Background
In 2020, the United States Postal Service implemented operational changes affecting mail collection, processing, and delivery. Several states and municipalities sued in district court, arguing these changes would impede mail-in voting and public services. The district court granted a preliminary injunction and later summary judgment for the plaintiffs on a claim that the Postal Service failed to request an advisory opinion from the Postal Regulatory Commission before implementing the changes.
The court’s reasoning
The court applied the two-step Thunder Basin framework to determine if the statutory review scheme displaced district court jurisdiction. At step one, the court found Congress created a specialized review scheme for challenges to Postal Service policy changes that generally displaces district court jurisdiction. At step two, the court concluded the States’ advisory opinion claim was squarely within the scope of the statutory scheme, was not wholly collateral, and fell within the Commission’s expertise. The court rejected arguments that the review scheme would not provide meaningful judicial review or that the preliminary injunction made Commission review moot.
We conclude the district court had no jurisdiction over that claim. Congress created a review scheme that channels certain complaints about Postal Service policies first to the Postal Regulatory Commission, with subsequent review in this court.
What it means going forward
The grant of summary judgment for the States is vacated, and the case is remanded with instructions to dismiss the advisory opinion claim. Future challenges to similar Postal Service policy changes must be filed first with the Postal Regulatory Commission.