Carlton Castlin v. Department of Veterans Affairs

CourtMerit Systems Protection Board
DecidedMarch 12, 2024
DocketAT-0752-17-0714-I-1
StatusUnpublished

This text of Carlton Castlin v. Department of Veterans Affairs (Carlton Castlin v. Department of Veterans Affairs) 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
Carlton Castlin v. Department of Veterans Affairs, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

CARLTON CASTLIN, DOCKET NUMBER Appellant, AT-0752-17-0714-I-1

v.

DEPARTMENT OF VETERANS DATE: March 12, 2024 AFFAIRS, Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

David A. Harley , Mount Pleasant, South Carolina, for the appellant.

Karen Rodgers , Montgomery, Alabama, for the agency.

Sophia Haynes , Esquire, Decatur, Georgia, for the agency.

BEFORE

Cathy A. Harris, Vice Chairman Raymond A. Limon, Member

FINAL ORDER

The agency has filed a petition for review of the initial decision, which mitigated the appellant’s removal to a 3-day suspension. For the reasons discussed below, we GRANT the agency’s petition for review, AFFIRM the administrative judge’s findings that the agency proved its charge as modified to 1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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

sustain an additional specification, REVERSE the administrative judge’s decision to mitigate the penalty, and SUSTAIN the appellant’s removal.

BACKGROUND The appellant was employed by the agency as an Advanced Medical Support Assistant. Initial Appeal File (IAF), Tab 8 at 12. The agency proposed his removal on June 8, 2017. Id. at 56-57. Effective July 19, 2017, the agency removed him based on one charge of inappropriate conduct supported by four specifications. Id. at 12, 14-17. According to the specifications, while on duty, the appellant called a female coworker a profane epithet (specification A), made critical comments and gestures about other female coworkers’ attire and body parts (specifications B and C), and made sexually explicit comments and gestures to another female coworker (specification D). Id. at 14-15. The appellant filed an appeal of his removal, challenging the sufficiency of the charges and raising affirmative defenses of race, age, sex, and sexual orientation discrimination. 2 IAF, Tab 1 at 3, Tab 19 at 5, Tab 28, Initial Decision (ID) at 15. After holding a hearing, the administrative judge issued an initial decision mitigating the appellant’s removal to a 3-day suspension. ID at 1-2, 13-15. He found that the agency proved specification A, but not the remaining specifications; there was a nexus between the nature of the proven on-duty misconduct and the efficiency of the service; and a 3-day suspension was the maximum penalty warranted under the circumstances. ID at 4-15. He found that 2 In the initial decision, the administrative judge did not consider the appellant’s inchoate equal employment opportunity (EEO) reprisal affirmative defense that he arguably raised in his initial appeal. ID at 15; IAF, Tab 1 at 3. The appellant did not assert that affirmative defense in any of his subsequent pleadings; object to the administrative judge’s status conference summary, which limited the appellant’s affirmative defenses to discrimination based on race, age, sex, and sexual orientation; or file a petition for review or other pleading challenging the initial decision that failed to address this potential affirmative defense. ID at 15; IAF, Tabs 19, 20. Accordingly, we find that, under these circumstances, the appellant waived or abandoned his EEO reprisal affirmative defense. See Thurman v. U.S. Postal Service, 2022) (setting forth a nonexhaustive list of factors for determining whether the appellant waived or abandoned an affirmative defense). 3

the appellant did not prove his affirmative defenses. 3 ID at 15-22. The agency has filed a petition for review. Petition for Review (PFR) File, Tab 1. The agency does not dispute the administrative judge’s finding that it proved the inappropriate conduct charge. ID at 13; see Canada v. Department of Homeland Security, 113 M.S.P.R. 509, ¶ 9 (2010) (observing that a charge of improper conduct has no specific element of proof and is established by proving that the employee committed the acts alleged in support of the broad label). Rather, it asserts that the administrative judge erred in not sustaining specifications B, C, and D and in mitigating the imposed penalty. PFR File, Tab 1 at 4-12. The appellant has not filed a response.

3 The administrative judge’s findings on the affirmative defenses are not challenged by either party on review. We note, however, that subsequent to the administrative judge’s decision, the Supreme Court issued its decision in Bostock v. Clayton County, 590 U.S. 644 (2020). In Bostock, the Court considered whether 42 U.S.C. § 2000e–2(a)(1), the Title VII provision outlawing discrimination by private employers “because of” sex, also prohibits discrimination on the basis of sexual orientation or transgender status. Bostock, 590 U.S. at 649-62. The Court concluded that it does, holding that when an employer takes action against an individual for being homosexual or transgender, “[s]ex plays a necessary and undistinguishable role in the decision, exactly what Title VII forbids.” Id. at 652. Here, although the administrative judge did not have the benefit of the Bostock decision, he nonetheless adjudicated the appellant’s sexual orientation discrimination claim, applying EEOC precedent on the matter. The administrative judge properly assessed whether the appellant proved his sexual orientation claim under a “motivating factor” causation standard. ID at 17. While the private sector provision of Title VII prohibits discrimination “because of” sex, the provision applicable in the context of Federal employment more broadly requires that all personnel actions affecting covered employees “shall be made free from any discrimination based on race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e-16(a); Pridgen v. Office of Management and Budget , 2022 MSPB 31, ¶ 20. We agree with the administrative judge’s finding that the appellant failed to prove this claim. Because there is no challenge on review to the administrative judge’s analysis of this affirmative defense and because it is not obvious that application of Bostock would yield a different result, we decline to readjudicate this issue. See Panter v. Department of the Air Force, 22 M.S.P.R. 281, 282 (1984) (finding that an adjudicatory error that is not prejudicial to a party’s substantive rights provides no basis to reverse an initial decision; 5 C.F.R. § 1201.115 (“The Board normally will consider only issues raised in a timely filed petition or cross petition for review.”). 4

ANALYSIS In an appeal of a removal under 5 U.S.C. chapter 75, the agency bears the burden of proving by preponderant evidence that its action was taken for such cause as would promote the efficiency of the service. 4 MacDonald v. Department of the Navy, 4 M.S.P.R. 403, 404 (1980); 5 C.F.R. § 1201.56(b)(1)(ii). To meet this burden, the agency must prove its charge, establish a nexus between the charge and the efficiency of the service, and demonstrate that the penalty imposed was reasonable. Pope v. U.S.

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Perry v. Merit Systems Protection Bd.
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Carlton Castlin v. Department of Veterans Affairs, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carlton-castlin-v-department-of-veterans-affairs-mspb-2024.