U.S. Court of Appeals for the Federal Circuit

Surti v. Mspb

September 9, 2026

Summary

The Federal Circuit affirmed the Merit Systems Protection Board’s dismissal of Surti’s appeal, holding that paid administrative leave is not an adverse action subject to Board jurisdiction and that Surti failed to non‑frivolously allege protected whistleblower activity for an individual‑right‑of‑action appeal.