Beberman v. Rubio

District Court, District of Columbia·Decided March 24, 2025·No. Civil Action No. 2022-0144·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JULIE BEBERMAN, Plaintiff,

v.

Civil Action No. 22-144 (TJK)

MARCO RUBIO, in his official capacity as Secretary of State,

Defendant.

MEMORANDUM OPINION & ORDER Because three tenure boards thought that Julie Beberman had not shown the potential to serve effectively as a Foreign Service officer, she never obtained tenure. Beberman challenged that tenure denial through administrative proceedings and convinced the Foreign Service Griev- ance Board that the tenure boards were improperly constituted because they lacked a member from outside the State Department. So she got a do-over: three new boards would reconsider her can- didacy. Beberman, however, wanted more. She asked the Grievance Board to require the tenure boards to consider extra years of her performance and to state their reasons for any future denials of tenure. More than that, she sought reinstatement pending the tenure boards’ decisions. The Grievance Board denied these requests, leading to this lawsuit.

The Court rejected Beberman’s challenges to the Grievance Board’s decision, partly on jurisdictional grounds and partly on the merits, and granted summary judgment to the State De- partment. Because the Grievance Board had issued its final decision on her grievance, her claim targeting its denial of interim relief was moot. And nothing about how the Board handled her other requests was arbitrary, capricious, or contrary to law. Ever persistent, Beberman moved for re- consideration of all those conclusions. But they remain as sound today as they were then, so she

has not come close to clearing the high standard for altering a judgment. The Court will thus deny her motion. I. Background As discussed in the Court’s Memorandum Opinion, see ECF No. 54, Beberman began working as an “untenured Foreign Service officer generalist” for the State Department in 2011. ECF No. 46-1 at 4. Untenured candidates like Beberman receive only a “limited appointment” that typically “may not exceed 5 years.” 22 U.S.C. § 3949(a). When that trial period ends, the candidate either receives tenure or is “separated from the Foreign Service.” 3 FAM 2216.2-1(c). Tenure boards twice deferred Beberman’s application in 2014 and 2015. ECF Nos. 37-19, 37-20. Both noted that she had violated the Department’s visa policies and, worse still, had “unyield- ing[ly]” insisted that “her judgment was equal to or superior to all” her “peers” and “current su- pervisors.” ECF No. 37-20 at 1; ECF No. 37-19 at 1. Soon after, a third tenure board denied her tenure. See ECF No. 46-1 at 4. Beberman was thus “designated for separation from the Foreign Service,” but she obtained “temporary interim relief” through a different grievance. Id.

Beberman then filed a grievance challenging the tenure boards’ decisions and, when she lost, appealed to the Foreign Service Grievance Board (“the Board”). ECF No. 46-1 at 4–9, 69– 71, 73. She first sought interim relief from separation, which the Board may grant when such separation “is related to a grievance pending before the Board” and when the Board finds that separation “should be suspended” for “one year” or “until the Board has ruled upon the grievance, whichever comes first.” 22 U.S.C. § 4136(8). The Board denied that request because Beberman had not shown that the claimed defect in tenure-board composition “may have been a substantial factor in denial of tenure.” See ECF No. 46-11 at 42–43. Just over two years later, the Board issued its final decision on Beberman’s grievance. See ECF No. 46-23. It granted Beberman’s request to have three “properly composed reconstituted” tenure boards consider her for tenure

because the previous boards had violated a policy requiring that a non-Department member sit on the board. Id. at 15, 22. But it rejected her requests for other relief, including (1) requiring any future tenure board that denies or defers her tenure to give a “statement of reasons,” (2) requiring those boards to consider aspects of her employment record postdating the tenure denial at the end of her five-year candidacy, and (3) reinstating her pending the decisions of the new tenure boards. Id. at 22–23.

Beberman sued, the parties cross-moved for summary judgment, and the Court ruled for the Department. See ECF Nos. 1, 22, 25, 54. First, the Court held that the Board did not act arbitrarily or capriciously by denying Beberman’s request to require the tenure boards to consider her entire employment file—including the parts from after her five-year limited appointment. ECF No. 54 at 5–8. The Board reasonably explained that the “fundamental purpose” of convening properly constituted tenure boards was to put Beberman back in the position she would have been in without the original error, so enlarging her employment file beyond the five-year appointment did not make sense. Id. at 6. To the extent Beberman wanted the tenure boards to review the extra materials to see whether earlier evaluations were “falsely prejudicial,” that claim did not under- mine the Board’s reasoning. Id. at 7. Beberman had filed a different grievance making that alle- gation, and the Board reasonably found that future tenure evaluations should happen after that grievance “decide[d] the contents of [her]” employment file. Id.; see also ECF No. 46-23 at 16– 17.

Second, the Court found that the Board did not arbitrarily or capriciously refuse to require the future tenure boards to state their reasons for deferring or denying Beberman tenure. ECF No. 54 at 8–11. The strictures of the Administrative Procedure Act—including the requirement of reasoned decisionmaking—apply to the Board as the entity that takes final agency action, not to

tenure boards that do not. See id. at 8–9 (citing 22 U.S.C. § 4140(a)). And Beberman offered no justification, statutory or otherwise, suggesting that the Board should have required such an expla- nation in her case. See id. at 9–11.

Third, the Court rejected Beberman’s challenges to the Board’s refusal to reinstate her while the reconstituted tenure boards evaluated her. ECF No. 54 at 11–13. The first of those challenges targeted the denial of interim relief and was moot because the Board had rendered its final decision. Id. at 11–12. And the second faltered for a different reason: the Board reasonably decided that Beberman needed an “affirmative grant of tenure” to justify reinstatement, so her failure to obtain that rendered reinstatement inappropriate. Id. at 12–13.

Beberman moved for reconsideration on all scores. See ECF No. 55 at 1. Her challenge to the decision denying interim relief is not moot, she insists, because the Board could reconsider and award backpay. See 55-1 at 4–7. And she says that the Court clearly erred by refusing to invalidate the Board’s final decision that did not reinstate her or impose Beberman’s preferred marching orders on the reconstituted tenure boards. See id. at 7–20. II. Legal Standard Beberman’s motion to “alter or amend” the Court’s judgment under Rule 59(e) implicates two forms of deferential review. To begin, such relief is “disfavored and should be granted only in extraordinary circumstances.” Rivera v. JPMorgan Chase Bank, N.A., 312 F.R.D. 216, 219 (D.D.C. 2015). And Rule 59(e) is not a vehicle to “relitigate old matters.” Exxon Shipping Co. v. Baker, 554 U.S. 471, 485 n.5 (2008) (citation omitted). Instead, granting a Rule 59(e) motion is appropriate only if “one of three circumstances exist[s]: (1) an ‘intervening change of controlling law,’ (2) ‘the availability of new evidence,’ or (3) ‘the need to correct a clear error or prevent manifest injustice.’” Rivera, 312 F.R.D. at 219 (quoting Firestone v. Firestone, 76 F.3d 1205, 1280 (D.C. Cir. 1996)). Beberman seeks refuge in the third circumstance—clear error, see ECF

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