Federal job discrimination appeals
Kloeckner v. Solis
In brief
The Court overturned the Eighth Circuit and ruled that covered federal employee discrimination claims belong in district court, even when the Board dismisses a case on procedural grounds.
- Where it stands
- Decided
Decided 9-0 · December 10, 2012 · Opinion by Justice Kagan
- What it’s about
- Carolyn Kloeckner’s federal employment-discrimination case was dismissed by the Merit Systems Protection Board on procedural grounds, and the Eighth Circuit said she had to seek review in the Federal Circuit.
- Who it affects
- Federal employees with these covered claims must seek review in district court, even if the Board dismisses their case on procedural grounds.
Summary: written with AI from the case record.
What it's about
The Supreme Court overturned that ruling and sent the case back to the Eighth Circuit (remanded), deciding that these cases belong in federal district court whether the Board dismisses them for procedural reasons or rules on the discrimination claim.
The Merit Systems Protection Board dismissed Carolyn Kloeckner’s federal employment-discrimination case on procedural grounds. The Eighth Circuit said she had to seek review in the Federal Circuit.
The dispute was about where Kloeckner could seek judicial review, not whether she had proved discrimination.
Question presented
Does a District Court or a Court of Appeals have jurisdiction over an employment discrimination claim that was dismissed by the Merit Systems Protection Board without ruling on the merits?
What the Court decided
Holding
A federal employee who claims that an agency action appealable to the MSPB violates an antidiscrimination statute listed in §7702(a)(1) should seek judicial review in district court, not the Federal Circuit, regardless whether the MSPB decided her case on procedural grounds or on the merits. 639 F. 3d 834, reversed and remanded.
- Result
- Reversed
The Court's reasoning
The Court said the proper court does not change based on whether the Board dismissed the case for procedural reasons or decided the discrimination claim.
The vote
What's next
The case returns to the Eighth Circuit, which must apply the ruling that federal district court is the proper forum. The Supreme Court did not decide whether Kloeckner’s discrimination claim succeeds.
Documents
Opinions
Audio
Docket activity
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AI analysis generated: Case Briefing
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Audio Recording added: Oral Arguments - Kloeckner
Opinion added: Kloeckner
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.