The U.S. Court of Appeals for the Federal Circuit affirmed the termination of a longtime Navy Department employee who was fired for security violations involving his government-issued cellphone, according to a decision filed Jan. 12, 2026.
The court ruled in *Madigan v. Department of the Navy* that the Merit Systems Protection Board's decision upholding Patrick J. Madigan's termination was supported by substantial evidence and in accordance with law. Madigan had challenged his firing through the federal employment appeals process.
Madigan began working for the Navy in 1992 and by the late 1990s was issued a cellular telephone, referred to as a Personal Electronic Device or PED. Over his decades-long career, he was promoted to Chief Engineer for the Navy's Commander Undersea Surveillance unit, which operated out of a secure facility.
The case originated in March 2021 when Lieutenant Commander Joseph Sanders began investigating reports that Madigan had misused his government PED within a secure CUS space. As part of the investigation, the Navy confiscated Madigan's device and discovered problematic material.
According to the court filing, the Navy found sexually graphic images on the device, as well as text messages and images that the agency contended violated security protocols. The discovery led to Madigan's termination from his position.
Madigan challenged the firing before the Merit Systems Protection Board, which provides federal employees with appeal rights in adverse personnel actions. The board ruled against Madigan, prompting his petition to the Federal Circuit.
The Federal Circuit's three-judge panel, consisting of Circuit Judges Prost, Wallach, and Stark, issued a brief per curiam opinion affirming the board's decision. The court found that the board's final decision was "supported by substantial evidence and in accordance with law."
The case highlights the strict security protocols governing federal employees who work in classified or secure environments. The Navy's Commander Undersea Surveillance unit operates in facilities where electronic devices are typically prohibited or heavily restricted due to national security concerns.
Government employees in sensitive positions are subject to enhanced scrutiny regarding their use of official equipment and adherence to security protocols. The misuse of government-issued devices, particularly in secure areas, can result in serious disciplinary action including termination.
The Federal Circuit's decision was marked as nonprecedential, meaning it cannot be cited as binding authority in future cases but reflects the court's application of established law to similar factual circumstances.
Madigan was represented by Ben Johnson of Pierce Jewett, PLLC in Richmond, Virginia. The Justice Department's Civil Division represented the Navy, with attorneys Patrick Angulo, Albert S. Iarossi, Patricia M. McCarthy, and Brett Shumate handling the case.
The Merit Systems Protection Board serves as an independent agency that protects federal employees from prohibited personnel practices while ensuring agencies can take appropriate disciplinary action. The board's decisions can be appealed to the Federal Circuit in cases involving certain types of personnel actions.
The Federal Circuit has jurisdiction over appeals from the Merit Systems Protection Board and regularly reviews cases involving federal employment disputes. The court's expertise in federal personnel law makes it the primary appellate venue for such matters.
The case demonstrates the consequences federal employees can face for violating security protocols, particularly those working in sensitive national security positions. The Navy's ability to maintain the termination despite the lengthy appeals process underscores the seriousness with which security breaches are treated.
For federal employees in secure environments, the decision serves as a reminder of the importance of strictly adhering to policies governing the use of government equipment and maintaining security protocols in classified areas. The case also illustrates the substantial deference courts give to agency determinations when supported by adequate evidence.
The ruling concludes a multi-year process that began with the 2021 investigation and proceeded through the Merit Systems Protection Board before reaching the Federal Circuit. The affirmation of Madigan's termination represents the final resolution of his challenge to the Navy's disciplinary action.