Anne Kelly v. Department of Labor

CourtMerit Systems Protection Board
DecidedJuly 16, 2024
DocketDC-0752-18-0576-I-1
StatusUnpublished

This text of Anne Kelly v. Department of Labor (Anne Kelly v. Department of Labor) is published on Counsel Stack Legal Research, covering Merit Systems Protection Board primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anne Kelly v. Department of Labor, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

ANNE C. KELLY, DOCKET NUMBER Appellant, DC-0752-18-0576-I-1

v.

DEPARTMENT OF LABOR, DATE: July 16, 2024 Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Anne C. Kelly , Ellicott City, Maryland, pro se.

Rolando N. Valdez , Esquire, Washington, D.C., for the agency.

BEFORE

Cathy A. Harris, Chairman Raymond A. Limon, Vice Chairman Henry J. Kerner, Member

FINAL ORDER

¶1 The appellant has filed a petition for review of the initial decision, which sustained her removal. Generally, we grant petitions such as this one only in the following circumstances: the initial decision contains erroneous findings of material fact; the initial decision is based on an erroneous interpretation of statute or regulation or the erroneous application of the law to the facts of the case; the

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions. In contrast, a precedential decision issued as an Opinion and Order has been identified by the Board as significantly contributing to the Board’s case law. See 5 C.F.R. § 1201.117(c). 2

administrative judge’s rulings during either the course of the appeal or the initial decision were not consistent with required procedures or involved an abuse of discretion, and the resulting error affected the outcome of the case; or new and material evidence or legal argument is available that, despite the petitioner’s due diligence, was not available when the record closed. Title 5 of the Code of Federal Regulations, section 1201.115 (5 C.F.R. § 1201.115). After fully considering the filings in this appeal, we conclude that the petitioner has not established any basis under section 1201.115 for granting the petition for review. Therefore, we DENY the petition for review. Except as expressly MODIFIED to provide additional support for the administrative judge’s findings on the appellant’s disability discrimination and equal employment opportunity (EEO) retaliation claims, we AFFIRM the initial decision.

BACKGROUND ¶2 The agency removed the appellant from her Information Technology Specialist position based on the following charges: (1) Providing Inaccurate Information on Your Timecards (27 specifications); (2) Inappropriate Behavior (7 specifications); and (3) Failure to Follow Supervisory Instructions (24 specifications). Initial Appeal File (IAF), Tab 1 at 175-82, Tab 10 at 7, Tab 12 at 15-30. The agency based the Inappropriate Behavior charge on the content of several emails the appellant sent to her supervisor and the Failure to Follow Supervisory Instructions charge on her failure to complete an assignment by a deadline date and failure to send email messages to the division’s staff indicating when she ended her work day while telecommuting. IAF, Tab 12 at 15, 20-24. ¶3 On appeal, the appellant challenged the action and asserted disability discrimination based on disparate treatment, disparate impact, and a failure to reasonably accommodate her disability, sex discrimination based on a hostile work environment, retaliation for EEO activity, whistleblower reprisal, a due process violation, harmful error, and violations of the Family and Medical Leave 3

Act of 1993 (FMLA) and the Telework Enhancement Act. IAF, Tab 16, Tab 22 at 6, 23, Tab 35. ¶4 Based on the written record because the appellant withdrew her request for a hearing, IAF, Tabs 34-35, the administrative judge sustained the removal action, IAF, Tab 44, Initial Decision (ID) at 1, 64. The administrative judge found that the agency proved 26 of the 27 specifications supporting the charge of Providing Inaccurate Information on Your Timecards, all 7 of the specifications supporting the charge of Inappropriate Behavior, and all 24 of the specifications supporting the charge of Failure to Follow Supervisory Instructions. ID at 11-34. The administrative judge further found that the appellant did not prove disability or sex discrimination, retaliation for EEO activity, reprisal for whistleblowing, a violation of due process, harmful error, or a violation of the FMLA or the Telework Enhancement Act. ID at 34-60. Finally, the administrative judge found that the agency proved a nexus between the misconduct and the efficiency of the service and that the penalty of removal was reasonable. ID at 60-64.

ANALYSIS ¶5 The appellant’s petition for review focuses on whether the agency discriminated against her by failing to accommodate her disability, discriminated against her based on sex, retaliated against her for engaging in EEO activity, and violated the FMLA and Telework Enhancement Act. Petition for Review (PFR) File, Tab 1 at 5-17. The appellant also challenges the reasonableness of the penalty. Id. at 17-20. Accordingly, we address these allegations. 2 We affirm all of the administrative judge’s findings, modifying her analysis as to the appellant’s disability discrimination and EEO retaliation claims.

2 We decline to disturb the administrative judge’s findings that the agency proved its charges and a nexus between the charges and the efficiency of the service, and that the appellant did not prove reprisal for whistleblowing, harmful error, or a due process violation. The appellant does not dispute these findings on review. See 5 C.F.R. § 1201.115 (providing that the Board will consider only issues raised in a timely filed petition or cross petition for review). 4

The appellant has not proven disability discrimination . ¶6 The administrative judge found that, although the appellant was disabled due to her depression and bipolar disorder, she did not assert that the agency denied her a reasonable accommodation, but instead alleged that her requested accommodation of telework was effectively denied because it was delayed by 2½ months. 3 ID at 36, 39-42. The administrative judge held that any delay was not unnecessary or unreasonable because the agency was entitled to request supporting medical documentation for the appellant’s conditions, which were not obvious, the agency worked to evaluate the request in an expeditious manner after she submitted medical documentation, and the agency was entitled to obtain signed and dated medical documentation from a medical provider. ID at 38-43. 4 ¶7 The appellant challenges the administrative judge’s finding that the delay was reasonable in part because the agency purportedly sought an independent medical review after the appellant submitted medical documentation on January 23, 2017. PFR File, Tab 1 at 5-6. The appellant contends that she did not submit medical documentation on that date and an independent medical review did not occur at that time. Id. The appellant asserts that the only communication she had with the agency on January 23, 2017, involved her representative informing the agency that the information it sought had already 3 The administrative judge did not address whether the appellant was a qualified individual with a disability. ID at 38-43; see Haas v. Department of Homeland Security, 2022MSPB 36, ¶¶ 28-29. 4 The administrative judge acknowledged that the agency could have provided an interim accommodation, but states that “doing so was complicated by the appellant’s recent telework revocation, which was effective on November 29, 2016.” ID at 41.

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Anne Kelly v. Department of Labor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anne-kelly-v-department-of-labor-mspb-2024.