Elgin v. Department of Treasury

Federal law required all male citizens between the ages of 18 and 22 to register for the draft. Another statute barred from federal employment anyone who had knowingly and willfully failed to register. Michael Elgin (plaintiff), a former federal employee, was fired for failing to register. Pursuant to the Civil Service Reform Act of 1978 (CSRA), which established a comprehensive framework for reviewing personnel actions taken against federal employees, Elgin challenged his termination before the Merit Systems Protection Board (MSPB). Elgin argued that the statute under which he was discharged was unconstitutional. The MSPB dismissed Elgin’s appeal on the grounds that the board lacked jurisdiction and the power to rule on the constitutionality of a statute. Rather than appealing to the Federal Circuit as prescribed by the CSRA, Elgin filed suit in federal district court, again challenging the constitutionality of the statute under which he was discharged. The government (defendant) responded that the district court lacked jurisdiction because the CSRA channeled such claims exclusively through the MSPB and the Federal Circuit. The district court concluded that it had jurisdiction but dismissed Elgin’s claims. The First Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss for lack of jurisdiction. The United States Supreme Court granted certiorari.