Barbara Chafin v. Office of Personnel Management

CourtMerit Systems Protection Board
DecidedJuly 26, 2024
DocketAT-844E-20-0506-I-1
StatusUnpublished

This text of Barbara Chafin v. Office of Personnel Management (Barbara Chafin v. Office of Personnel Management) 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
Barbara Chafin v. Office of Personnel Management, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

BARBARA LEE CHAFIN, DOCKET NUMBER Appellant, AT-844E-20-0506-I-1

v.

OFFICE OF PERSONNEL DATE: July 26, 2024 MANAGEMENT, Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Lawrence Berger , Esquire, Glen Cove, New York, for the appellant.

Linnette Scott , Washington, D.C., for the agency.

BEFORE

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

FINAL ORDER

The appellant has filed a petition for review of the initial decision, which affirmed the reconsideration decision of the Office of Personnel Management (OPM) that denied her application for disability retirement benefits under the Federal Employees’ Retirement System (FERS). On petition for review, 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1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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

appellant argues that the administrative judge erred in affirming OPM’s final decision by relying solely on the appellant’s claim concerning her inability to commute to work and failed to assess whether her epilepsy is incompatible with either useful and efficient service or retention in her former position. Petition for Review (PFR) File, Tab 1 at 4. 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 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 to SUPPLEMENT the administrative judge’s analysis to explain the determination that the appellant failed to show that her medical condition was incompatible with either useful and efficient service or retention in her position, we AFFIRM the initial decision. On review, the appellant argues, in part, that as a result of her medical condition she could not perform the duties of her position. PFR File, Tab 1 at 7-8. The administrative judge was not persuaded, and neither are we. Initial Decision (ID) at 3-5. We supplement the initial decision to provide additional support for this finding. One way that an appellant may meet the statutory requirement that she is unable, because of disease or injury, to render useful and efficient service in her position is by demonstrating that her medical condition is inconsistent with working in general, in a particular line of work, or in a particular type of work 3

setting. 5 U.S.C. § 8451(a)(1)(B); Christopherson v. Office of Personnel Management, 119 M.S.P.R. 635, ¶ 6 (2013). Here, the medical evidence in the record indicated that, after a seizure at work in February 2018, the hospital discharged the appellant the next day in stable condition with no restrictions and further noted that she was alert, oriented, and had good judgment. 2 Initial Appeal File (IAF), Tab 13 at 94-95. Although the appellant provided physician’s notes to support her application for disability, the notes provided her epilepsy diagnosis, requested the agency excuse her from work for follow-up appointments for her seizures, and reflected that she suffered from stress related to her inability to drive, but noted no additional restrictions. Id. at 100, 107. The appellant’s hearing testimony provided little clarity about her medical condition’s functional implications on her ability to do her job, and she only identified the restriction of her inability to commute. IAF, Tab 21, Hearing Audio (testimony of the appellant). Accordingly, after considering all evidence in the record, we discern no basis to disturb the administrative judge’s finding that the appellant failed to show that she suffered from a disabling medical condition that was incompatible with either useful and efficient service or retention in her position. See Christopherson, 119 M.S.P.R. 635, ¶ 6; 5 C.F.R. § 844.103(a)(2). To the extent the appellant raises arguments regarding the remaining criteria for entitlement to disability retirement, such as whether accommodation of her medical condition in

2 On review, the appellant argues that OPM’s contention that her seizure activity has remained stable is incorrect and she has continued to suffer from seizures since her removal. PFR File, Tab 1 at 6-7; IAF, Tab 13 at 9, Tab 16 at 6. However, any worsening of her condition after her separation is not relevant to our determination. Rather, we must restrict our inquiry to whether she became disabled while employed. 5 C.F.R. § 844.103(a)(2); see Wall v. Office of Personnel Management, 116 M.S.P.R. 188, ¶¶ 5, 18 (2010) (finding in a Civil Service Retirement System disability retirement appeal that post-termination medical evidence that did not link the worsening of an appellant’s medical condition to the period prior to his termination did not substantiate the existence of a pre-termination disability), aff’d per curiam, 417 F. App’x 952 (Fed. Cir. 2011). Thus, although we have considered this evidence, we do not find that it changes the outcome in this appeal. IAF, Tab 16 at 10-11. 4

the position held was unreasonable, PFR File, Tab 1 at 7-8; Christopherson, 119 M.S.P.R. 635, ¶ 6, we find it unnecessary to address those arguments.

NOTICE OF APPEAL RIGHTS 3 The initial decision, as supplemented by this Final Order, constitutes the Board’s final decision in this matter. 5 C.F.R. § 1201.113. You may obtain review of this final decision. 5 U.S.C. § 7703(a)(1). By statute, the nature of your claims determines the time limit for seeking such review and the appropriate forum with which to file. 5 U.S.C. § 7703(b). Although we offer the following summary of available appeal rights, the Merit Systems Protection Board does not provide legal advice on which option is most appropriate for your situation and the rights described below do not represent a statement of how courts will rule regarding which cases fall within their jurisdiction.

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Related

Wall v. Office of Personnel Management
417 F. App'x 952 (Federal Circuit, 2011)
Perry v. Merit Systems Protection Bd.
582 U.S. 420 (Supreme Court, 2017)

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