---
kind: "section"
citation: "22 U.S.C. § 4109"
title: "22"
title_heading: "Foreign Relations and Intercourse"
number: "4109"
heading: "Judicial review and enforcement"
release: "119-102"
date: "2026-07-12"
url: "https://uscodex.org/usc/22/4109"
units:
  - "Chapter 52 — Foreign Service"
  - "Subchapter X — Labor-Management Relations"
---

# §4109. Judicial review and enforcement

- (a) **Persons entitled to maintain action; time of filing; venue—** Except as provided in [section 4114(d) of this title](/usc/22/4114.md?p=d), any [person](/usc/22/4102.md?p=14) aggrieved by a final order of the [Board](/usc/22/4102.md?p=2) may, during the 60-day period beginning on the date on which the order was issued, institute an action for judicial review of such order in the United States [Court](/usc/22/4044.md?p=3) of Appeals for the District of Columbia.
- (b) **Enforcement of order; temporary relief or restraining order—** The [Board](/usc/22/4102.md?p=2) may petition the United States [Court](/usc/22/4044.md?p=3) of Appeals for the District of Columbia for the enforcement of any order of the [Board](/usc/22/4102.md?p=2) under this subchapter and for any appropriate temporary relief or restraining order.
- (c) **Applicability of other provisions of law—** Subsection (c) of [section 7123 of title 5](/usc/5/7123.md) shall apply to judicial review and enforcement of actions by the [Board](/usc/22/4102.md?p=2) in the same manner that it applies to judicial review and enforcement of actions of the [Authority](/usc/22/4102.md?p=1) under chapter 71 of title 5.
- (d) **Unfair labor practices—** The [Board](/usc/22/4102.md?p=2) may, upon issuance of a complaint as provided in [section 4116 of this title](/usc/22/4116.md) charging that any [person](/usc/22/4102.md?p=14) has engaged in or is engaging in an unfair labor practice, petition the United States District [Court](/usc/22/4044.md?p=3) for the District of Columbia, for appropriate temporary relief (including a restraining order). Upon the filing of the petition, the [court](/usc/22/4044.md?p=3) shall cause notice thereof to be served upon the [person](/usc/22/4102.md?p=14), and thereupon shall have jurisdiction to grant any temporary relief (including a temporary restraining order) it considers just and proper. A [court](/usc/22/4044.md?p=3) shall not grant any temporary relief under this section if it would interfere with the ability of the [Department](/usc/22/3902.md?p=4) to carry out its essential [functions](/usc/22/3902.md?p=6) or if the [Board](/usc/22/4102.md?p=2) fails to establish probable cause that an unfair labor practice is being committed.

## Source credit

(Pub. L. 96–465, title I, § 1009, Oct. 17, 1980, 94 Stat. 2133.)