The question
Whether the Fourth Circuit violated the principle of party presentation when it vacated and remanded based on an issue no party had raised, namely whether current conditions at the MSPB affect Congress's intent to channel covered federal-employee claims out of district court.
Margolin v. NAIJ
What the Court decided
The Court reversed the Fourth Circuit and remanded for further proceedings. The Fourth Circuit had agreed that the immigration judges' association's claims were covered by the Civil Service Reform Act and thus barred from district court, but it vacated and remanded on its own initiative to examine whether removal of the Special Counsel and MSPB members meant the CSRA no longer functioned as Congress intended. The parties had never raised that question, and both had conceded the CSRA channels covered claims to the MSPB. Deciding a case different from the one the parties advanced violated the principle of party presentation and was an abuse of discretion.
How the justices split
UnanimousPer curiam (unsigned)
Delivered by the Court
Federal courts adhere to the principle of party presentation and decide only the questions the parties present. Both parties conceded that the CSRA channels covered federal-employee claims to the MSPB and confined their dispute to whether the association's specific claims were covered. The Fourth Circuit instead addressed on its own initiative whether changed conditions at the MSPB meant Congress no longer intended any such claims to be channeled, and remanded for factfinding on that question without giving either side a chance to address it. That departure from party presentation was an abuse of discretion, so the judgment is reversed and the case remanded.
Concurring
Thomas, joined by Barrett
Thomas agreed the Fourth Circuit erred on party presentation and wrote separately to argue its decision was also wrong on the merits. Under Elgin v. Department of Treasury, covered employees appealing covered agency actions must proceed exclusively through the CSRA's statutory review scheme, and the Fourth Circuit conceded both that the association's members are covered employees and that the policy is a covered action. A change in conditions, such as the President's removal of the Special Counsel and MSPB members, does not change the meaning of the statute or the binding force of the Court's interpretation of it. Statutes change only when Congress changes them, not when judges conclude they no longer serve Congress's purposes.
How we know · 5 sourced claims
The Court reversed the judgment of the Fourth Circuit and remanded for further proceedings.
Source: syllabus, Held
The decision was issued per curiam.
Source: syllabus, lineup
Justice Thomas filed a concurring opinion, joined by Justice Barrett.
Source: syllabus, lineup
The Court held that the Fourth Circuit violated the principle of party presentation by deciding the case on a ground no party had raised and without supplemental briefing.
Source: syllabus, Held
Both parties conceded that the CSRA channels covered federal-employee claims to the MSPB and disputed only whether the association's specific claims were covered.
Source: syllabus, Held