Jain-Miecell Roberson v. United States

The Civil Service Reform Act of 1978 (CSRA), 5 U.S.C. § 1101 et seq., provides a comprehensive framework for reviewing adverse personnel actions against federal employees, channeling most claims to the Merit Systems Protection Board (MSPB) with judicial review exclusively in the Court of Appeals for the Federal Circuit. In Perry v. Merit Systems Protection Board, 582 U.S. 420 (2017), this Court held that “mixed cases”—those combining CSRA-covered per­ sonnel actions with discrimination claims under fed­ eral anti-discrimination laws—must be reviewed in district court under 5 U.S.C. § 7703(b)(2). However, this Court has not addressed whether claims alleging constitutional violations (e.g., due process deprivations) or state-law torts intertwined with CSRA-covered actions constitute “mixed cases” warranting district court jurisdiction, or whether such claims are preempted by the CSRA and funneled exclusively to the MSPB and Federal Circuit. The Questions Presented Are:

1. Whether a federal employee’s claims alleging constitutional due process violations and state-law torts (e.g., negligence and emotional distress under Penn­ sylvania law) arising from a CSRA-covered personnel action (e.g., detail, transfer, or reassignment) constitute a “mixed case” eligible for district court review under Perry v. Merit Systems Protection Board, or whether such claims are precluded from district court jurisdic­ tion by the CSRA’s exclusive remedial scheme.

2. Whether the CSRA precludes district court jurisdiction over constitutional claims challenging the validity of a federal statute or regulation governing