Renzi v. US DOL

2016 DNH 103
CourtDistrict Court, D. New Hampshire
DecidedJune 22, 2016
Docket16-cv-039-JD
StatusPublished

This text of 2016 DNH 103 (Renzi v. US DOL) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Renzi v. US DOL, 2016 DNH 103 (D.N.H. 2016).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Diane Renzi

v. Civil No. 16-cv-039-JD Opinion No. 2016 DNH 103 Thomas E. Perez, Secretary United States Department of Labor

O R D E R

Diane Renzi has brought suit against Thomas E. Perez,

Secretary of the United States Department of Labor, challenging

the denial of her federal workers’ compensation claim under the

Federal Employees’ Compensation Act (“FECA”). She alleges that

in denying her claim the Secretary violated FECA mandates and

her constitutional rights to due process and equal protection.

The Secretary moves to dismiss for lack of subject matter

jurisdiction.1

Standard of Review

A defendant may challenge the jurisdictional basis of the

suit by moving to dismiss under Rule 12(b)(1). In deciding a

1 Although the Secretary cites both Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6) in the motion to dismiss, the memorandum in support of the motion proceeds under only Rule 12(b)(1). Therefore, the court construes the motion as seeking to dismiss the claims due to a lack of subject matter jurisdiction under Rule 12(b)(1). motion under Rule 12(b)(1), the court “credit[s] the plaintiff’s

well-pled factual allegations and draws all reasonable

inferences in the plaintiff’s favor.” Merlonghi v. United

States, 620 F.3d 50, 54 (1st Cir. 2010). “The district court

may also consider whatever evidence has been submitted, such as

depositions and exhibits.”2 Id.

Background3

Renzi worked as a Passport Specialist for the Department of

State in Portsmouth, New Hampshire. On October 6, 2011, Renzi

fell while walking up the stairs at work, injuring her hands,

her right shoulder, and her knees. She filed a claim for

workers’ compensation benefits, and the Office of Workers’

Compensation Programs (“OWCP”) accepted her claim on January 26,

2012. Renzi received workers’ compensation benefits through May

of 2013 and then again in October and November of 2013 after

2 Renzi asserts that the Secretary is moving to dismiss under Rule 12(b)(6), although she also acknowledges Rule 12(b)(1). Based on the limited scope of review under Rule 12(b)(6), Renzi argues that the motion must be converted to one for summary judgment. Fed. R. Civ. P. 12(d). Because the motion seeks dismissal due to a lack of subject matter jurisdiction under Rule 12(b)(1), not failure to state a claim under 12(b)(6), the additional evidence submitted by the parties may be considered without converting the motion to one for summary judgment.

3 Consonant with the standard of review, the background information is taken from Renzi’s complaint and additional evidence submitted by the parties.

2 knee surgery. The OWCP also approved a schedule award to Renzi

because of permanent impairment to her right arm and left leg

caused by the fall.

On September 27, 2013, Renzi filed a new claim with the

OWCP due to osteoarthritis in her left thumb that she asserted

made her unable to work. She alleged that the osteoarthritis

was caused by repetitive hand activities at work and was

aggravated and accelerated by the fall. Renzi asked that her

two claims be merged, and the OWCP agreed to merge the claims.

On February 6, 2014, the OWCP denied Renzi’s claim because

she had not shown a causal relationship between the

osteoarthritis in her thumb and her work. The OWCP explained

that the medical opinions Renzi provided, which stated that the

fall and work activities “more likely than not” contributed to

her osteoarthritis condition, were equivocal as to causation.

Renzi then sought reconsideration and submitted additional

medical opinions.

The OWCP again found the medical opinion evidence lacked an

unequivocal opinion that Renzi’s degenerative osteoarthritis was

directly related to her work duties. The OWCP stated that the

medical opinion must provide “a complete and accurate history of

[her] condition and the potential contributing factors” and a

“firm and unequivocal opinion” that work caused her

3 osteoarthritis condition. The OWCP issued its final decision

denying Renzi’s application on September 28, 2015. Renzi did

not appeal that decision.

Renzi filed this action on February 6, 2016. She asserts

subject matter jurisdiction under 28 U.S.C. § 1331 and 5 U.S.C.

§ 8101, et seq. She alleges that the Secretary, through the

OWCP, violated her “constitutional rights and statutory mandates

of the Federal Employees Compensation Act (FECA), 5 USC § 8101

et seq.” She brings seven counts titled: Burden of Proof,

Burden of Proof on Causation, Probative Value, Timeliness,

Process Due, Equal Protection, and Damages.

Discussion

The Secretary moves to dismiss Renzi’s claims on the ground

that the court lacks jurisdiction to review the decision of the

OWCP denying Renzi’s workers’ compensation claim under FECA.

The Secretary also challenges Renzi’s claim for damages. In

response, Renzi argues that jurisdiction exists to consider her

claims that the OWCP violated her rights to procedural and

substantive due process and equal protection and that the OWCP

violated FECA mandates in denying her claim. The Secretary

filed a reply, and Renzi filed a surreply.

Under FECA, § 8101, et seq., a decision by the OWCP to deny

workers’ compensation benefits is “final and conclusive for all

4 purposes and with respect to all questions of law and fact; and

[] not subject to review by another official of the United

States or by a court by mandamus or otherwise.” § 8128(b). As

such, FECA unambiguously and comprehensively bars “any judicial

review of the Secretary’s determination of FECA coverage.”

Southwest Marine, Inc. v. Gizoni, 502 U.S. 81, 90 (1991).

Despite the statutory preclusion to review of FECA coverage

decisions, a court has jurisdiction to hear constitutional

challenges to the administration of FECA.4 Paluca v. Sec’y of

Labor, 813 F.2d 524, 526 (1st Cir. 1987); accord Cooper v. Chao,

71 F. App’x 76, 77 (1st Cir. 2003).

To provide jurisdiction within the exception, a

constitutional claim must not be “so attenuated and

unsubstantial as to be absolutely devoid of merit.” Palucca,

813 F.2d at 526. That is, a cognizable constitutional claim

must be “specific and substantive.” Cooper, 71 F. App’x at 77.

Therefore, a conclusory allegation of a constitutional challenge

is not enough to avoid preclusion under § 8128(b). Stone v.

Chao, 284 F. Supp. 2d 241, 246 (D. Mass. 2003).

Although a few courts have found an exception to the bar on

judicial review for claims that the OWCP violated a clear FECA

4 In light of the plain meaning of § 8128, Renzi’s theory that § 8128(b) does not apply to her claims is not persuasive.

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2016 DNH 103, Counsel Stack Legal Research, https://law.counselstack.com/opinion/renzi-v-us-dol-nhd-2016.