N.D. Ill. Notes Split Re Whether Civil Service Reform Act Precludes Court From Authorizing Injunctive Relief

Per Pubentz v. Holder, 2011 WL 1900196 (N.D. Ill. May 19, 2011):

[T]here is a circuit split as to whether, under the CSRA [Civil Service Reform Act of 1978], a court is precluded from authorizing injunctive relief.^FN5 The Seventh Circuit has not addressed the issue.

FN5. Compare Saul v. United States, 928 F.2d 829, 843 (9th Cir.1991), and Stephens v. Dep't of Health & Human Servs., 901 F.2d 1571, 1576 (11th Cir.1990), and Lombardi v. Small Bus. Admin., 889 F.2d 959, 962 (10th Cir.1989) (holding CSRA as the exclusive vehicle for all federal employee claims related to federal employment), with Spagnola v. Mathis, 859 F.2d 223, 229 (D.C.Cir.1988) and Mitchum v. Hurt, 73 F.3d 30 (3d Cir.1995).