Case Explained: ESSENFELD V. CAO

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-06-29 Docket: 4:25-cv-00465-JGZ-PSOT The Ninth Circuit affirmed the district court’s dismissal of Theodore E. Essenfeld’s pro se action challenging Navy disciplinary proceedings, holding that the federal courts lacked subject matter jurisdiction because the plaintiff failed to identify a final agency action. Applying the standard for administrative claims under the Administrative Procedure Act (APA), the court determined that a challenged agency action must mark the consummation of the agency’s decision-making process and result in determined rights, obligations, or legal consequences to be reviewable. While affirming the dismissal on these jurisdictional grounds, the court instructed the district court to amend the judgment to reflect that the dismissal is without prejudice, allowing the plaintiff to potentially refile if a final agency action can be identified. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.