John H. Buchanan, Jr. v. United States Postal Service, Etc.

508 F.2d 259, 1975 U.S. App. LEXIS 16034
CourtCourt of Appeals for the Fifth Circuit
DecidedFebruary 19, 1975
Docket74-2851 and 74-3214
StatusPublished
Cited by80 cases

This text of 508 F.2d 259 (John H. Buchanan, Jr. v. United States Postal Service, Etc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John H. Buchanan, Jr. v. United States Postal Service, Etc., 508 F.2d 259, 1975 U.S. App. LEXIS 16034 (5th Cir. 1975).

Opinion

GODBOLD, Circuit Judge:

This first impression case was brought by three Congressmen who sue on behalf of a class composed of numerous users, located throughout the United States, of the United States Postal Service. The Postal Service was created as an independent establishment of the executive branch of the government by the Postal Reorganization Act of 1970, 39 U.S.C. §§ 101-5605, and generally performs functions formerly carried out by the Post Office Department. The controversy centers upon previously uninterpreted language of 39 U.S.C. § 3661:

(a) The Postal Service shall develop and promote adequate and efficient postal services.
(b) When the Postal Service determines that there should be a change in the nature of postal services which will generally affect service on a nationwide or substantially nationwide basis, it shall submit a proposal, within a reasonable time prior to the effective date of such proposal, to the Postal Rate Commission requesting an advisory opinion on the change.
(c) The Commission shall not issue its opinion on any proposal until an opportunity for hearing on the record under sections 556 and 557 of title 5 has been accorded to the Postal Service, users of the mail, and an officer of the Commission who shall be required to represent the interests of the general public. The opinion shall be in writing and shall include a certification by each Commissioner agreeing with the opinion that in his judgment the opinion conforms to the policies established under this title.

Suit was filed April 30, 1974. The complaint, as amended, asked that pending hearings before the Postal Rate Commission and advisory opinions by that body the court enjoin implementation of three Postal Service programs.

The Postal Service is in the process of implementing three programs which plaintiffs contend are “change[s] in the nature of postal services which will generally affect service on a nationwide or *262 substantially nationwide basis” within the meaning of subsection (b) and thus required to be submitted to the Postal Rate Commission 1 for hearings and advisory opinions as required by (b) and (c). Opinions of the Rate Commission are, as the statute states, advisory only. The Postal Service is not required to follow them. The Postal Service has not submitted the programs to the Rate Commission. The programs are: (1) a plan to consolidate and eliminate “district offices” throughout the United States; (2) the retail analysis program (“RAP”); 2 and (3) the “national bulk mail system” program.

Discovery commenced promptly after suit was filed. Following a hearing on May 11 the court issued a temporary injunction on May 14 finding with respect to RAP and consolidation of district offices that plaintiffs probably would prevail in demonstrating that they were “change[s] in the nature of postal services” within the meaning of § 3661 and that plaintiffs would suffer irreparable injury if the preliminary injunction were not issued. With respect to the national bulk mail system program the court found § 3661 inapplicable because “in all likelihood” the decision to implement it had been made before July 1, 1971, the date the Postal Reorganization Act became effective. Defendants appeal from these grants of relief and from the order of the District Court denying their motion for summary judgment. 3

I. § 3661: “changes in the nature of postal services”

The central issue is the meaning of “change in the nature of postal services which will generally affect service on a nationwide or substantially nationwide basis.” We examine that language in the light of the purposes and legislative history of § 3661.

Two of the basic policies underlying the Postal Reorganization Act pull in different directions. The Postal Service emphasizes the goal of vesting in management the freedom to make decisions without external constraints. The plaintiffs counter with the goal of providing to the American people a public service which is sensitive and responsive to their needs. Although these policies conflict to some extent, we think a balance may be struck whereby management is given the freedom to manage without unnecessary limitations and the public is given an opportunity to present their views on decisions of the Postal Service which affect them.

The language of the statute, the legislative history, and the existence of alternative remedies indicate that Congress intended § 3661 to apply to only a specified class of decisions. Postal management was left with broad decision-making power, subject to § 3661 requirements for specified decisions.

The language of § 3661 indicates the limited scope of application. All changes within the Service will probably affect postal service to some extent. For example, a decision to combine two high management positions could ultimately have an effect on a nationwide or substantially nationwide basis. The language of the statute, however, indicates that three factors must coexist before § 3661 applies. First, there must be a “change.” This implies that a quantitative determination is necessary. There must be some meaningful impact on service. Minor alterations which have a minimal effect on the general class of postal users do not fall within § 3661. Second, the change must be “in the na *263 ture of postal services.” This involves a qualitative examination of the manner in which postal services available to the user will be altered. Third, the change must affect service “on a nationwide or substantially nationwide basis.” A broad geographical area must be involved. These three factors combine to demonstrate that Congress intended the safeguards of § 3661 to apply only when changes of significance were contemplated.

There is much in the legislative history of the Act to indicate that Congress intended to increase the ability of the Postal Service management to make the decisions necessary to the efficient and effective operation of the postal system. For example, the Kappel Commission 4 emphasized the need for increased management authority:

What the Post Office needs is management leadership. It needs a management free to manage with all that entails; authorities matched with responsibilities . . . 5

Similarly the House Committee, recommending the passage of an earlier version of the Act stated:

Top management must be given authority, consistent with its responsibilities, to provide an efficient and economical postal system. Postal management has been severely and unjustly hampered in its efforts to administer the Department in a businesslike way. 6

A policy of broad authority in postal management is further supported by modifications made by the Senate-House Conference Committee.

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Bluebook (online)
508 F.2d 259, 1975 U.S. App. LEXIS 16034, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-h-buchanan-jr-v-united-states-postal-service-etc-ca5-1975.