Background
Jonathan Chatman was a permanent, classified employee of the Louisiana Department of Health when the department removed him from employment on February 28, 2024. His removal letter advised him that he had 30 days from receipt to appeal to the Louisiana State Civil Service Commission. Chatman did not pursue that appeal.
Instead, in September 2025, Chatman sued LDH, its former secretary Ralph Abraham, the Department of State Civil Service, and its director Byron Decoteau in Bossier Parish district court. His pleadings challenged the legality of his removal and sought reinstatement, back pay, costs, and a civil-service hearing. The defendants raised lack of subject-matter jurisdiction and improper venue. The district court sustained the jurisdictional exceptions and dismissed the claims.
The Court’s Holding
The Second Circuit affirmed. Under Article 10, Section 12(A) of the Louisiana Constitution, the State Civil Service Commission has exclusive authority over removal and disciplinary cases involving permanent classified employees. That exclusive jurisdiction prevents district courts from exercising concurrent jurisdiction over employment disputes between classified employees and their employers.
Chatman’s various pleadings—including those invoking mandamus—still sought relief based on his alleged wrongful termination. He could not avoid the Commission’s exclusive jurisdiction by labeling the dispute as another type of action. The court also rejected his claim that parties should have been sworn before the hearing because no witnesses testified, only counsel and Chatman presented argument. His venue arguments failed because the district court never ruled on the venue exceptions after dismissing the case for lack of jurisdiction.
Key Takeaways
- Permanent classified Louisiana employees must pursue removal and disciplinary disputes through the State Civil Service Commission.
- Relabeling a termination dispute as mandamus or another civil action does not create district-court jurisdiction.
- Once the district court dismissed for lack of subject-matter jurisdiction, it did not need to decide the defendants’ venue objections.
Why It Matters
The decision reinforces that the Civil Service Commission is the exclusive initial forum for challenges to the removal of permanent classified state employees. Employees who bypass the Commission’s appeal process cannot obtain reinstatement, back pay, or a civil-service hearing by filing a wrongful-termination action in district court.