Luca v. Social Security Administration

CourtDistrict Court, E.D. Michigan
DecidedSeptember 29, 2025
Docket2:23-cv-12393
StatusUnknown

This text of Luca v. Social Security Administration (Luca v. Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Luca v. Social Security Administration, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

JAMES LUCA,

Plaintiff, Case No. 2:23-cv-12393 v. Magistrate Judge Anthony P. Patti

SOCIAL SECURITY ADMINISTRATION,

Defendant.

/

OPINION AND ORDER GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT (ECF No. 19)

Plaintiff James Luca was an employee at the Social Security Administration (“Agency”). This is one of four lawsuits he has brought in this Court in the past three years against the Agency related to his employment.1 In the case at bar, he claims that the Agency wrongly passed him over for various posted positions based

1 See Luca v. Comm’r of Soc. Sec., 2:23-cv-11966, 2025 WL 2463150 (E.D. Mich. Aug. 26, 2025); Luca v. Comm’r of Soc. Sec., No. 4:22-cv-11169, 2024 WL 4340706 (E.D. Mich. Sept. 27, 2024), aff’d, No. 24-2039, 2025 U.S. App. LEXIS 23044, at *12 (6th Cir. Sept. 5, 2025) (“[T]he evidence is nearly overwhelming that Luca’s abuse of the [Agency]’s leave policies was the sole reason for its termination decision.”); Luca v. Kijakazi, No. 4:22-cv-12001 (E.D. Mich. Sept. 29, 2023). on his age, race, color, sex, and past attempts to pursue discrimination claims against it.

The parties consented to my jurisdiction to resolve this action. Because no reasonable jury would find that the Agency discriminated against Luca with respect to one of the non-selections and every reasonable jury would find that the

Agency had legitimate, non-discriminatory reasons for the other non-selections, all Luca’s claims fail. The Court shall grant summary judgment for the Agency. FACTUAL BACKGROUND In 2014 and 2015, Luca applied for higher posts with his employer, the

Agency. Those promotions were governed by a merit promotion plan that the Agency had negotiated with the American Federation of Governmental Employees (hereinafter, the “Plan”). The Agency did not pick Luca for any of the positions.

He later challenged those non-selections in administrative proceedings before the Agency and later the Equal Employment Opportunity Commission (“EEOC”). Neither the Agency nor the EEOC found any wrongdoing. This suit followed. I. The Plan’s Merit Selection Rules

The starting point for the Plan’s selection rules is the federal government’s General Schedule pay system, which consists of “GS levels” numbered one through fifteen.2 For General Schedule jobs, the employee holding the job has a

2 This information regarding the Plan’s merit selection rules comes from the Plan GS level. The higher the GS level, the better the employee’s salary and other benefits, and an employee’s GS level may be increased as they become more

experienced. Some General Schedule jobs also have a terminal GS level. An employee who reaches a terminal GS level cannot advance to a higher GS level without switching jobs.

The jobs at issue here were General Schedule jobs with a terminal GS level of 11. And the Agency was looking to hire applicants at the GS-5, GS-7, GS-9, and GS-11 levels, or some combination thereof. Applicants had to qualify for a particular GS level based on experience, education, and other factors to be hired at

that GS level. And applicants had to state the lowest GS level they would accept. After the job listings at issue here closed, the Agency first determined whether all the applicants for each job qualified for the lowest GS level they had

said they would take, as well as all higher available GS levels. The Agency then made separate, ranked lists for each GS level consisting of all the applicants who were eligible at that GS level. And the criterion for ranking applicants at each GS level were different than the factors the Agency used to determine applicants’

eligibility for a certain GS level. After creating these ranked lists for each GS level, the Agency trimmed all but the ten most qualified applicants from each list with more than ten applicants.

(ECF No. 19-6) and an affidavit from an Agency employee (ECF No. 19-4). For lists with fewer than ten applicants, all the applicants remained on the list. The resulting lists, which the Agency called “best qualified” or “BQ” lists, were then

sent to the selection officials. When an applicant’s name was listed on a certain BQ list, it was said that the applicant had been “referred” at that GS level. And selection officials could pick an applicant from any of the BQ lists; officials were

not, for example, required to choose from the BQ list for the highest GS level.3 II. The Vacancies Luca applied for positions as a claims representative at the Agency’s Ann Arbor, Farmington Hills, Wyandotte, Detroit Conner, Roseville, Inkster, and

Highland Park offices, all of which were in Michigan.4 He was eligible for GS-11

3 For example, assume an applicant, April, applied for a vacancy that was open to applicants at the GS-5 level and up. Assume she was eligible at the GS-9 level and applied at the GS-7 level. Assume also that she was among the top ten highest-ranked GS-9-eligible applicants but not among the top ten highest-ranked GS-7-eligible applicants. She would have been referred at the GS-9 level because she was among the top ten GS-9-eligible applicants. But she would not have been referred at the GS- 5 level because she had applied at the GS-7 level; nor at the GS-7 level because she was not among the top ten GS-7-eligible applicants; nor at the GS-11 level because she was not GS-11-eligible. If the selection official wished to hire someone at the GS-5, GS-7, or GS-11 levels, the official would not have considered April for the job. And if the official considered GS-9-eligible applicants, then April would have had to beat out the other nine applicants who had been referred at that level. 4 In the papers the parties also discuss vacancy number 1213695, which was for an administrative assistant position at the Agency’s office of disability adjudication and review. Luca applied for that vacancy, and he was not selected. At his deposition, Luca explained that he was not challenging “any aspect of [the Agency’s] decision” in connection with this vacancy. (Luca Dep. 76:19–21, ECF No. 19-2.) In his response to the Agency’s motion for summary judgment, he uses the Agency’s selection process for this vacancy as an example of what he believes should have level jobs, but he applied at lower GS levels. None of the offices picked him. In late 2015, the selection officials authored affidavits explaining why.

A. Ann Arbor (Vacancy No. 1218768) The Ann Arbor vacancy was open to GS-7 through GS-11-level applicants. (ECF No. 19-7, PageID.288.) Luca applied at the GS-7 level, and he ranked eighteenth out of twenty-two among GS-7-eligible applicants; twenty-fourth out of

twenty-nine among GS-9-eligible applicants; and last among four GS-11-eligible applicants. (Cruz Aff. ¶ 33, ECF No. 19-4.) He was thus only referred at the GS- 11 level. (Id. ¶ 32.)

The Agency hired Megan Westhoff, a thirty-year-old white woman, at the GS-9 level. (Laird Aff. ¶ 30, ECF No. 19-11; ECF No. 19-9, PageID.328.) Westhoff was hired because her “manager [had] provided positive feedback”; and

she had “a good work history,” “good performance ratings,” and “a number of years of experience as Service Representative.” (Laird Aff. ¶ 32; see also ECF No. 19-12.) Westhoff’s experience mattered because “Service Representatives have the background and experience to later become a Claims Representative.” (Laird

Aff. ¶ 32.) The selection official was also “familiar with [Westhoff’s] quality work.” (Id.)

happened with the other vacancies. The Court accordingly assumes that Luca is not bringing any claims in connection with this vacancy. Luca was not hired because he “did not have the necessary experience as a Service Representative or background.” (Id. ¶ 34.) And Luca learned that he was

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Texas Department of Community Affairs v. Burdine
450 U.S. 248 (Supreme Court, 1981)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Stevens v. Department of Treasury
500 U.S. 1 (Supreme Court, 1991)
Benford v. Frank
943 F.2d 609 (Sixth Circuit, 1991)
Brian E. Davis v. United States Department of Justice
204 F.3d 723 (Seventh Circuit, 2000)
Surles v. Andison
678 F.3d 452 (Sixth Circuit, 2012)
Hunter v. Secretary of United States Army
565 F.3d 986 (Sixth Circuit, 2009)
Tepper v. Potter
505 F.3d 508 (Sixth Circuit, 2007)
Frank Rembisz v. Jacob Lew
590 F. App'x 501 (Sixth Circuit, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Luca v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/luca-v-social-security-administration-mied-2025.