this Court is both impressed and mildly offended. Impressed by the audacity; offended by the implication that our sacred institution could be swayed by such blatant quid pro quo. Rest assured, Ryan, this Court is perfectly capable of selling out for far less.

In conclusion, the Court finds itself once again (?) adjudicating a case in which Ryan Keane tilts at windmills of his own construction (Quixotic!). We deny the petition in full, though we do suggest Ryan consider starting the “Virginia Law Ryan Review” on his own time, ideally as a lifestyle brand for those who confuse chaos with charisma.

IT IS SO ORDERED.

ADDENDUM: The Court takes judicial notice of Ryan’s next likely step: submitting a follow-up petition to be named "Supreme SBA Overlord." We preemptively deny, though we will entertain a petition to depose Law Weekly’s most cursed prodigal son/absentee dad,[1] current SBA President Mark Graff.

Postscript: The Court reminds the SBA that leaving empty chairs in the Senate is not a power move; it’s an open invitation to chaos and coups.

GRAFF, J., concurring in the judgement and dissenting in part.

I could not support (or assuredly enforce) a verdict supporting Mr. Keane’s instatement as 3L Senator purely off vibes. Accordingly, I agree with the Court’s responses to Appellant’s arguments, especially including that “no one actually wants to be in SBA.”[1]

I dissent, in part, to the Court’s rejection of Mr. Keane’s “chief legal argument… [that] I forgot to fill out a form, but have you considered that I'm funny and people like me?" I know of at least two (2) people who like Ryan. Further, the Court asserts the “bar is low” for GroupMe likes; as anyone who knows the hollow feeling of a GroupMe “miss” will assuredly agree, Ryan’s 133 likes are indeed impressive, and lend credulity to the notion that he’s funny. Though the logic of his argument ultimately fails, the Court may be incorrect in implying that he is neither “funny” nor “liked.”

On a more serious note, Mr. Keane’s predicament is unfortunate. Though his petition and campaign are satirical, it is heartening to see such enthusiasm for student self-governance. The majority correctly points out that many Senate spots were not run for; hopefully SBA can do more to engage with the student body and encourage participation in elections.

[1] This opinion is satirical and written entirely in my personal capacity. Please do not impeach me before I have taken office.       

Aʟʟᴀʀᴅ, C.J. Emeritus, concurring in part and concurring in the judgment.

Chief Justice Demitry appropriately denies Mr. Keane’s petition, which substitutes braggadocio for competent reliance on this Court’s precedent. Where shall I begin?

Mr. Keane styles the question presented as whether “the Court of Petty Appeals [is] willing to have the courage . . .” I will stop you there. This is the Court of Petty Appeals. Leave your courage at the door.

Mr. Keane proceeds to make unsubstantiated claims about the purpose of elections. In claiming that SBA Elections are mere “popularity” contests, Keane offends this Court’s commitment to democracy. See Commonwealth v. Allard, 77 U.Va 11 (2024) (Allard, C.J., dissenting) (“The Law Weekly is famous at UVA Law for many things, chief among them its steadfast commitment to democracy.”). And Mr. Keane gets this entirely wrong. SBA Elections have almost nothing to do with popularity, as they are decided by approximately ten voters.

In his brief attempt to rely on this Court’s precedent, Mr. Keane cites 1Ls, 2Ls, 3Ls, et al. v. The Pavilion at North Grounds, 76 U.Va 1 (2023) for the proposition that 1Ls always lose. Kudos to Mr. Keane for his familiarity with our most frequently invoked maxim. But his reliance on Pavilion is entirely misplaced. As the codification of the 1Ls rule makes clear, “1Ls always lose unless it is funnier for them to win.” PRCP 2 (emphasis added). Mr. Keane’s failure to address the balance of whimsy in this case reflects a complete misunderstanding of our law.

Apparently pleased with his roughshod reasoning, Mr. Keane writes in closing that the Court is “bound by” its precedent. Mr. Keane again reveals his ignorance of our law. See PRCP 1. (“We do what we want.”).

At only one point does Mr. Keane’s brief approach a satisfactory reliance on this Court’s precedent—his invocation of a bribe. It is on this point that I differ, though only slightly, with the majority. As I recently wrote, I most certainly could be swayed by a blatant quid pro quo. See Intoxicated Student Association v. University of Virginia, 77 U.Va 18 (2025) (Allard, C.J. Emeritus, concurring) (“We are not above being bribed. Seriously, we’d love it.”). I can only assume, based on the rest of his brief, that Mr. Keane’s allusion to our recent case law is accidental. Regardless, his proffered bribe—settling the “VLW” acronym debate in our favor—is an offense to this Court’s authority. Only we can settle that matter; SBA has no authority over it.

I am left with the impression that Mr. Keane’s brief is no more serious than his SBA candidacy. Admittedly, for a Court that asks its litigants to submit their filings in Jokerman font, see PRCP 11(a), Mr. Keane’s jocular attitude should perhaps be encouraged. But would we still be the Court of Petty Appeals if we didn’t eviscerate those who are bored enough to write for us? No, we would not.

[1] Went to the gas station to get zyns last year during a Law Weekly meeting, was never seen again at a meeting until campaign season.