Christa Nyamekye v. Department of Commerce

CourtMerit Systems Protection Board
DecidedApril 19, 2024
DocketDC-0752-20-0388-I-2
StatusUnpublished

This text of Christa Nyamekye v. Department of Commerce (Christa Nyamekye v. Department of Commerce) 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
Christa Nyamekye v. Department of Commerce, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

CHRISTA NYAMEKYE, DOCKET NUMBER Appellant, DC-0752-20-0388-I-2

v.

DEPARTMENT OF COMMERCE, DATE: April 19, 2024 Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

James A. Hill , Esquire, and Michael L. Spekter , Esquire, Silver Spring, Maryland, for the appellant.

Chieko M. Clarke and Michael Gridley , Alexandria, Virginia, for the agency.

BEFORE

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

FINAL ORDER

The appellant has filed a petition for review of the initial decision, which affirmed her removal for absence without leave (AWOL). 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

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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

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 appellant 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 address the appellant’s due process argument, we AFFIRM the initial decision.

BACKGROUND The appellant was a GS-12 Accountant for the agency’s Patent and Trademark Office. Nyamekye v. Department of Commerce, MSPB Docket No. DC-0752-20-0388-I-1, Initial Appeal File (IAF), Tab 8 at 30. On November 26, 2019, the agency proposed her removal based on 44 hours of AWOL between July 22 and August 30, 2019. Id. at 70-76. Specifically, the agency alleged that, on 18 different days, the appellant was absent from work, without authorization, for various periods of time totaling 44 hours. 2 Id. at 70-71. The agency further alleged that the appellant had not requested leave for her absences, had claimed these hours as time worked, and had been paid accordingly. Id. at 70. The appellant responded to the proposed removal, and on January 15, 2020, the deciding official issued a decision sustaining the charge and removing the appellant effective January 24, 2020. Id. at 36-41, 43-68.

2 The 18 specifications of AWOL are misnumbered in the notice of proposed removal. IAF, Tab 8 at 70-71. However, there is no indication that this misnumbering caused the appellant any confusion such that she was unable to understand the precise nature of the agency’s allegations. 3

The appellant filed a Board appeal, contesting the merits of the agency’s action and raising affirmative defenses of race and sex discrimination. 3 IAF, Tab 1 at 4-6; Nyamekye v. Department of Commerce, MSPB Docket No. DC-0752-20-0388-I-2, Appeal File (I-2 AF), Tab 5, Tab 14 at 8-13, Tab 17 at 5-6. After a hearing, the administrative judge issued an initial decision affirming the appellant’s removal. I-2 AF, Tab 25, Initial Decision (ID). She found that the agency proved its charge and that the appellant failed to prove her affirmative defenses. ID at 3-37. The administrative judge also found that the penalty was within the tolerable limits of reasonableness. ID at 37-42. The appellant has filed a petition for review, arguing that the agency violated her right to due process, that the administrative judge erred in analyzing her discrimination claims, and that the removal penalty is inconsistent with the penalties imposed on other employees for similar offenses. Petition for Review (PFR) File, Tab 3. The agency has filed a response. PFR File, Tab 5.

ANALYSIS The agency proved its AWOL charge. To prove an absence without leave charge, an agency must show that the employee was absent from duty, and either that her absence was unauthorized or that her request for leave was properly denied. Boscoe v. Department of Agriculture, 54 M.S.P.R. 315, 325 (1992). In this case, the administrative judge considered each of the 18 specifications of AWOL and found that the appellant was absent from duty during various periods of time during which she was supposed to have been at work, for a total of 44 hours as the agency alleged. ID at 15-28. Accordingly, the administrative judge sustained each of the 3 The appellant initially alleged discrimination based on age, but we find that she has abandoned that claim. IAF, Tab 1 at 6; see Thurman v. U.S. Postal Service, 2022 MSPB 21, ¶¶ 17-28. The appellant’s only allegation of age discrimination was a pro forma assertion in her initial filing, she was represented by an attorney throughout these proceedings, and she did not object when age discrimination was not included as an issue in the administrative judge’s prehearing conference summary. IAF, Tab 1 at 6; I-2 AF, Tab 17. Nor has the appellant raised the issue on petition for review. 4

18 specifications and the charge as a whole. Id. The administrative judge’s findings are well-reasoned and supported by the record, and the appellant does not contest them on review. See 5 C.F.R. § 1201.115 (“The Board normally will consider only issues raised in a timely filed petition or cross petition for review.”).

The appellant has not shown that the agency denied her due process. On petition for review, the appellant argues that the agency denied her right to due process because the deciding official based his penalty determination partly on information that was not contained in the notice of proposed removal. PFR File, Tab 3 at 9-15. Specifically, in her response to the notice of proposed removal, the appellant stated that she sometimes worked more hours than she actually reported. IAF, Tab 8 at 47-49. Far from allaying his concerns about the appellant’s behavior, the deciding official believed that her failure to record work time represented further disregard for the agency’s time and attendance policies, and he considered this evidence in arriving at his decision. Hearing Transcript, Day 1 (Tr. 1) at 212-15, 235-37 (testimony of the deciding official). As a threshold matter, we acknowledge that the appellant did not raise this affirmative defense in time for it to be included as an issue in the administrative judge’s prehearing conference summary. Nevertheless, during the course of the hearing, the deciding official gave information which had not been adduced in discovery and which the appellant’s representative interpreted as evidence of a due process violation. PFR File, Tab 3 at 5-6; Hearing Transcript, Day 2 (Tr. 2) at 126 (appellant’s closing argument). The appellant’s representative raised the issue before the close of the record below, during his closing argument. Tr. 2 at 126-27 (appellant’s closing argument).

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Christa Nyamekye v. Department of Commerce, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christa-nyamekye-v-department-of-commerce-mspb-2024.