A federal appeals court recently ruled on a significant case involving a former State Department employee, Adele Ruppe, and Secretary of State Marco Rubio. The Court of Appeals for the D.C. Circuit decided on July 31, 2026, that Ruppe's claims against the State Department included a Fair Labor Standards Act (FLSA) damages claim that should not have been transferred to another court. This ruling is crucial for federal employees seeking to file claims under the FLSA, as it clarifies the jurisdictional landscape for such cases.
The case, Ruppe v. Rubio (Docket No. 24-5199), arose when Ruppe, a Foreign Service officer, alleged multiple violations of federal anti-discrimination laws after experiencing difficulties in her workplace. The court's decision impacts not only Ruppe but also other federal employees who may face similar issues regarding workplace discrimination and wage claims.
Background
Adele Ruppe joined the Foreign Service in 1993 and was promoted to the Senior Foreign Service in 2011. In 2014, she began working as a director in the Office of Public Diplomacy for the Bureau of European and Eurasian Affairs. Over the next two years, Ruppe sought a promotion to a deputy chief of mission position in Europe but faced challenges, including alleged discriminatory conduct from her direct supervisor.
In response to these issues, Ruppe filed an Equal Employment Opportunity complaint with the State Department's Office of Civil Rights. Following this, she took legal action against the Department, raising seven discrimination claims, including five under Title VII of the Civil Rights Act, one under the Rehabilitation Act of 1973, and one under the FLSA. Ruppe's FLSA claim sought damages exceeding $10,000.
The case initially went to the U.S. District Court for the District of Columbia. The district court granted summary judgment for the State Department on Ruppe's Title VII and Rehabilitation Act claims. However, it ruled that it lacked jurisdiction over her FLSA damages claim, citing a previous case, Waters v. Rumsfeld, which suggested that such claims should be handled exclusively by the Court of Federal Claims. Consequently, the district court transferred Ruppe's FLSA claim to that court, leading to her appeal.
The Ruling
The D.C. Circuit Court of Appeals affirmed the district court's summary judgment on Ruppe's Title VII and Rehabilitation Act claims but vacated the transfer of her FLSA claim. The court ruled that Waters could not be reconciled with a later Supreme Court decision, United States v. Bormes, which established that both district courts and the Court of Federal Claims have concurrent jurisdiction over FLSA damages claims against the United States.
The court stated, "We conclude that the district courts and the Court of Federal Claims have concurrent jurisdiction over FLSA damages claims against the United States. We therefore vacate the transfer and remand for the district court to consider Ruppe’s FLSA claim."
This ruling was delivered by Circuit Judge Rao, with Judges Wilkins and Pan also on the panel. The court's decision effectively overrules the precedent set by Waters, clarifying that federal employees can pursue FLSA claims in either court.
Impact
The D.C. Circuit's ruling has significant implications for federal employees. It establishes that they have the option to file FLSA claims in district courts, rather than being restricted to the Court of Federal Claims. This change may encourage more federal employees to seek justice for wage violations without the fear of being directed to a court that may not be as accessible or favorable for their claims.
By affirming concurrent jurisdiction, the court has opened the door for a more straightforward legal process for employees like Ruppe, who may face discrimination and wage-related issues. This ruling may also set a precedent for future cases involving similar claims, allowing more employees to challenge unfair practices within federal agencies.