Case Explained: STATE OF NEW YORK v. DONALD J. TRUMP

Court: United States Court of Appeals for the District of Columbia Circuit

Filed: 2026-07-14

The D.C. Circuit vacated the district court’s grant of summary judgment in favor of the States and remanded the case with instructions to dismiss the plaintiffs’ claim that the Postal Service violated 39 U.S.C. § 3661(b) by failing to seek an advisory opinion from the Postal Regulatory Commission before implementing 2020 operational changes. The court held that the district court lacked subject matter jurisdiction over this claim because Congress established a comprehensive statutory review scheme in the Postal Accountability and Enhancement Act (39 U.S.C. §§ 3661–63) that implicitly precludes initial district court review. Applying the two-step framework from *Thunder Basin Coal Co. v. Reich*, the court found that: (1) Congress’s intent to channel such complaints to the Commission is fairly discernible in the detailed statutory structure, which mandates initial administrative review followed by exclusive appellate review in the D.C. Circuit; and (2) the claim falls squarely within the scope of that scheme because it is not collateral to the statute, does not foreclose meaningful judicial review (as parties may petition this court after Commission action), and involves questions well within the Commission’s specialized expertise regarding postal policy changes. The court rejected the States’ argument that the urgency of the 2020 election or the lack of immediate injunctive relief from the Commission justified bypassing the administrative process, noting that Congress’s channeling decision imposes specific timing constraints that parties must adhere to.

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