Jain-Miecell Roberson v. United States

• Court: Court of Appeals for the Third Circuit
• Decided: December 2, 2025
• Docket: 25-2203
• Status: Unpublished

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________

No. 25-2203 ___________

JAIN-MIECELL ROBERSON, Appellant v.

UNITED STATES OF AMERICA ____________________________________

On Appeal from the United States District Court for the Middle District of Pennsylvania (M.D. Pa. Civil Action No. 1:24-cv-02036) Magistrate Judge: Honorable Daryl F. Bloom (by consent) ____________________________________

Submitted Pursuant to Third Circuit LAR 34.1(a) November 19, 2025

Before: KRAUSE, RESTREPO, and PORTER, Circuit Judges

(Opinion filed: December 2, 2025) ___________

OPINION * ___________

PER CURIAM

Pro se appellant Jain-Miecell Roberson appeals from the District Court’s dismissal

of his complaint, where he alleged claims stemming from his employment at the Naval

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. Supply Systems Command Business Systems Center (“NAVSUP”). For the reasons that

follow, we will affirm the District Court’s judgment.

I.

In early 2023, Roberson was working as a comptroller supervisor at NAVSUP in

Mechanicsburg, PA. In the spring of 2023, Roberson received an annual performance

evaluation which rated his performance as fully successful in all categories but one,

where he received an outstanding rating. Roberson notified his supervisor that he

intended to file a grievance to formally dispute the evaluation, as he believed he should

have received an outstanding rating in all categories. In May 2023, Roberson was

informed that he would be detailed, transferred, or reassigned to a different position at the

NAVSUP headquarters team. In late 2023, Roberson filed an appeal with the Merit

Systems Protection Board (“MSPB”), which has not yet been resolved.

Roberson then initiated this federal lawsuit against the United States in November

2024. He raised 26 claims, alleging that: (1) he was transferred without proper notice and

was not reinstated to his comptroller supervisor position after his detail at NAVSUP

headquarters, which he believed was because he filed a grievance; (2) his position was

inaccurately recorded in official records after his transfer; (3) he was not given adequate

information about grievance procedures and proper grievance procedures were not

followed; (4) he experienced harassment and a hostile work environment after he

submitted his grievance; (5) he was unfairly evaluated; (6) he was denied training

opportunities; and (7) when Roberson served as the lead member of a hiring

recommendation panel, his recommended candidate was not hired. He sought to bring 2 these claims under the Civil Service Reform Act (“CSRA”), the Federal Tort Claims Act,

and various Pennsylvania statutes.

Roberson filed a motion for summary judgment soon after, where he requested a

default judgment. The United States filed a motion to dismiss. Presiding with the

consent of the parties, a Magistrate Judge dismissed the case for lack of subject matter

jurisdiction and denied Roberson’s motion. Roberson timely appealed.

II.

We have jurisdiction pursuant to 28 U.S.C. § 1291. We review de novo the

District Court’s dismissal of Roberson’s complaint for lack of subject matter jurisdiction.

See In re Horizon Healthcare Servs. Inc. Data Breach Litig., 846 F.3d 625, 632 (3d Cir.

2017). We construe his pro se pleadings liberally. See Erickson v. Pardus, 551 U.S. 89,

94 (2007). We review the denial of Roberson’s request for a default judgment for abuse

of discretion. See Chamberlain v. Giampapa, 210 F.3d 154, 164 (3d Cir. 2000).

III.

We agree with the District Court’s dismissal of Roberson’s complaint. Roberson

fundamentally alleges that his employer engaged in prohibited personnel practices as

defined by the CSRA, and he particularly challenges the procedures that were followed in

taking various personnel actions. Because all of Roberson’s claims fall under the CSRA,

the District Court lacked jurisdiction to review them.

The CSRA sets out an exclusive “framework for evaluating adverse personnel

actions” taken against federal employees, “including the availability of administrative

and judicial review.” United States v. Fausto, 484 U.S. 439, 443 (1988). Under this 3 comprehensive review scheme, eligible federal employees may dispute “prohibited

personnel practices” — “meaning any ‘personnel action’ motivated by an impermissible

ground” — before the Merit Systems Protection Board (“MSPB”). Manivannan v.

United States Dep’t of Energy, 42 F.4th 163, 171 (3d Cir. 2022). The United States

Court of Appeals for the Federal Circuit then has exclusive jurisdiction over appeals from

final MSPB decisions. See Elgin v. Dep’t of Treasury, 567 U.S. 1, 6 (2012).

“[W]hen assessing whether the CSRA bars federal jurisdiction over an otherwise

reviewable claim, courts . . . look to the specific underlying conduct being challenged to

determine whether that conduct is an employment action covered by the statute.”

Manivannan, 42 F.4th at 172. “If [an] employee’s federal suit is, ‘at bottom,’ challenging

an employment action within the [MSPB’s] jurisdiction, then it must proceed through the

review process provided in the CSRA.” Id. (citation omitted). An action covered by the

CSRA “is confined to the remedies it offers.” Id. at 170.

Here, the District Court appropriately determined that Roberson’s claims fell

within the exclusive scope of the CSRA. Roberson himself characterized his claims as

violations of the CSRA and sought to bring his claims under that statute. Roberson

challenges actions that all fall within the specifically enumerated “personnel actions”

outlined by the CSRA. See 5 U.S.C. § 2302(a)(2)(A). He brought several claims related

to his reassignment from the position of comptroller supervisor and his concerns

regarding procedures that were allegedly not followed. See id. § 2302(a)(2)(A)(iv)

(listing “a detail, transfer, or reassignment” as a “personnel action”). He claimed that he

was unfairly evaluated and denied training opportunities. See id. § 2302(a)(2)(A)(vii), 4 (ix) (listing “a performance evaluation” and a decision . . . concerning education or

training” as “personnel action[s]”). And, as the District Court explained, under the

circumstances of this case, Roberson’s remaining claims regarding harassment after

submitting his grievance, inadequate responses to his grievance requests, and overlooking

his hiring recommendations all fell under the category for a “significant change in duties,

responsibilities, or working conditions.” See id. at § 2302(a)(2)(A)(xii).

Roberson’s claims also alleged “prohibited personnel practices” as defined by the

CSRA. See id. § 2302(b). He maintained that he was harassed and reassigned because

he complained of mistreatment and filed a grievance. See id. § 2302(b)(8)(A)(ii)

(prohibiting personnel actions taken because of a “disclosure of information . . . which

the employee or applicant reasonably believes evidences . . . an abuse of authority”);

§ 2302(b)(9) (prohibiting personnel actions taken because an employee has filed a

grievance). Roberson’s claims regarding his evaluation, being denied training

opportunities, and the decision to go against his hiring recommendation all addressed

alleged violations of merit system principles. See id. § 2302(b)(12) (prohibiting

personnel actions that violate the merit system principles outlined in § 2301);

§ 2301(b)(2), (4), (7) (outlining merit system principles that employees “receive fair and

equitable treatment in all aspects of personnel management,” “maintain high standards of

integrity, conduct, and concern for the public interest,” and “be provided effective

education and training” when such training would improve an employee’s performance).

Roberson characterized his remaining claims relating to his requests for

information and the grievance process as due process violations. On appeal, Roberson 5 argues that all of his claims should have been interpreted as challenges to the procedures

by which the alleged employment actions took place, rather than challenges to the

underlying actions themselves. These claims allege violations of the merit system

principle that all employees should be treated “with proper regard for their privacy and

constitutional rights.” See id. § 2301(b)(2); see also Weaver v. U.S. Info. Agency, 87

F.3d 1429, 1432 (D.C. Cir. 1996) (“Among the merit system principles in § 2301 is the

requirement that all employees be treated ‘with proper regard for their privacy and

constitutional rights.’”) (citation omitted). Although Roberson argues on appeal that he

would not be able to raise his due process claims in MSPB proceedings, the MSPB

regularly hears constitutional and due process claims, and Roberson can seek review of

the MSPB’s decision on those claims in the Federal Circuit. See, e.g., Stone v. F.D.I.C.,

179 F.3d 1368, 1376-77 (Fed. Cir. 1999) (reviewing an employee’s claim that his

procedural due process rights were violated when he was removed from his position).

Thus, the MSPB has exclusive jurisdiction to review Roberson’s challenge to those

actions and the way they took place.

On appeal, Roberson contends that his allegations “all fall under Pennsylvania

Statute Violations” as “Due Process Failure by Malpractice,” making the District Court

the proper forum for his claims. Appellant’s Br. at 2-4. In support, he cites provisions of

the Pennsylvania Workers’ Compensation Act and the Pennsylvania Occupational

Disease Act that have no apparent relevance to his allegations. See 77 Pa. Stat. Ann. § 41

(limiting defenses available in personal injury actions by employees for injuries incurred

“in the course of his employment”); id. § 51 (providing that employers are liable for their 6 employees’ negligence “while acting within the scope of their employment”); id. § 1302

(providing that employers are liable for their employees’ negligence “while acting within

the scope of their employment”).

Roberson does not explain how these statutes provide the District Court with

jurisdiction over his claims given the expansive scope of the CSRA — however he

chooses to label these claims, reviewing them would “infringe on territory exclusive to

the [MSPB].” Manivannan, 42 F.4th at 173 n.4. Accordingly, because Roberson’s

claims fell under the CSRA, the District Court appropriately concluded that it lacked

jurisdiction over his complaint. 1

Finally, the District Court properly denied Roberson’s request for a default

judgment where no default had been entered. 2 See Fed. R. Civ. P. 55(a)-(b);

Chamberlain, 210 F.3d at 164.

For these reasons, we will affirm the judgment of the District Court.

1 Because we agree with the District Court’s CSRA analysis, we need not address its alternative grounds for concluding that it lacked jurisdiction over Roberson’s complaint. Additionally, to the extent that Roberson discusses any other issues for the first time in his reply brief, we do not consider them. See Barna v. Bd. of Sch. Dirs. of Panther Valley Sch. Dist., 877 F.3d 136, 146 (3d Cir. 2017). 2 Roberson argues that the District Court should have treated and analyzed his motion as a request for summary judgment, but we discern no error in the District Court’s approach, as Roberson requested a default judgment in his motion. 7