Caldwell v. Employees Workers Compensation Appeals Board
Civil Action No. 2017-1043
| D.D.C. | Jan 3, 2018Background
- Plaintiff David L. Caldwell, a National Gallery of Art employee, alleges a work-related injury in July 2009 and sought disability compensation.
- Caldwell pursued administrative relief under the Federal Employees' Compensation Act (FECA) through the Office of Workers' Compensation Programs and appealed a decision to the Employees' Compensation Appeals Board (ECAB) in December 2016.
- Unhappy with ECAB's decision, Caldwell filed suit in D.C. Superior Court against ECAB; ECAB removed the case to federal district court and moved to dismiss for lack of subject-matter jurisdiction under Rule 12(b)(1).
- The central factual concessions: the injury occurred while Caldwell performed federal workplace duties and he pursued (and exhausted) the administrative FECA process culminating in an ECAB appeal.
- The district court considered the motion under the Rule 12(b)(1) standard, noting the plaintiff bears the burden to establish jurisdiction and that the court may look beyond the pleadings for jurisdictional facts.
- The court concluded FECA provides the exclusive remedy for Caldwell’s injury and that federal courts lack jurisdiction to review FECA claims decided through the administrative process.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court has subject-matter jurisdiction over Caldwell's claim arising from a workplace injury at a federal institution | Caldwell sought review in court after an adverse administrative/ECAB decision | ECAB: FECA is the exclusive remedy for federal employees; claims are committed to administrative review and not subject to judicial review | Dismissed for lack of jurisdiction: FECA precludes judicial review of such claims |
| Whether the fact Caldwell was denied compensation affects jurisdiction | Caldwell contends he never received compensation and thus seeks court relief | ECAB: denial of compensation does not create jurisdiction; jurisdictional bar applies regardless of outcome | Held that denial of benefits is immaterial; court lacks authority to review FECA determinations |
Key Cases Cited
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (federal courts are courts of limited jurisdiction)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (plaintiff bears burden to establish subject-matter jurisdiction)
- Johansen v. United States, 343 U.S. 427 (1952) (FECA supplies the exclusive remedy for federal employees' work-related injuries)
- Gallucci v. Chao, 374 F. Supp. 2d 121 (D.D.C. 2005) (describing FECA administrative-review process and preclusion of judicial review)
- Spinelli v. Goss, 446 F.3d 159 (D.C. Cir. 2006) (holding courts cannot review FECA-covered claims even when plaintiffs allege they received inadequate compensation)