Reaffirming the Civil Service Reform Act’s Exclusive Channel for Federal Personnel Disputes: Commentary on Jain‑Miecell Roberson v. United States (3d Cir. 2025)

I. Introduction

The Third Circuit’s nonprecedential decision in Jain‑Miecell Roberson v. United States, No. 25‑2203 (3d Cir. Dec. 2, 2025), is a clear application—and reinforcement—of a core structural rule of federal civil service law: when a federal employee challenges “personnel actions” or “prohibited personnel practices” covered by the Civil Service Reform Act (CSRA), those challenges must proceed exclusively through the CSRA’s administrative scheme, centered on the Merit Systems Protection Board (MSPB) and the Federal Circuit, not through collateral suits in federal district court.

Although “not precedential” under Third Circuit Internal Operating Procedure 5.7, the opinion offers a concise illustration of how courts identify CSRA‑covered conduct and how they treat attempts to re‑label CSRA employment disputes as tort, state‑law, or constitutional claims. It also reiterates the basic mechanics of default judgment under Federal Rule of Civil Procedure 55.

II. Factual and Procedural Background

A. Employment relationship and initial dispute

Jain‑Miecell Roberson was employed as a comptroller supervisor at the Naval Supply Systems Command Business Systems Center (NAVSUP) in Mechanicsburg, Pennsylvania, in early 2023. As a federal civilian employee, his employment relationship was governed by the CSRA.

In the spring of 2023, Roberson received his annual performance evaluation. He was rated “fully successful” in all categories except one, in which he received an “outstanding” rating. Roberson believed his performance warranted “outstanding” ratings across the board.

Roberson notified his supervisor that he intended to file a grievance regarding the evaluation. Following that notice:

• In May 2023, he was informed that he would be detailed, transferred, or reassigned to a different position on the NAVSUP headquarters team.
• He later alleged that he was not properly notified of this change and not restored to his comptroller supervisor position after the detail.

B. Administrative proceedings before the MSPB

In late 2023, Roberson filed an appeal with the Merit Systems Protection Board (MSPB), the agency tribunal that hears appeals of many federal personnel actions. The MSPB proceeding was still pending when he later filed suit in federal district court.

C. The federal lawsuit in the Middle District of Pennsylvania

In November 2024, Roberson—proceeding pro se—filed a federal civil action against the United States in the Middle District of Pennsylvania, raising 26 claims. The opinion groups these claims into seven substantive categories:

1. Transfer and non‑reinstatement: He alleged he was transferred without proper notice and not reinstated to his comptroller supervisor role after his headquarters detail, and that this was in retaliation for filing a grievance.
2. Inaccurate personnel records: He claimed his position was inaccurately recorded in official records after his transfer.
3. Grievance procedure issues: He asserted that he was not given adequate information about grievance procedures and that proper procedures were not followed.
4. Harassment and hostile work environment: He alleged that he experienced harassment and a hostile work environment after he submitted his grievance.
5. Unfair performance evaluation: He challenged the performance rating he received.
6. Denied training opportunities: He claimed he was improperly denied training that should have been provided.
7. Ignored hiring recommendation: As lead member of a hiring recommendation panel, he recommended a candidate who ultimately was not hired; he challenged that decision.

As legal bases, Roberson invoked:

• the Civil Service Reform Act (CSRA),
• the Federal Tort Claims Act (FTCA), and
• various Pennsylvania statutes.

Soon after filing, Roberson submitted a motion he labeled as one for summary judgment but that requested a default judgment. The United States moved to dismiss, arguing lack of subject‑matter jurisdiction under the CSRA’s exclusive remedial scheme.

With the parties’ consent, a Magistrate Judge (Hon. Daryl F. Bloom) presided and:

• dismissed the complaint for lack of subject‑matter jurisdiction, and
• denied the motion for default judgment.

D. Appeal to the Third Circuit

Roberson appealed, arguing principally that:

• his claims should be treated as arising under Pennsylvania statutes and “due process failure by malpractice,” rather than as CSRA claims; and
• the District Court erred by not granting his motion for default (or by not treating it as a proper summary judgment motion).

The Third Circuit exercised jurisdiction under 28 U.S.C. § 1291 and decided the case on the briefs pursuant to L.A.R. 34.1(a).

III. Summary of the Third Circuit’s Opinion

The Court of Appeals, in a per curiam opinion, affirmed the District Court on two main points:

1. CSRA Exclusivity / Lack of District Court Jurisdiction
   The court held that all of Roberson’s claims, however labeled, challenge “personnel actions” and “prohibited personnel practices” covered by the CSRA. Because the CSRA establishes an exclusive review scheme that runs through the MSPB and then the Federal Circuit, federal district courts lack subject‑matter jurisdiction over such disputes.
2. Denial of Default Judgment
   The court also held that the District Court properly denied Roberson’s request for default judgment because no default had ever been entered under Federal Rule of Civil Procedure 55(a). Treating his filing as a motion for default rather than as a motion for summary judgment was not error because the motion itself requested default.

Accordingly, the judgment of dismissal was affirmed, and the appellate court did not reach the District Court’s alternative jurisdictional theories or new issues raised for the first time in Roberson’s reply brief.

IV. Doctrinal Framework and Precedents Cited

A. The Civil Service Reform Act (CSRA)

The CSRA is a comprehensive statute that governs federal civil service personnel actions. Two sets of provisions are especially important here:

1. “Personnel actions” – 5 U.S.C. § 2302(a)(2)(A)
   This section defines the kinds of employment decisions that fall within the CSRA regime, including:
   • Details, transfers, or reassignments (§ 2302(a)(2)(A)(iv));
   • Performance evaluations (§ 2302(a)(2)(A)(vii));
   • Decisions concerning education or training (§ 2302(a)(2)(A)(ix)); and
   • “Any other significant change in duties, responsibilities, or working conditions” (§ 2302(a)(2)(A)(xii)).
2. “Prohibited personnel practices” – 5 U.S.C. § 2302(b)
   This section identifies improper motives or methods for taking personnel actions, such as:
   • Retaliation for protected disclosures evidencing an “abuse of authority” (§ 2302(b)(8)(A)(ii));
   • Retaliation for filing a grievance (§ 2302(b)(9)); and
   • Personnel actions contrary to “merit system principles” (§ 2302(b)(12)), as set out in § 2301.

The CSRA’s core structure is that covered personnel actions and prohibited personnel practices must be challenged through CSRA channels, with limited exceptions (e.g., certain anti‑discrimination “mixed cases,” not present here).

B. Supreme Court authority: United States v. Fausto and Elgin v. Department of Treasury

The Third Circuit relied on two key Supreme Court precedents:

1. United States v. Fausto, 484 U.S. 439 (1988)
   Fausto held that the CSRA sets out an exclusive and comprehensive “framework for evaluating adverse personnel actions” against federal employees, including “the availability of administrative and judicial review.” Because Congress created this detailed scheme, courts generally infer that it precludes other routes of review (e.g., Tucker Act suits or certain collateral actions) for covered personnel disputes.
2. Elgin v. Department of Treasury, 567 U.S. 1 (2012)
   Elgin confirmed that the CSRA’s review mechanism—MSPB review followed by Federal Circuit review—is the exclusive avenue for judicial review even when employees frame their challenge in constitutional terms (e.g., arguing a statute is unconstitutional as applied to them).

Together, these cases anchor the notion that Congress meant for CSRA to displace alternative litigation paths for covered federal employment disputes.

C. Third Circuit template: Manivannan v. U.S. Department of Energy

The Third Circuit’s own decision in Manivannan v. United States Department of Energy, 42 F.4th 163 (3d Cir. 2022), provides the doctrinal template the panel applies here.

Key points from Manivannan that are quoted or paraphrased in Roberson’s case:

• When deciding whether the CSRA bars federal jurisdiction over an “otherwise reviewable claim,” courts “look to the specific underlying conduct being challenged” to determine whether it is a “personnel action” under the CSRA (§ 2302(a)(2)(A)).
• If the lawsuit is, “at bottom, challenging an employment action within the MSPB’s jurisdiction,” it must proceed through the CSRA process and cannot be brought directly in district court.
• Where the CSRA applies, the employee is “confined to the remedies it offers.”
• The court also warned that entertaining such suits would “infringe on territory exclusive to the MSPB.”

The Roberson panel invokes this framework to characterize each of Roberson’s causes of action as, in substance, a challenge to CSRA‑covered personnel actions.

D. Other cited cases: standards of review and ancillary issues

• In re Horizon Healthcare Services Inc. Data Breach Litigation, 846 F.3d 625 (3d Cir. 2017)
  Cited for the de novo standard of review when reviewing a Rule 12(b)(1) dismissal for lack of subject‑matter jurisdiction.
• Erickson v. Pardus, 551 U.S. 89 (2007)
  Quoted for the proposition that the court must liberally construe pro se pleadings.
• Chamberlain v. Giampapa, 210 F.3d 154 (3d Cir. 2000)
  Cited for two points: the abuse‑of‑discretion standard for reviewing a denial of default judgment, and the procedural requirements under Rule 55.
• Weaver v. U.S. Information Agency, 87 F.3d 1429 (D.C. Cir. 1996)
  Cited to emphasize that one of the CSRA’s “merit system principles” is that federal employees must be treated “with proper regard for their privacy and constitutional rights” (5 U.S.C. § 2301(b)(2)).
• Stone v. FDIC, 179 F.3d 1368 (Fed. Cir. 1999)
  Cited as an example of the MSPB and the Federal Circuit adjudicating procedural due process claims within the CSRA review framework—demonstrating that constitutional issues can be raised there.
• Barna v. Board of School Directors of Panther Valley School District, 877 F.3d 136 (3d Cir. 2017)
  Invoked for the basic appellate rule that arguments raised for the first time in a reply brief are generally not considered.

V. The Court’s Legal Reasoning

A. Characterizing Roberson’s claims as CSRA “personnel actions”

The court starts with the premise that substance controls over labels. Following Manivannan, the panel looks to “the specific underlying conduct” being challenged.

Roberson’s key factual complaints map neatly onto the CSRA’s definition of “personnel actions” in § 2302(a)(2)(A):

• Transfer / reassignment / detail
  His reassignment from comptroller supervisor and alleged failure to reinstate him fit exactly within § 2302(a)(2)(A)(iv), which explicitly lists “a detail, transfer, or reassignment” as a covered personnel action.
• Performance evaluation
  His challenge to his “fully successful” performance rating corresponds to § 2302(a)(2)(A)(vii), which identifies “a performance evaluation” as a personnel action.
• Denied training opportunities
  His claim that he was improperly denied training falls within § 2302(a)(2)(A)(ix), which covers decisions concerning education or training.
• Harassment and grievance‑related conduct / hiring recommendation
  The panel, echoing the District Court, treats:
  • alleged harassment after submitting his grievance,
  • inadequate responses to grievance requests, and
  • disregard of his hiring recommendations
  as encompassed by the catch‑all provision § 2302(a)(2)(A)(xii): “a significant change in duties, responsibilities, or working conditions.” These allegations, at least as pleaded, describe changes to the environment and conditions in which he worked, and thus qualify as CSRA personnel actions.

Once those actions are recognized as CSRA‑covered personnel actions, the CSRA’s exclusive remedial structure is triggered.

B. Identifying Roberson’s allegations as “prohibited personnel practices”

The opinion then addresses Roberson’s assertions about improper motives behind those personnel actions. The court notes that his allegations line up closely with several “prohibited personnel practices” under § 2302(b):

• Retaliation for grievance / abuse‑of‑authority complaint
  Roberson alleged he was harassed and reassigned because he complained of mistreatment and filed a grievance. The panel ties this to:
  • § 2302(b)(8)(A)(ii): banning personnel actions taken because of an employee’s “disclosure of information” reasonably believed to evidence, among other things, an “abuse of authority”; and
  • § 2302(b)(9): banning personnel actions taken because an employee has filed a “grievance.”
• Violations of merit system principles
  His other claims—unfair evaluations, denial of training, and the decision to go against his hiring recommendation—are characterized as alleged violations of “merit system principles” under § 2302(b)(12), which forbids personnel actions that violate the principles listed in § 2301. The opinion specifically cites:
  • § 2301(b)(2): employees should receive “fair and equitable treatment in all aspects of personnel management” and be treated with proper regard for their privacy and constitutional rights;
  • § 2301(b)(4): personnel management should “maintain high standards of integrity, conduct, and concern for the public interest”;
  • § 2301(b)(7): employees should “be provided effective education and training” where that would improve their performance.

By linking Roberson’s allegations to specific CSRA provisions, the panel underscores that his disputes are plainly CSRA‑type prohibited personnel practice claims, even though he attempted to invoke other statutory and constitutional labels.

C. Treatment of due process and constitutional arguments

Roberson also characterized some claims—particularly those relating to requests for information and the grievance process—as “due process” violations and suggested he could not raise such claims in MSPB proceedings.

The Third Circuit rejects that position on two grounds:

1. Substantively, these claims still concern “procedures by which the alleged employment actions took place”, so they remain bound up with CSRA personnel actions and merit principles (including the requirement that employees be treated with proper regard for their privacy and constitutional rights, § 2301(b)(2)).
2. Institutionally, the court notes that the MSPB regularly hears constitutional and due process claims, and that employees may seek review of MSPB constitutional rulings in the Federal Circuit. The opinion cites:
   • Weaver, recognizing the privacy/constitutional‑rights element of merit system principles; and
   • Stone, where the Federal Circuit reviewed a claim that an employee’s procedural due process rights were violated in removal proceedings.
   This squares with Elgin’s holding that constitutional claims about CSRA‑covered personnel actions must proceed within the CSRA framework.

Thus, the presence of constitutional language in a complaint does not grant district courts jurisdiction to bypass the CSRA process.

D. Rejection of Roberson’s reliance on Pennsylvania statutes

On appeal, Roberson argued that his allegations “all fall under Pennsylvania Statute Violations” as a “Due Process Failure by Malpractice,” and that this supposedly makes the District Court the correct forum. He cited three provisions of Pennsylvania law:

• 77 Pa. Stat. Ann. § 41;
• 77 Pa. Stat. Ann. § 51; and
• 77 Pa. Stat. Ann. § 1302.

Those provisions are part of the Pennsylvania Workers’ Compensation Act and Occupational Disease Act, addressing employer liability for employees’ injuries or negligence in the course of employment. The court notes that they have “no apparent relevance” to Roberson’s allegations, which center on personnel actions and internal management decisions, not workplace injuries or occupational disease.

More fundamentally, the panel emphasizes that no matter how Roberson chooses to label his claims, review of those CSRA‑covered personnel disputes by a district court would “infringe on territory exclusive to the MSPB,” echoing the phrasing from Manivannan. Defining a claim as arising under state law cannot expand federal subject‑matter jurisdiction where Congress has affirmatively channeled such disputes into a different remedial scheme.

E. Jurisdictional conclusion: District Court properly dismissed

Having determined that:

• Roberson’s allegations involve CSRA “personnel actions” and “prohibited personnel practices”; and
• those issues are within the exclusive purview of the CSRA’s review scheme (MSPB → Federal Circuit),

the Third Circuit affirms that the District Court lacked subject‑matter jurisdiction over the complaint. The court also notes:

• Because the CSRA analysis suffices to resolve the case, the panel does not reach the District Court’s alternative jurisdictional grounds.
• Any new arguments raised for the first time in Roberson’s reply brief are not considered, consistent with Barna.

Finally, the panel addresses Roberson’s challenge to the denial of his request for a default judgment.

Under Federal Rule of Civil Procedure 55:

1. Rule 55(a) – The clerk enters “default” when a party has failed to plead or otherwise defend.
2. Rule 55(b) – After default is entered, the plaintiff can seek a default judgment from the clerk (in some cases) or from the court.

The Third Circuit holds:

• There was no entry of default in this case; therefore, a default judgment could not properly be granted.
• To the extent Roberson argued on appeal that the District Court should have treated his motion as a summary‑judgment motion (under Rule 56), the panel finds no error in the District Court’s approach. Roberson’s filing explicitly requested default judgment, and the District Court acted accordingly.

Thus, there was no abuse of discretion in denying his request for default judgment.

VI. Simplifying Key Legal Concepts

A. Subject‑matter jurisdiction

Subject‑matter jurisdiction is a court’s authority to hear a particular type of case. It is conferred by the Constitution and statutes, not by the parties’ consent. If Congress has created a special, exclusive review scheme for a class of disputes—as it has for many federal personnel actions under the CSRA—then ordinary district courts may lack jurisdiction even if the claims would otherwise resemble tort or constitutional claims.

In this case, the Third Circuit held that the CSRA’s comprehensive scheme removes district courts’ jurisdiction over Roberson’s claims, because those claims are squarely in the CSRA’s domain.

B. “Personnel actions,” “prohibited personnel practices,” and “merit system principles”

• Personnel actions are the types of employment decisions covered by the CSRA—e.g., hiring, firing, promotions, reassignments, performance reviews, training decisions, and other significant changes in job duties or working conditions.
• Prohibited personnel practices describe unlawful reasons or methods for taking personnel actions—e.g., retaliation for whistleblowing, discrimination based on protected activities, or actions taken in violation of merit system principles.
• Merit system principles (5 U.S.C. § 2301) are general standards for fair and effective federal personnel management—e.g., fair and equitable treatment, integrity in personnel actions, and appropriate training.

When an employee alleges both a particular personnel action (such as a transfer or a performance review) and a prohibited reason (such as retaliation for a grievance), the claim is a classic CSRA prohibited personnel practice claim.

C. The MSPB and Federal Circuit review

The Merit Systems Protection Board (MSPB) is an independent quasi‑judicial agency that hears appeals from many federal employees who challenge CSRA‑covered personnel actions.

The usual path for a covered employee is:

1. Take the matter to the MSPB (after exhausting any required internal agency procedures).
2. Receive an initial decision (often from an administrative judge), then a final Board decision.
3. Seek judicial review of the MSPB’s final decision in the U.S. Court of Appeals for the Federal Circuit, which has exclusive jurisdiction in most such appeals.

This channel remains the route even for constitutional objections to the validity or application of federal personnel rules, as confirmed in Elgin.

D. Default vs. default judgment vs. summary judgment

• Default (Rule 55(a)): A procedural status entered by the clerk when a defending party “has failed to plead or otherwise defend.” It is a prerequisite to any default judgment.
• Default judgment (Rule 55(b)): A final judgment entered against a party in default, usually when that party has not appeared or contested the action.
• Summary judgment (Rule 56): A determination on the merits that no genuine disputes of material fact exist and that the moving party is entitled to judgment as a matter of law, based on the record (pleadings, affidavits, discovery, etc.).

In Roberson’s case, he requested a default judgment without any prior entry of default, and the government was actively defending the case (including filing a motion to dismiss). Thus, the request for default was procedurally unfounded, and the court did not treat it as a motion for summary judgment.

VII. Impact and Implications

A. Reinforcing CSRA exclusivity in the Third Circuit

While nonprecedential, the decision reinforces an already strong line of authority: federal employees in the Third Circuit cannot bypass the CSRA by relabeling their grievances as tort claims, state‑law claims, or even pure constitutional claims. The court will:

• look past the legal labels to the underlying employment conduct, and
• if that conduct is a CSRA “personnel action,” treat the claim as confined to the CSRA remedial scheme.

Roberson’s attempt to invoke Pennsylvania workers’ compensation statutes illustrates that artful pleading cannot escape CSRA preclusion.

B. Clarifying that procedural and due process challenges are still “CSRA claims”

An important nuance in this opinion is the court’s treatment of claims framed as procedural or constitutional challenges:

• Roberson argued his disputes were about the procedures used in transferring him, evaluating him, or processing his grievances, rather than about the underlying actions themselves.
• The panel responds that challenges to the procedures by which personnel actions are taken are still part of a CSRA dispute, especially when grounded in merit system principles and due process concepts.
• The MSPB and Federal Circuit remain the appropriate fora for legitimate due process challenges to CSRA‑governed personnel actions.

This confirms that separating process from substance does not create a separate, district‑court cause of action when federal personnel decisions are at issue.

C. Practical implications for federal employees and counsel

For federal employees and practitioners, the case underscores several practical points:

1. Early issue‑spotting
   When an employment dispute involves transfers, evaluations, training, disciplinary actions, or hostile changes in working conditions, it is almost always a CSRA matter. Employees must be directed toward agency grievance processes and, if appropriate, MSPB appeals rather than directly to district court.
2. Limited role for FTCA and state‑law theories
   Tort and state‑law employment theories have very limited application in the federal civil service context, particularly when they overlap substantively with CSRA‑covered personnel matters. Attempting to cast personnel disputes as negligence or malpractice under state law will generally fail in federal court.
3. Constitutional claims do not create an “escape hatch”
   Framing an employment challenge as a violation of due process or constitutional rights does not move the dispute outside the CSRA framework. Those constitutional objections must be aired in MSPB proceedings and, if necessary, on review in the Federal Circuit.
4. Procedural rigor in default practice
   The decision also serves as a reminder that default practice under Rule 55 has specific steps:
   • First, seek entry of default by the clerk;
   • only then, if appropriate, move for default judgment.
   A responsive defendant and a pending motion to dismiss virtually foreclose default.

D. Boundaries and unresolved areas

The opinion does not attempt to redraw the outer boundaries of CSRA exclusivity but illustrates how broadly the list of “personnel actions” and “significant change in duties, responsibilities, or working conditions” can be applied. Questions that remain for other cases include, for example:

• How far claims of workplace harassment or hostile environment extend as “significant changes in working conditions” under § 2302(a)(2)(A)(xii);
• How CSRA exclusivity interacts with potential statutory discrimination claims (e.g., under Title VII or the ADEA) in “mixed” cases, which follow somewhat different channels not implicated here.

Nonetheless, within its CSRA‑centric facts, the decision’s message is clear: employment disputes like Roberson’s are handled within the CSRA’s specialized system, not through general civil litigation.

VIII. Conclusion

Jain‑Miecell Roberson v. United States provides a focused application of the CSRA’s exclusive remedial framework to a familiar pattern of federal employment grievances: dissatisfaction with evaluations, perceived retaliation for grievances, disputes about reassignments, and complaints about hostile treatment and denied training.

The Third Circuit:

• Catalogs each of Roberson’s claims as a CSRA “personnel action” or prohibited personnel practice under 5 U.S.C. § 2302;
• Reaffirms that such disputes must proceed via MSPB and Federal Circuit review, not collateral suits in district court, even when framed as constitutional or state‑law wrongs; and
• Clarifies the proper use of default judgment procedures, rejecting Roberson’s attempt to secure judgment in the absence of any entry of default.

Though nonprecedential, the opinion is a strong reminder that the CSRA is not merely one tool among many for federal employees: for covered personnel disputes, it is the tool, and it defines both the rights and the forum. Employees and practitioners must therefore shape their strategies—and expectations—around the CSRA’s channels and limitations rather than around general civil litigation remedies.