Sun v. D.C. Office of Employee Appeals

1. Whether a court’s inherent power to set aside a judgment for fraud on the court—as preserved in Super. Ct. Civ. R. 60(d)—is subject to a “reasonable time” limitation when an adjudicator, lacking mandatory statutory qualifications, intentionally subverts a superior court’s remand mandate to favor a party, thereby violating the Due Process Clause and undermining the integrity of the judicial process. 2. Whether a court violates the Party Presentation Principle and the Fifth Amendment Due Process Clause by rejecting an agency’s functional confession of error and unilaterally asserting defenses on behalf of the government to uphold a decision rendered by an unlicensed examiner. 3. Whether a tribunal violates the Mandate Rule and the Fifth Amendment Due Process Clause by unilaterally altering the legal framework on remand such that it failed to adjudicate the causal link in the prima facie stage of the McDonnell Douglas framework. 4. Whether an administrative decision that is void for lack of jurisdictional authority can have preclusive effect over a federal Title VII claim, particularly where that claim was decided under the McDonnell Douglas framework in conflict with the standard for summary judgment.