LACHANCE v. ERICKSON

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Case Basics
Docket No. 
96-1395
Petitioner 
LaChance
Respondent 
Erickson
Advocates
(Argued the cause for the respondents)
(Department of Justice, argued the cause for the petitioner)
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Term:
Facts of the Case 

Federal employees subject to adverse actions by their respective agencies, each made false statements to agency investigators with respect to the misconduct with which they were charged. In each case, the agency additionally charged the false statement as a ground for adverse action. Separately, each employee appealed the actions taken against him or her to the Merit Systems Protection Board (Board). The Board upheld the portion of each penalty that was based on the underlying charge. The Board overturned each false statement charge. The Board held that an employee's false statements could not be used for purposes of impeaching the employee's credibility, nor could they be considered in setting the appropriate punishment for the employee's underlying misconduct. Ultimately, the Court of Appeals for the Federal Circuit agreed with the Board and held that no penalty could be based on a false denial of the underlying claim.

Question 

Does either the Due Process Clause or the Civil Service Reform Act preclude a federal agency from sanctioning an employee for making false statements to the agency regarding alleged employment-related misconduct on the part of the employee?

Conclusion 
Decision: 9 votes for LaChance, 0 vote(s) against
Legal provision: Due Process

No. In an unanimous opinion delivered by Chief Justice William H. Rehnquist, the Court held that neither the Fifth Amendment's Due Process Clause nor the Civil Service Reform Act precludes a federal agency from sanctioning an employee for making false statements to the agency regarding his alleged employment-related misconduct. "The core of due process is the right to notice and a meaningful opportunity to be heard," wrote Chief Justice Rehnquist. "But we reject, on the basis of both precedent and principle," continued Chief Justice Rehnquist, "the view expressed by the Court of Appeals in this case that a 'meaningful opportunity to be heard' includes a right to make false statements with respect to the charged conduct."

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LACHANCE v. ERICKSON. The Oyez Project at IIT Chicago-Kent College of Law. 11 September 2014. <http://www.oyez.org/cases/1990-1999/1997/1997_96_1395>.
LACHANCE v. ERICKSON, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1990-1999/1997/1997_96_1395 (last visited September 11, 2014).
"LACHANCE v. ERICKSON," The Oyez Project at IIT Chicago-Kent College of Law, accessed September 11, 2014, http://www.oyez.org/cases/1990-1999/1997/1997_96_1395.