Dayton v. Hanson
Hanson sued the Office of Senator Mark Dayton under the Congressional Accountability Act, alleging that the Office violated the Family and Medical Leave Act by firing him for a perceived disability, and the Fair Labor Standards Act by failing to pay him overtime compensation. The Office asserted immunity from suit under the Speech or Debate Clause of the United States Constitution and moved to dismiss the complaint for lack of subject matter jurisdiction. The Office claimed that Hanson assists the representative in performing legislative duties, and thus any personnel decisions are shielded by the Speech or Debate Clause.
The district court denied the motion and the Court of Appeals for the District of Columbia Circuit affirmed. The Court held that a the personal office of a member of Congress may be liable under the Accountability Act for misconduct provided that the plaintiff can prove his case without inquiring into “legislative acts or the motivation for legislative acts.”
Questions Presented:
Does the Speech or Debate Clause of the U.S. Constitution, U.S. CONST. art. I, § 6, cl. 1, bar federal court jurisdiction of an action brought under the Congressional Accountability Act of 1995, 2 U.S.C. §§ 1301-1438 (2000), by a congressional employee whose job duties are part of the due functioning of the legislative process?
1) Was the Office of Senator Mark Dayton entitled to appeal the judgment of the Court of Appeals for the District of Columbia Circuit directly to this Court?
2) Was this case rendered moot by the expiration of the term of office of Senator Dayton?
