Heider v. United States

521 F. Supp. 422, 1981 U.S. Dist. LEXIS 15624
CourtDistrict Court, M.D. Florida
DecidedSeptember 8, 1981
DocketNo. 76-186-Civ-J-WC
StatusPublished

This text of 521 F. Supp. 422 (Heider v. United States) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Heider v. United States, 521 F. Supp. 422, 1981 U.S. Dist. LEXIS 15624 (M.D. Fla. 1981).

Opinion

SUMMARY JUDGMENT

HIGBY, District Judge.

This is an action for a judgment declaring how Plaintiff Paul H. Heider’s Civil Service pension payments should be calculated. The parties agree that the facts are undisputed and summary judgment is appropriate.

Heider was a Federal Civil Service employee working as a Special Agent with the Bureau of Alcohol, Tobacco and Firearms, Department of the Treasury, GS-1811-12 (Special Agent/Analyst). He retired from active service effective January 31, 1975, with total creditable service of 28 years, 11 months, and 16 days. Upon his retirement Heider became entitled to Civil Service retirement benefits. 5 U.S.C. § 8336(c) (1977).

During his active service Heider’s salary included his regular pay and “premium pay.” Premium pay is the Civil Service term for compensation for uncontrolled overtime work as a criminal investigator. 5 U.S.C. § 5545(c)(1) (1977). The Civil Service Commission however based Heider’s pension only upon his regular compensation. The Commission’s Bureau of Retirement, Insurance and Occupational Health gave Heider notice of its position in the annuity statement it provided.

Heider contended that his premium pay ought to be counted in computing his monthly pension payment, pursuant to an amendment to the Civil Service Retirement Act effective January 5, 1975. On May 22, 1975, he wrote a letter to the Commission stating his position. His letter stated:

I am hereby appealing your computation of my annuity . . . and I am requesting such Administrative relief as may be available to me.
I further request that you advise me specifically as to what procedure I must follow to secure administrative relief, citing such regulation or legal sections as are applicable.

The Commission did not reply. Heider wrote again on June 12, 1975. Again he stated, “I am appealing your computation of my annuity ... and I am further requesting such Administrative relief as may be available to me.”

July 30, 1975, the Bureau’s section chief replied telling Heider what he already knew — that the Bureau differed with Heider on how his retirement should be calculated. He did not reply to Heider’s statement that he was appealing the decision or to the request for information about proper appeal procedures. The Commission never responded to Heider’s request for an appeal or information about obtaining administrative review. After the six months period for seeking administrative review, 5 C.F.R. § 831.107, passed, Heider instituted this action.

Exhaustion of Administrative Remedy

The United States has moved to dismiss this action for failure to exhaust administrative remedies. That position is wholly unsupported. Indeed raising it in these circumstances is so unjustified that it is an embarrassment to the citizens of this country.

The doctrine of exhaustion of administrative remedies is well established in the jurisprudence of administrative law. See generally 3 K. Davis, Administrative Law Treatise § 20.01 et seq. (1958 ed., 1965 Supp.); L. Jaffe, Judicial Control of Administrative Action 424-458 (1965). The doctrine provides ‘that no one is entitled to judicial relief for a supposed or threatened injury until the prescribed administrative remedy has been exhausted.’ Myers v. Bethlehem Shipbuilding Corp., [424]*424303 U.S. 41, 50-51, 58 S.Ct. 459 [463] 82 L.Ed. 638, 643, 644 (1938). The doctrine is applied in a number of different situations and is, like most judicial doctrines subject to numerous exceptions. Application of the doctrine to specific cases requires an understanding of its purposes and of the particular administrative scheme involved.
Perhaps the most common application of the exhaustion doctrine is in cases where the relevant statute provides that certain administrative procedures shall be exclusive. See Myers v. Bethlehem Shipbuilding Corp., 303 U.S. 41, 58 S.Ct. 459, 82 L.Ed. 638 (1938) (National Labor Relations Act). The reasons for making such procedures exclusive, and for the judicial application of the exhaustion doctrine in cases where the statutory requirement of exclusivity is not so explicit, are not difficult to understand. A primary purpose is, of course, the avoidance of premature interruption of the administrative process. The agency, like a trial court, is created for the purpose of applying a statute in the first instance. Accordingly, it is normally desirable to let the agency develop the necessary factual background upon which decisions should be based. And since agency decisions are frequently of a discretionary nature or frequently require expertise, the agency should be given the first chance to exercise that discretion or to apply that expertise. And of course it is generally more efficient for the administrative process to go forward without interruption than it is to permit the parties to seek aid from the courts at various intermediate stages. The very same reasons lie behind judicial rules sharply limiting interlocutory appeals.
Closely related to the above reasons is a notion peculiar to administrative law. The administrative agency is created as a separate entity and invested with certain powers and duties. The courts ordinarily should not interfere with an agency until it has completed its action, or else has clearly exceeded its jurisdiction. As Professor Jaffe puts it, ‘[t]he exhaustion doctrine is, therefore, an expression of executive and administrative autonomy.’ This reason is particularly pertinent where the function of the agency and the particular decision sought to be reviewed involve exercise of discretionary powers granted the agency by Congress, or require application of special expertise.

McKart v. U. S., 395 U.S. 185, 193, 89 S.Ct. 1657, 1662, 23 L.Ed.2d 194, 203 (1969) (footnotes omitted).

Here there are no reasons for requiring exhaustion of administrative remedies. The issue here is strictly statutory construction. Its resolution does not require any particular expertise and does not call for exercise of administrative discretion. See, McKart v. U. S., 395 U.S. 185, 198, 89 S.Ct. 1657, 1665, 23 L.Ed.2d 194, 205 (1969). Heider in his letters asked for administrative review. The Commission ignored the opportunity to resolve this issue internally. No administrative process will be interrupted. The Commission has completed its proceedings.

In this case requiring exhaustion of administrative remedies would serve no legitimate purpose. The motion to dismiss is denied.

The Statute’s Meaning

The dispute here is over the effective date and meaning of an amendment changing the definition of average pay. Heider’s retirement annuity is computed using a formula which uses average pay to determine the annuity. 5 U.S.C. § 8339(d)(1) (1977).

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521 F. Supp. 422, 1981 U.S. Dist. LEXIS 15624, Counsel Stack Legal Research, https://law.counselstack.com/opinion/heider-v-united-states-flmd-1981.