Cathy A. Anderson v. American Federation of Government Employees, AFL-CIO American Federation of Government Employees, AFL-CIO, District 10 American Federation of Government Employees, AFL-CIO, Council 215 And American Federation Government Employees, AFL-CIO, Local 3506

CourtCourt of Appeals of Texas
DecidedApril 7, 2011
Docket01-09-00994-CV
StatusPublished

This text of Cathy A. Anderson v. American Federation of Government Employees, AFL-CIO American Federation of Government Employees, AFL-CIO, District 10 American Federation of Government Employees, AFL-CIO, Council 215 And American Federation Government Employees, AFL-CIO, Local 3506 (Cathy A. Anderson v. American Federation of Government Employees, AFL-CIO American Federation of Government Employees, AFL-CIO, District 10 American Federation of Government Employees, AFL-CIO, Council 215 And American Federation Government Employees, AFL-CIO, Local 3506) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cathy A. Anderson v. American Federation of Government Employees, AFL-CIO American Federation of Government Employees, AFL-CIO, District 10 American Federation of Government Employees, AFL-CIO, Council 215 And American Federation Government Employees, AFL-CIO, Local 3506, (Tex. Ct. App. 2011).

Opinion

Opinion issued April 7, 2011

In The

Court of Appeals

For The

First District of Texas

————————————

NO. 01-09-00994-CV

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Cathy Anderson, Appellant

V.

American Federation of Government Employees, AFL-CIO; American Federation of Government Employees, AFL-CIO, DISTRICT 10; American Federation of Government Employees, AFL-CIO, COUNCIL 215; American Federation of Government Employees, AFL-CIO, LOCAL 3506, Appellees

On Appeal from the 157th District Court

Harris County, Texas

Trial Court Case No. 2009-24849

O P I N I O N

          In this appeal, we decide whether a federal government employee’s state law tort claims against a labor union are completely preempted by the Civil Service Reform Act of 1978.  See 5 U.S.C. §§ 2301–2305 (West 1994 & Supp. 2010), 5 U.S.C. §§ 7101–7154 (West 1996 & Supp. 2010) (West 2010).  Finding no complete preemption under the circumstances presented in this case, we reverse and remand.

BACKGROUND

          Anderson was a group supervisor for the Social Security Administration Office of Disability Adjudication and Review [“ODAR”] in Houston, Texas.  Scott Stier was a case intake assistant and reported to Anderson.  On July 24, 2007, Anderson issued a proposed three-day suspension to Stier for failing to associate mail in a timely manner.  On October 2, 2007, Stier sent a letter to the Agency’s Office of Special Counsel, in which he asserted that Anderson had been confiscating and hoarding his mail, thereby violating his due process rights.  Stier also sent a copy of this letter to Anderson, Melissa Huett, a hearing office manager for ODAR, and Mark Mephail, a hearing office administrative law judge for ODAR.  On November 1, 2007, Huett placed Stier on a one-day suspension, rather than the three-day suspension recommended by Anderson.

          Stier appealed his suspension to the Merit Systems Protection Board, alleging that ODAR’s suspension of him was in retaliation for his complaint about Anderson. On July 15, 2008, an administrative law judge [“ALJ”] upheld Stier’s suspension.  In his order, the ALJ stated, “I find, however that because Huett’s decision to suspend [Stier] was issued . . . just four months after the disclosure of which she had knowledge, a reasonable person could conclude that the disclosure was a contributing factor in the agency’s decision to suspend [Stier].”  Nevertheless, the ALJ upheld Stier’s suspension because he found that ODAR would have taken the personnel action against Stier even if there had been no whistleblowing involved.

          According to allegations in her petition, Anderson discovered in February or early March of 2009 that Stier, who was also an Executive Vice-President of Local 3506 of the American Federation of Government Employees, AFL-CIO, had been sending emails to other union members in Anderson’s office that contained a link to the Local 3506’s website where they would find “disturbing” information about Anderson.  Anderson accessed the website and found the following summary of Stier’s personnel matter:  “ . . . the [ALJ] found that Stier’s disclosure was based on a reasonable belief that Anderson was hoarding mail and that action constituted an abuse of her authority.”

          After seeing the information about her on the union’s website, Anderson filed suit in state court against the American Federation of Government Employees, including the Local 3506, Council 215, and District 10 [hereafter, collectively “the union.”], alleging libel, slander, and intentional infliction of emotional distress.[1]

          The union filed a motion to dismiss based on lack of subject-matter jurisdiction.  Specifically, the union claimed that Anderson’s state tort claims were preempted by the Civil Service Reform Act of 1978 [“CSRA”], which is codified in Title 5 of the United States Code.  The trial court granted to union’s motion and dismissed Anderson’s case.  This appeal followed.

PREEMPTION UNDER THE CSRA

Standard of Review and Applicable Law on Preemption

In filing a plea to the jurisdiction, a litigant challenges the trial court’s subject-matter jurisdiction. Bland Indep. Sch. Dist. v. Blue, 34 S.W.3d 547, 554 (Tex. 2000). In order to prevail, the party asserting the plea must show that, even if all the allegations in the plaintiff’s pleadings are taken as true, there is an incurable jurisdictional defect apparent from the face of the pleadings, rendering it impossible for the plaintiff’s petition to confer jurisdiction on the trial court. Rylander v. Caldwell, 23 S.W.3d 132, 135 (Tex. App.—Austin 2000, no pet.).

Because subject-matter jurisdiction is a question of law, we conduct a de novo review of the trial court’s ruling on the plea. See Mayhew v. Town of Sunnyvale, 964 S.W.2d 922, 928 (Tex. 1998). Upon review, we consider the pleadings and the evidence pertinent to the jurisdictional inquiry. Cnty. of Cameron v. Brown, 80 S.W.3d 549, 555 (Tex. 2002). We do not consider the merits of the case; our jurisdiction is limited to reviewing the grant or denial of the plea to the jurisdiction that was filed. Id.; see also Tex. Civ. Prac. & Rem. Code Ann. § 51.014(a)(8) (Vernon Supp. 2010); Brenham Hous. Auth. v. Davies, 

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Anderson v. United States
364 F. App'x 920 (Fifth Circuit, 2010)
Bush v. Lucas
462 U.S. 367 (Supreme Court, 1983)
United States v. Fausto
484 U.S. 439 (Supreme Court, 1988)
Paul E. Montplaisir v. Richard J. Leighton
875 F.2d 1 (First Circuit, 1989)
Brenham Housing Authority v. Davies
158 S.W.3d 53 (Court of Appeals of Texas, 2005)
Bland Independent School District v. Blue
34 S.W.3d 547 (Texas Supreme Court, 2000)
Twyman v. Twyman
855 S.W.2d 619 (Texas Supreme Court, 1993)
County of Cameron v. Brown
80 S.W.3d 549 (Texas Supreme Court, 2002)
City of Dallas v. First Trade Union Savings Bank
133 S.W.3d 680 (Court of Appeals of Texas, 2003)
Rylander v. Caldwell
23 S.W.3d 132 (Court of Appeals of Texas, 2000)
Mayhew v. Town of Sunnyvale
964 S.W.2d 922 (Texas Supreme Court, 1998)
Gilding v. Carr
608 F. Supp. 2d 1147 (D. Arizona, 2009)

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Cathy A. Anderson v. American Federation of Government Employees, AFL-CIO American Federation of Government Employees, AFL-CIO, District 10 American Federation of Government Employees, AFL-CIO, Council 215 And American Federation Government Employees, AFL-CIO, Local 3506, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cathy-a-anderson-v-american-federation-of-government-employees-afl-cio-texapp-2011.