The right of an employee to retreat to a lower-graded position when faced with separation in a reduction-in-force depends on the career progression of the position being sought, not the position from which the employee is retreating, says the U.S. Court of Appeals for the Federal Circuit. The court’s decision in Henderson v. Department of the Interior notes that by regulation, an employee may retreat to a position not more than three grades below the position from which the employee was released. In the Henderson decision, the court said that although the position the employee held at the time of the RIF had two-grade intervals for progression, the position being sought had one-grade intervals and thus the employee was more than three grades higher.