Elgin v. Department of the Treasury (2011)
- Docket
- 11-45
- Decided
- 2011-01-01
Summary
Question: If a federal employee has a constitutional claim for equitable relief, do the federal district courts have jurisdiction, or does the Civil Service Reform Act preclude that jurisdiction? Conclusion: The Civil Service Reform Act precludes jurisdiction. Justice Clarence Thomas, writing for a 6-3 majority, affirmed the First Circuit. The Court held that the Act precluded the federal district courts from hearing Elgin's claim even though Elgin brought a constitutional challenge. There is no textual basis to support Elgin's argument that the Act contains an exception for constitutional challenges to federal statutes. Justice Thomas argued that carving out an exception for constitutional challenges would undermine the act's purpose of creating of an integrated scheme of administrative and judicial review for aggrieved federal employees. The Act does not foreclose all judicial review of Elgin's claim. Instead, the Act directs it to the U. S. Court of Appeals, Federal Circuit.. Justice Samuel A. Alito, Jr. dissented, arguing that congress did not intend for the MSPB to hear constitutional challenges. The MSPB lacks the authority and ability to properly adjudicate federal constitutional challenges. Also, Congress did not expressly limit the federal courts' ability to hear constitutional challenges related to federal employment. Justice Ruth Bader Ginsburg and Justice Elena Kagan joined in the dissent.