“Class of one” equal-protection claim related to postal delivery service; Subject-matter jurisdiction; 28 USC § 1331; Effect of an administrative review scheme; Elgin v Department of Treasury; Thunder Basin Coal Co v Reich; Free Enter Fund v Public Co Accounting Oversight Bd; Axon Enter, Inc v Federal Trade Comm’n; The Postal Accountability & Enhancement Act (PAEA); 39 USC § 3662

The court held that plaintiffs’ “class of one” equal-protection claim concerning defendant-USPS’s failure to deliver mail to their property had to be filed before the Postal Regulatory Commission. Thus, it affirmed the district court’s dismissal of their first amended complaint for lack of jurisdiction. The USPS stopped delivering to the mailbox at the end of plaintiffs’ driveway on a single lane road after a confrontation between one of their neighbors and a mail carrier. They have to “travel to a mailbox about half a mile down the road to retrieve letters and five miles into” a town for parcels. The court applies a two-step process to “determine whether an administrative review scheme divests a district court of jurisdiction over a constitutional claim[.]” At step one, it considered “whether the PAEA, ‘by specifying a different method to resolve claims about agency action,’ implicitly supplants § 1331’s grant of jurisdiction.” It concluded, after reviewing “the PAEA’s text, structure, context, and purpose, Congress’s intent to supplant federal district court jurisdiction over those matters expressly placed within the Commission’s purview is fairly discernible.” The court determined that Congress intended “that the Commission have exclusive jurisdiction over service- and rate-related complaints.” It next found that plaintiffs fared “no better at step two, because each of the three Thunder Basin factors indicates that this particular case belongs before the Postal Regulatory Commission.” The court noted that the fact all three of those factors indicated that their “‘claim is “of the type” Congress thought belonged within [the] statutory scheme’” helped explain why courts, including this one, “have all held that the Commission has exclusive jurisdiction over claims like Plaintiffs’, even when they are framed as constitutional issues.”