Charles Klein, Jr. v. Usps

Summary

After the Postal Service stopped delivering mail directly to the Kleins' and Havens' properties on Hillman Ridge Road in Brown County, Ohio, the property owners sued asserting a 'class of one' equal-protection claim. The Sixth Circuit affirmed dismissal of the first amended complaint for lack of subject matter jurisdiction, holding under the Thunder Basin framework that the Postal Accountability and Enhancement Act fairly discernibly channels such complaints exclusively to the Postal Regulatory Commission. At step two, all three factors confirmed the channeling: meaningful judicial review remains available in the D.C. Circuit, the claim is not wholly collateral because it mirrors 39 U.S.C. § 403(c)'s prohibition on unreasonable discrimination among mail users, and the Commission's postal expertise can be brought to bear on the rational-basis question.