Law School Case Brief
Ass'n of Admin. Law Judges v. Colvin - 777 F.3d 402 (7th Cir. 2015)
The Administrative Procedure Act provides that when conducting a hearing an administrative law judge is not subject to direction or supervision by other employees of the agency that he is employed by and may not be assigned duties inconsistent with his duties and responsibilities as an administrative law judge.
The Association of Administrative Law Judges (the “Association”) was a union which represented the Social Security Administration's administrative law judges in collective bargaining with the Administration, pursuant to the Federal Labor-Management Relations Act. The Association, together with three administrative law judges employed by the Social Security Administration filed a suit against the head of the Administration, contending that by requiring its administrative law judges to decide at least 500 social security disability cases a year, the Administration has interfered with the administrative law judges' decisional independence, in violation of the Administrative Procedure Act. The Administrative Procedure Act provided that when conducting a hearing, an administrative law judge was not subject to direction or supervision by other employees of the agency that he was employed by, and may not be assigned duties inconsistent with his duties and responsibilities as an administrative law judge. The district court dismissed the complaint for want of subject-matter jurisdiction, holding that the Civil Service Reform Act of 1978 )(CSRA) precluded the plaintiffs' resort to the Administrative Procedure Act. The district judge ruled that the plaintiffs were alleging a "significant change in duties, responsibilities, or working conditions," and if this is correct, their exclusive remedy is under the CSRA.
Did the district court err in its decision to dismiss the complaint, which was filed under the Administrative Procedure Act and alleged incidental and unintentional effects of a change in working conditions of administrative law judges?
The decision of the district court was affirmed by the U.S. Circuit Court of Appeals, which held that an action by a union and administrative law judges employed by the Social Security Administration, alleging that an increase in their required quota of cases to resolve was an interference with their decisional independence in violation of 5 U.S.C.S. §§ 554(d)(2) and 3105 of the Administrative Procedure Act, lacked merit because the Civil Service Reform Act of 1978 (CSRA) controlled. Even assuming that the correct remedy was applied, the Court ruled that there was no violation of 5 U.S.C.S. § 2302(a)(1), (2)(A)(xii), (b) of the CSRA because the significant change in duties due to the increase in production quota was not prohibited.
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