## Facts

- The Social Security Administration (SSA) faced a backlog of disability cases.
- In 2007, SSA’s Chief Administrative Law Judge issued a directive stating a numerical “goal” that each administrative law judge (ALJ) manage the docket to issue 500–700 legally sufficient decisions annually.
- The Association of Administrative Law Judges (a union representing SSA ALJs) and three ALJs alleged the “goal” operated as an enforced quota through formal and informal discipline.
- Plaintiffs alleged the quota pressured ALJs to favor speed over accuracy and interfered with ALJs’ decisional independence.
- Plaintiffs relied on Administrative Procedure Act (APA) provisions protecting ALJs from agency direction when conducting hearings and from inconsistent assigned duties.

## Issues

1. Whether the Civil Service Reform Act of 1978 (CSRA) provides the exclusive remedial scheme for ALJs’ challenge to SSA’s productivity quota, thereby precluding an APA suit in federal district court.
2. Whether the quota and related enforcement constitute a “personnel practice” or “working conditions” dispute governed by the CSRA and federal labor-management statutes.

## Decision

- The Seventh Circuit affirmed the dismissal for lack of subject-matter jurisdiction.
- The court held that the CSRA and related federal labor statutes provide the exclusive mechanisms for addressing the challenged quota and any related discipline.
- The court treated the quota as affecting duties, responsibilities, and working conditions, placing it within the CSRA’s domain rather than permitting district-court APA review.

## Legal Principles

- When Congress supplies a comprehensive remedial scheme for federal employment disputes, that scheme generally displaces parallel suits under more general review statutes.
- Agency performance expectations and alleged enforcement through discipline can constitute “personnel practices” involving changes in duties, responsibilities, or working conditions under the CSRA.
- Union-represented federal employees must pursue working-conditions disputes through the labor-management framework and CSRA administrative channels rather than through an APA action in district court.
- Claims framed as interference with ALJ decisional independence do not create an independent route to district-court APA jurisdiction when the challenged conduct falls within the CSRA’s personnel-practice framework.

## Conclusion

The court held that challenges by SSA ALJs and their union to a productivity quota and its enforcement must proceed through the CSRA and federal labor-management processes, and that these statutes preclude an APA-based suit in federal district court.


Ass'n of Admin. Law Judges v. Colvin, 777 F.3d 402 (7th Cir. 2015)