Cunningham v. Opm

Court of Appeals for the Federal Circuit·Decided July 15, 2025·No. 25-1036·Unpublished

Opinion

NOTE: This disposition is nonprecedential.

United States Court of Appeals for the Federal Circuit

FELICIA CUNNINGHAM,

Petitioner

v.

OFFICE OF PERSONNEL MANAGEMENT, Respondent

2025-1036

Petition for review of the Merit Systems Protection Board in No. AT-844E-20-0572-I-1.

Decided: July 15, 2025

FELICIA CUNNINGHAM, Oxford, AL, pro se.

BLAKE WILLIAM COWMAN, Commercial Litigation Branch, Civil Division, United States Department of Justice , Washington, DC, for respondent. Also represented by TARA K. HOGAN, PATRICIA M. MCCARTHY, YAAKOV ROTH.

2 CUNNINGHAM v. OPM

Before MOORE, Chief Judge, STOLL, Circuit Judge, and WANG, District Judge. 1

PER CURIAM.

Felicia Cunningham seeks review of a final decision of the Merit Systems Protection Board, which affirmed the Office of Personnel Management’s determination that she did not meet the legal requirements for disability retirement . For the following reasons, we affirm.

BACKGROUND

I

Ms. Cunningham worked for the Department of Veterans Affairs as a Veterans Service Representative (VSR) from June 2015 until June 2019, when she resigned. In 2019 prior to her resignation, Ms. Cunningham applied for disability retirement under the Federal Employees’ Retirement System (FERS).

In Ms. Cunningham’s statement of disability, which she filed shortly before her resignation, she identified “migraine headaches and anxiety” as her disabling conditions. SAppx22. 2 Ms. Cunningham explained that “[her daily] tension migraine headaches” resulted from “the demands of [her VSR] position” and “[t]he stress of the VSR position has aggravated [her] headaches and [she] cannot perform [her] duties any longer.” Id. She also noted her “depr[e]ssive disorder [wa]s . . . aggravated by the demands of” her position. Id.

1 Honorable Nina Y. Wang, District Judge, United States District Court for the District of Colorado, sitting by designation.

2 “SAppx” refers to the Supplemental Appendix submitted by Respondent at ECF No. 25.

CUNNINGHAM v. OPM 3

On December 9, 2019, the Office of Personnel Management (OPM) denied Ms. Cunningham’s application, “finding that she did not meet the legal requirements for disability retirement.” SAppx2. Ms. Cunningham sought reconsideration, and OPM issued a final decision affirming its initial decision. Ms. Cunningham appealed OPM’s decision to the Merit Systems Protection Board.

II

The administrative judge affirmed OPM’s determination that Ms. Cunningham’s documentation “was insufficient to establish entitlement to disability retirement.” SAppx7–8. The administrative judge started his analysis by noting that Ms. Cunningham could establish eligibility for disability retirement by either “(1) . . . showing that the medical condition from which she suffers caused a deficiency in performance, attendance, or conduct; or (2) . . . showing that the medical condition is incompatible with useful and efficient service or retention in her position .” SAppx3 (citing 5 C.F.R. § 831.1203(a)(2)).

First, addressing performance or conduct deficiencies, the administrative judge acknowledged Ms. Cunningham’s manager indicated that her “performance and conduct were satisfactory” and that Ms. Cunningham “produced no persuasive evidence or argument to contradict her supervisor ’s conclusions.” SAppx8. The administrative judge also explained that, although Ms. Cunningham’s “medical conditions may . . . have impacted her performance and conduct (e.g., her attendance) to some degree, there is simply no record evidence that [her performance and conduct] descended below a fully successful level.” Id.

Second, addressing useful and efficient service, the administrative judge explained that Ms. Cunningham’s medical documentation did not state “that she was . . . unable to perform useful and efficient service. Nor d[id] the medical documentation explain how any medical conditions affected her specific work requirements as a VSR.” Id. The 4 CUNNINGHAM v. OPM

administrative judge also considered Ms. Cunningham’s hearing testimony, noting she “identified no specific work requirements that her condition prevented her from fulfilling ” and that the subjective evidence that she was “unable to fulfill specific job requirements is unsupported by competent medical evidence to that effect.” SAppx8–9. In sum, the administrative judge found that “none of [Ms. Cunningham’s] medical documentation . . . indicates any sort of work restriction.” SAppx9.

In evaluating the medical evidence, the administrative judge recognized “that the medical evidence reflects, at best, inconsistent use of prescribed medications by” Ms. Cunningham. Id. The administrative judge determined that Ms. Cunningham’s treatment notes from 2017 and 2018 “show[ed] that [she] was quite late in beginning her Floricet prescription for migraines, and that she used it only occasionally thereafter,” and her 2019 treatment notes “stated [Ms. Cunningham] had not yet started taking amitriptyline and Maxalt” and that she “dropped Topomax because it made her feel funny.” Id. (internal quotation marks omitted). The administrative judge was “not persuaded [Ms. Cunningham] followed her doctors’ directions closely enough to warrant an award of disability retirement benefits.” SAppx10.

The administrative judge also considered that Ms. Cunningham “was granted Department of Veterans Affairs (DVA) disability benefits (70%) in August 2019” but explained that given the lack of “other record evidence meeting the applicable criteria[] . . . the DVA’s decision to grant benefits to [Ms. Cunningham] is insufficient to establish that she is entitled to disability retirement under FERS.” Id.

Finally, the administrative judge considered Ms. Cunningham ’s claims of “missed work due to her medical conditions ” but explained “there is no evidence of record quantifying her absences” and “her supervisor did not

CUNNINGHAM v. OPM 5

report an attendance problem.” Id. The administrative judge concluded “whatever work absences the appellant may have experienced do not overcome the lack of record evidence concerning the effect of her medical condition on her specific job duties.” Id. After analyzing the record and Ms. Cunningham’s arguments, the administrative judge concluded Ms. Cunningham did not demonstrate “by preponderant evidence . . . [that] her medical condition(s) [were] incompatible with useful and efficient service or retention in her position.” SAppx11.

Ms. Cunningham petitioned for review of the administrative judge’s initial decision. In her petition she contended that “[d]ue process was ignored” because OPM filed the agency record two days late and “[OPM’s] response should have been objected [to] by [the administrative judge].” SAppx41. She also indicated that she had “documents or evidence . . . important to [her] appeal that were not filed with the judge before the record closed,” but she failed to attach the documents and evidence as instructed. Id. Ms. Cunningham also indicated that her “mental issues ” were relevant and the administrative judge overlooked her primary doctor’s medical opinion. Id.

III

The Board denied Ms. Cunningham’s petition and affirmed the initial decision. The administrative judge’s initial decision thus became the Board’s final decision pursuant to 5 C.F.R. § 1201.113(b).

The Board first addressed Ms. Cunningham’s mental disabilities including depression and anxiety caused by migraine headaches. SAppx26. The Board “considered whether the record evidence would support a finding that [Ms. Cunningham] was disabled” because of her mental disabilities, but explained “the mere diagnosis of depression or an anxiety disorder [without more] is not informative enough to allow either OPM or the Board to 6 CUNNINGHAM v. OPM

conclude . . . that an employee is disabled from useful and efficient service.” Id.

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