v. United States, 364 Fed. Appx. 920 (5th Cir.2010). Because Stier was the proper party and Anderson filed her claim within the 1-year state of limitations for defamation claims in the State of Texas, see Tex. Civ. Prac. & Rem.Code Ann. § 16.002(a), the dismissal based on limitations was also erroneous. Anderson, 364 Fed.Appx. at 925. Similarly, because the United States was not the proper party, there were no administrative remedies to exhaust before bringing her intentional infliction of emotional distress claim. Id. 2 . We note that there have been cases in which a supervisor’s defamation claims against subordinates have been held to be preempted. See Schwartz, v. Int'l Fed. of Prof Is & Technical Eng’rs, No. 3:07-CV-0978-l, 2007 WL 3196347 (N.D.Tex. Oct. 31, 2007) (memo, op.) (<HOLDING>); Greene v. Am. Fed. of Gov’t Employees,
holding that employee did not invoke grievance procedure where he never mentioned the word grievance to the union and where he never asked the union to take any action on his behalf holding that supervisors libel claims against supervisee and supervisees union representative were preempted by csra because statements giving rise to supervisors claims were made during course of administrative grievance against supervisor holding that a claim based on statements made during a formal grievance procedure was preempted holding that claims based on alleged defamatory statements made during course of grievance were preempted by csra because as union representative subordinate was recommending personnel action against supervisor by filing grievance holding that because plaintiffs were reasonable in interpreting defendants grievance procedure to apply only to active employees plaintiffs did not act in bad faith when they alleged that no applicable grievance procedure existed