Michel A. Padilla v. Administrator, Federal Aviation Administration
662 F. App'x 743
| 11th Cir. | 2016Background
- Petitioners Michel A. Padilla and Brian A. Weisblat were FAA-designated Training Center Evaluators whose designations were terminated for cause by the FAA on Sept. 18, 2015.
- Termination letters cited only a regulatory violation: certificating an airman who did not meet English-proficiency requirement (14 C.F.R. § 61.153(b)); no factual details or named airmen were initially provided.
- Petitioners filed administrative appeals arguing the termination letters lacked the specificity required by FAA Order 8900.1 (which directs that reasons be “as specific as possible” and supplies a template/sample letter).
- The FAA later sent letters on Oct. 22, 2015 identifying the specific airmen involved and affirmed the terminations.
- Petitioners sought judicial review, not of the substantive termination decision (which is committed to agency discretion), but of whether the FAA adhered to its internal procedural requirement to state reasons with sufficient specificity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether FAA violated its own rule requiring termination letters be “as specific as possible” | Padilla & Weisblat: letter was insufficiently specific because it cited only the regulation without factual detail or named airmen, impairing ability to appeal | FAA: letter tracked the Order’s template; compliance with the template satisfies the specificity requirement | Court: Held FAA substantially complied; adherence to template demonstrates compliance with Order 8900.1’s specificity requirement |
| Whether court has jurisdiction to review procedural compliance | Petitioners: court may review failure to follow internal procedural rules (procedural challenge) | FAA: substantive termination is unreviewable, but procedural compliance is reviewable | Court: Jurisdiction exists to review whether FAA followed its own procedural rules; did so here and denied petitions |
Key Cases Cited
- Vitarelli v. Seaton, 359 U.S. 535 (1959) (agencies must scrupulously observe their own procedural rules)
- Service v. Dulles, 354 U.S. 363 (1957) (same principle regarding internal agency rules)
- Am. Farm Lines v. Black Ball Freight Serv., 397 U.S. 532 (1970) (internal rules meant to confer important procedural benefits may not require showing of prejudice)
- Sheble v. Huerta, 755 F.3d 954 (D.C. Cir. 2014) (FAA template letter serves as a model for what satisfies Order 8900.1 specificity)
- Lopez v. Fed. Aviation Admin., 318 F.3d 242 (D.C. Cir. 2003) (courts may review procedural challenges to FAA designee terminations)