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Robin Gary Smith v. Federal Aviation Administration Department of Transportation

Citations: 47 F.3d 1178; 1995 U.S. App. LEXIS 10865; 1995 WL 74675Docket: 94-9545

Court: Court of Appeals for the Tenth Circuit; February 23, 1995; Federal Appellate Court

Narrative Opinion Summary

In this case, the appellant contested the Federal Aviation Administration's decision not to renew his Pilot Examiner Designation, alleging that such non-renewal constituted an unlawful taking and violated his due process rights. The Tenth Circuit Court of Appeals analyzed whether the appellant had a recognized property or liberty interest in the designation that would necessitate due process protections. The court noted that establishing such an interest required a legitimate claim of entitlement, rather than a mere expectation. It was determined that the appellant had been notified by the FAA of his right to submit additional information or request an informal hearing within a specified period, an opportunity he did not utilize. As a result, the court found his due process claims unsubstantiated and dismissed his petition. The decision is not a binding precedent but may be cited under certain conditions as outlined in a prior General Order.

Legal Issues Addressed

Due Process in Administrative Decisions

Application: The court evaluated whether the appellant had a recognized property or liberty interest in the Pilot Examiner Designation that would require due process protections.

Reasoning: The Tenth Circuit Court of Appeals examined whether Smith had a recognized property or liberty interest in the PED, which would necessitate due process protections.

Legitimate Claim of Entitlement

Application: The court determined that the appellant needed to demonstrate a legitimate claim of entitlement to the PED to warrant due process, beyond mere desire or expectation.

Reasoning: However, the court noted that to establish such an interest, Smith must show a legitimate claim of entitlement beyond mere desire or expectation.

Opportunity to Respond

Application: The court found that the appellant was given adequate opportunity to respond to the FAA's decision by submitting additional information or requesting an informal hearing.

Reasoning: Smith had received a notification from the FAA that explicitly allowed him the option to submit additional information or request an informal hearing within ten days.

Sufficiency of Due Process Claims

Application: The appellant's due process claim was deemed insufficient as he did not demonstrate that he was denied the opportunity to respond to the FAA's decision.

Reasoning: Therefore, the court concluded that his due process argument lacked merit, as the evidence indicated he was given an opportunity to respond.