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Supreme Court rules in federal jurisdiction case

The US Supreme Court [official website] on Monday ruled 6-3 [opinion, PDF] that the Civil Service Reform Act (CSRA) [text] provides the exclusive form of judicial review for employment grievances of qualifying federal employees. In Elgin v. Department of Treasury [SCOTUSblog backgrounder], Michael Elgin and several other former federal employees argued that a law [5 USC § 3328 text] banning individuals who fail to register for selective service from serving in certain federal positions was unconstitutional, and thus their dismissals from their positions were not justified. Elgin had originally brought his case before the Merit Systems Protection Board (MSPB), a reviewing body created by the CSRA to hear cases of federal employee grievances. The MSPB ruled that it did not have jurisdiction to consider the constitutionality of a federal law, even when that law is the basis for dismissal of an employee. The issue before the court was whether the petitioners may bring this claim in federal district court as an alternative to the MSPB. In its decision, the court determined that because federal court is the avenue of appeal from a MSPB decision, the petitioner is precluded from bringing the case in federal court originally: "we conclude that it is fairly discernible that the CSRA review scheme was intended to preclude district court jurisdiction over petitioners' claims." Justice Alito, joined by Justices Ginsburg and Kagain dissented from the ruling, finding that the constitutional issue in this case is not the kind of review the MSPB was designed to conduct.

The court affirmed the decision [text] of the US Court of Appeals for the First Circuit, which held that the CRSA was the sole avenue of relief for the petitioners. The case was originally brought in the US District Court for the District of Massachusetts, where the court found that it did have jurisdiction, and ruled against the employees on the merits. The Supreme Court's affirmance of the First Circuit vacates the decision of the District court and dismisses the case in federal court. The petitioners are not barred from further pursuing their cases in the MSPB, as long as the claim is within the statute of limitations.

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