TITLE AND CITATION
The case was between Plaintiff-Appellant (John C. Ryan) and Defendant-Appellee (United States Department of Justice).
TYPE OF ACTION
Agent Ryan was relieved of his duties after 21 years of service with the FBI due to disobedience. He went to court accusing FBI of discrimination based on his religious beliefs.
FACTS OF THE CASE
In October 1986,vandalism took place at military recruiting facilities. Messages at the spot linked the destruction with pacifist groups, later identified as “Veterans Fast for Life” and “Plowshares”. The FBI issued a memoinstructing its agents to contact logical law enforcement departments to determine any similar incidents. John C. Ryan, who was in charge of domestic security and terrorism investigations at the FBI’s office in Peoria, Illinois, also received a copy of the memo. Ryan decided not to comply and be involved in this case because of his personal and religious beliefs. Ryan also decided to refuse agent James Swinford’srequest to swap assignments with Ryan. Thomas Jones, the agent in charge of the Peoria office,asked Ryan to carry out the order he receivedbut Ryan refused again. Jones started Ryan’s insubordination in 1987, and Ryan was fired after 21 years of service.
ISSUE
Due to his religious beliefs, Ryan refused to investigatean anti-military activity that wascharacterized bynonviolent, although illegal, acts. As Ryan exhibited formal disobedience instead of asking to be relieved of the assignment, he invited a formal reply. However, he was not prepared for such severe consequences. Therefore, Ryan required from the FBI to discuss the accommodation of his beliefs. However, this argument was problematic because Title VII requires strict action, without any discussion.
DECISION
The FBI elegantly elaborated its decision. Ryan’s beliefs were not questioned, his deeds were.
REASONING
The decision to fire him came as a result of hisdirect refusalto follow a direct order. Additionally, Ryan refused Swinford’s proposition to swap duties. Therefore, the ground for FBI’s decision was not discrimination on account of religion.
The district judge repeatedAssistant Director Glover’s reasoning that it is hard to create special work within an office where people are required to handle everything that is assigned to them. He stated that moving an agent to another office involves “more than a de minimis cost”, while employers cannot encourage employees who are choosy with regards to their duties.Glover rejected passivity in this case because he firmly believed thatRyan’s disobedience was inconsistent with the FBI’s mission.
RULE OF LAW
The merit systems protection board and the administrative judge in charge concluded the issue stating that FBI is not responsible for a situation when one’s religious beliefs interfere with the missions of the FBI. The district court that reviewed the record under 5 U.S.C. § 7703(b)(2) andconcluded that MSPB’s decision is in accordance with the law and supported by evidence.The court also held a trial on de novo with regard to his complaints under Title VII of the Civil Rights Act of 1964 (“Casetext,” n.d.).
Reference
Casetext. (n.d.). Retrieved from https://casetext.com/case/ryan-v-department-of-justice-2