American Federation of Government Employees, Local 3369 v. United States Social Security Administration

CourtDistrict Court, S.D. New York
DecidedMarch 31, 2026
Docket1:23-cv-03595
StatusUnknown

This text of American Federation of Government Employees, Local 3369 v. United States Social Security Administration (American Federation of Government Employees, Local 3369 v. United States Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Federation of Government Employees, Local 3369 v. United States Social Security Administration, (S.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, LOCAL 3369,

Plaintiff,

v. 23-CV-03595-LTS

UNITED STATES SOCIAL SECURITY ADMINISTRATION,

Defendant.

MEMORANDUM OPINION AND ORDER1 Plaintiff American Federation of Government Employees, Local 3369 (“Plaintiff” or “AFGE, Local 3369”) brings a one-count action against Defendant United States Social Security Administration (“Defendant” or “SSA”) for violation of the Freedom of Information Act (“FOIA”), 5 U.S.C. section 552. (Docket entry no. 6 (“Am. Compl.”).) Plaintiff claims procedural violations of 5 U.S.C. sections 552(a)(6)(A)(i), 552(a)(6)(B)(ii), and 552(a)(7)(B)(ii), as well as a substantive violation of 5 U.S.C. section 552(a)(3) for improperly withholding certain documents. (Id. ¶¶ 59-63; id. at 13-14.) Plaintiff seeks declarations regarding the allegations of procedural noncompliance and orders for the disclosure of material that Plaintiff claims has been withheld improperly. In response, Defendant moves to dismiss the Amended Complaint under Federal Rule of Civil Procedure 12(b)(6) or, in the alternative, for summary judgment under Rule 56. (Docket entry no. 14.) The Court has subject matter jurisdiction under 28 U.S.C. section 1331 and 5 U.S.C. section 552(a)(4)(B). The Court has considered carefully

1 All pincites to materials filed on the docket refer to ECF-designated pages. the parties’ submissions. (Docket entry no. 15 (“Def. Mem.”); docket entry no. 16 (“Christ Decl.”); docket entry no. 21 (“Pl. Opp.”); docket entry no. 22 (“Def. Reply”)). For the following reasons, Defendant’s motion for summary judgment dismissing the amended complaint is granted.

I. BACKGROUND The following background summarizes the pertinent allegations of the Amended Complaint (docket entry no. 6) and the facts proffered by Defendant through the Declaration of Michelle Christ (docket entry no. 16), who was the Deputy Executive Director for the Office of Privacy and Disclosure in the Office of the General Counsel and the Social Security Administration. The parties’ submissions reveal no material disputed facts.

A. The 2017 Executive Orders In May 2017, President Donald Trump issued Executive Orders 13826, 13837, and 13839 (the “2017 Executive Orders”). (Am. Compl. ¶ 27.) These Executive Orders were designed to minimize the effectiveness of federal employee unions, put a barrier between such unions and the employees they represent, and deny and deprive federal employees of certain rights and privileges. (Id.) In particular, Executive Order 13837 evicted unions from federal buildings that they had occupied for decades. (Id.) B. The Collective Bargaining Agreements In 2012, the American Federation of Government Employees (“AFGE National”) and Defendant SSA had entered into a collective bargaining agreement (the “2012 National Agreement”). (Id. ¶ 33.) The 2012 National Agreement appears to have expired in 2016. (See

id. ¶ 41.) Negotiations on a new collective bargaining agreement continued into September 2019, alongside AFGE National’s legal challenges to the 2017 Executive Orders. (Id. ¶ 34); see Am. Fed’n of Gov’t Emps., AFL-CIO v. Trump, 318 F. Supp. 3d 370, 377 (D.D.C. Aug. 25, 2018), rev’d and vacated, 929 F.3d 748 (D.C. Cir. July 16, 2019), rehearing en banc denied (Sep. 25, 2019) (dismissing AFGE National’s challenges to the 2017 Executive Orders for lack of

subject matter jurisdiction). On September 27, 2019, a few days after AFGE National’s challenges to the 2017 Executive Orders were dismissed, AFGE National entered into a collective bargaining agreement with Defendant. (Am. Compl. ¶ 35.) Plaintiff alleges that AFGE National signed the agreement under “duress” because Defendant threatened to fully enforce the 2017 Executive Orders. (Id.) C. The 2021 Executive Order On January 22, 2021, President Joseph Biden issued Executive Order 14003, “Protecting the Federal Workforce,” which revoked and rescinded the 2017 Executive Orders. (Id. ¶ 29.) On March 5, 2021, the Office of Personnel Management issued its “Guidance for

Implementation of Executive Order 14003 – Protecting the Federal Workforce” (the “Guidance”) (Id. ¶ 30.) The Guidance directed all federal agency heads to revisit and identify any changes in policy or collective bargaining agreements that reflected implementation of the 2017 Executive Orders, as well as to engage the affected unions “as soon as practicable” and “suspend, revise or rescind the actions covered in any agency policy.” (Id. ¶¶ 30-31.) Guidance 14003 also specifically rescinded the office space eviction imposed by the 2017 Executive Orders. (Id. ¶ 32.) D. The Office Space Dispute Shortly after the Guidance was issued, Plaintiff made a request to restore its union office space, from which it had been evicted under the 2017 Executive Orders. (Id. ¶ 36.) This request was denied by the Flushing Area District Manager. (Id.) Plaintiff subsequently filed a grievance against Defendant and, during the course

of the grievance dispute, Plaintiff served on Defendant a subpoena for records. (Id. ¶ 37.) In response to the subpoena, Defendant asserted privilege and produced an “Agency Privilege Log,” which withheld five emails and one conference call. (Id. ¶ 38; docket entry no. 16-1 (“Christ Decl. Ex. 1”) at 4.) The Agency Privilege Log (Christ Decl. Ex. 1, at 4) is reproduced below: Type of Author Recipient Date Title/ Subject Matter Privilege Explanation Document Description Claimed Conference Katherine Employee Unknown Agenda Executive Order Guidance Topics for Call Agenda Hannah Relations/ 14003 call Labor regarding Relations 14003 guidance Email Joe OLMER 2/3/2021 Information on Addressing Guidance Internal Sullivan Executive union emails guidance on Order on regarding addressing Protecting the Executive Order emails Federal 14003 Workforce Email Jim OLMER 1/25/2021 Information on Executive Order Guidance Internal Julian Executive 14003 and guidance on Order on union demands 14003 Protecting the Federal Workforce Email Joe OLMER 2/9/2021 Initial Initial Guidance Guidance Internal Sullivan Guidance on on Executive guidance on Executive 14003 14003 Order on Protecting the Federal Workforce Type of Author Recipient Date Title/ Subject Matter Privilege Explanation Document Description Claimed Email OLMER OLMER 3/17/2021 Supplemental Clean Record Guidance Internal Guidance on guidance under Guidance on Clean Records the executive 14003 and orders 13839 Email OLMER OLMER 3/19/2021 Internal Updated Guidance Internal Guidance on guidance on Guidance on EO 14003 implementation 14003 of 14003 Five of the six withheld communications were sent to OLMER, which is Defendant SSA’s Office of Labor-Management and Employee Relations. (Christ Decl. ¶ 12.) OLMER is a component within SSA’s Office of the Deputy Commissioner (“DHCR”). (Id.) DHCR directs the administration of SSA’s human resources programs, including personnel management, labor management, employee relations, and training. (Id. ¶ 13.) OLMER manages SSA’s labor management and employee relations program, including the development and evaluation of the program and the formulation of SSA-wide labor management and employee relations policy.

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American Federation of Government Employees, Local 3369 v. United States Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-federation-of-government-employees-local-3369-v-united-states-nysd-2026.