Langeman v. Merrick Garland, No. 22-5264 (D.C. Cir. 2023)
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In this case, Michael W. Langeman, a former Special Agent with the Federal Bureau of Investigation (FBI), appealed against the dismissal of his complaint for failure to state a claim. Langeman was terminated from his position after an investigation by the Department of Justice (DOJ) revealed his mishandling of the investigation into sexual abuse allegations against USA Gymnastics Physician Lawrence Gerard Nassar. Langeman claimed that his termination violated his constitutional rights protected by the Fifth Amendment’s Due Process Clause. He argued that his termination violated a constitutionally protected property interest in his continued employment and deprived him of a constitutionally protected liberty interest in his reputation, thereby damaging his future employment in law enforcement.
The United States Court of Appeals for the District of Columbia Circuit disagreed with Langeman's arguments. The court held that Langeman failed to sufficiently plead deprivation of a property interest or liberty interest without due process. The court found that the FBI had explicitly retained the discretion to summarily terminate employees, and this did not create a legitimate property interest sufficient to state a claim under procedural due process. As for Langeman's claim of deprivation of a liberty interest, the court found that Langeman did not establish that any allegedly defamatory conduct accompanied his dismissal from government employment.
Therefore, the court affirmed the district court’s dismissal of Langeman’s complaint for failure to state a claim. It also found that Langeman could not demonstrate a clear right to relief for his mandamus claim due to his deficient due process allegations, therefore mandamus relief was not available to him.
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