Christian v. New York Department of Labor (1974)

Discharged federal probationary employees denied unemployment compensation by a state agency should have been informed of their “right to additional information or reconsideration and correction” of the findings.

Citation: 414 U.S. 614 (1974)
Date decided: Jan 21, 1974
Longer case name: Christian v. New York Department of Labor
Law type: Civil
Jurisdiction level:Federal
State of origin: New York
Topic(s):Due process, Equal protection, Federal employees, and Unemployment compensation
Lists:Important cases
Attorneys:E. Richard Larson (National Employment Law Project) argued the cause for appellants. With him on the briefs were Dennis R. Yeager and Robert P. Roberts.
Others involved:Mozart G. Ratner, George B. Driesen, Leo M. Pellerzi, and George Kaufmann filed a brief for the National Association of Letter Carriers AFL-CIO et al, as amici curiae urging reversal.
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Case Importance

Discharged federal probationary employees should have been told that they were eligible for unemployment compensation.

Case Details

(The syllabus is not part of the opinion, but is a summary prepared by the court reporter as a convenience.)



Appellants, former federal probationary employees who were denied benefits under the Unemployment Compensation for Federal Employees Program, brought this action in District Court seeking declaratory and injunctive relief against provisions of the Program and its implementing regulations that they contended operated to deny them a hearing on the factual basis for their removal from federal service, for the purpose of determining their eligibility under state law for unemployment compensation. They claimed that the Act requires such a hearing and, alternatively, that the denial of a hearing deprived them of due process and equal protection. A three-judge District Court held that the statute does not require a hearing to contest the employing agency’s findings; dismissed the constitutional claims against the federal defendants for lack of subject matter jurisdiction; and held that the state agency’s denial of a hearing did not violate the Due Process or Equal Protection Clauses.

Held: Any decision upon appellants’ statutory or constitutional claims would be premature in view of the fact that the record does not disclose that the state agency, in notifying appellants of the adverse determinations, informed them, as it was required to do by the applicable regulation, of their “right to additional information or reconsideration and correction” of the findings by the employing agencies; or that appellants invoked the available procedure entitling them to request their agencies “to reconsider and correct” those findings. The District Court’s dismissal of the suit as to both federal and state defendants is therefore vacated with directions that the court determine whether appellants should be permitted to invoke the applicable administrative procedures. Pp. 414 U. S. 618-624.

347 F. Supp. 1158, vacated and remanded.

BRENNAN, J., delivered the opinion for a unanimous Court.

From the opinion

Appellants, discharged federal probationary employees, were denied unemployment compensation by the New York State Department of Labor, an “agent of the United States” under agreement with the Secretary of Labor for the administration of the Unemployment Compensation for Federal Employees (UCFE) Program, 5 U.S.C. § 8501 et seq. Appellants brought this class suit against that state agency in the District Court for the Southern District of New York, joining as defendants the United States Department of Labor, which is charged with overall responsibility for the program, and the United States Post Office Department and Department of the Treasury, which are appellants’ former employing agencies.

Appellants alleged that the state agency had based its adverse determinations on findings of fact made ex parte by the federal employing agencies, and that the state agency had refused to afford either appellant a hearing at which he or she could attempt to contest those federal findings. The result, appellants claimed, was a deprivation of any opportunity to be heard, in violation of the UCFE statutes and of the Fifth and Fourteenth Amendments. They sought certification as representatives of the class of persons similarly situated, the convening of a three-judge court, and declaratory, injunctive, and mandamus relief.

The District Court viewed the suit as a constitutional attack on 5 U.S.C. § 8506(a), [Footnote 1] which, inter alia, makes the findings of the federal employing agency “final and conclusive” on the state agency, and on the regulations of the Secretary of Labor promulgated, pursuant to 5 U.S.C. § 8508, to enforce the program. [Footnote 2] A three-judge court was convened. That court, in an opinion reported at 347 F. Supp. 1158 (1972), first examined the statutory claim and held that § 8506(a) does not require that appellants receive either a state or a federal hearing to contest the employing agency’s findings. Next, the court noted that jurisdiction over the claims against the federal defendants had been alleged only under 28 U.S.C. § 1361, providing for mandamus actions. Holding that § 1361 will not support a constitutional challenge to a statute, the court dismissed the constitutional claims against the federal defendants for lack of subject matter jurisdiction. [Footnote 3] Finally, turning to the constitutional claims against the state defendants, the court, apparently assuming for purposes of argument that the federal defendants were not constitutionally required to afford appellants a hearing, treated the claims as asserting that denial of a state hearing was, in effect, a denial of any hearing on the federal findings. The court held that the denial of a hearing by the state agency did not violate either the Due Process or the Equal Protection Clause.

Last modified: 2022-12-27 12:45
Case internal grade: A | Case internal status: OK |
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