Davette Buchanan v. Department of Veterans Affairs

CourtMerit Systems Protection Board
DecidedAugust 3, 2022
DocketDC-1221-21-0390-W-1
StatusUnpublished

This text of Davette Buchanan v. Department of Veterans Affairs (Davette Buchanan 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
Davette Buchanan v. Department of Veterans Affairs, (Miss. 2022).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

DAVETTE G. BUCHANAN, DOCKET NUMBER Appellant, DC-1221-21-0390-W-1

v.

DEPARTMENT OF VETERANS DATE: August 3, 2022 AFFAIRS, Agency.

THIS ORDER IS NONPRECEDENTIAL 1

Davette G. Buchanan, Black Mountain, North Carolina, pro se.

Erin Brady Rega, Winston Salem, North Carolina, for the agency.

BEFORE

Cathy A. Harris, Vice Chairman Raymond A. Limon, Member Tristan L. Leavitt, Member

REMAND ORDER

¶1 The appellant has filed a petition for review of the initial decision, which dismissed her individual right of action (IRA) appeal for lack of jurisdiction. For the reasons discussed below, we GRANT the appellant’s petition for review,

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

VACATE the initial decision, and REMAND the case to the Washington Regional Office for further adjudication in accordance with this Remand Order.

BACKGROUND ¶2 The appellant is a GS-7 Medical Instrument Technician at the Charles George Veterans Affairs (VA) Medical Center in Asheville, North Carolina. Initial Appeal File (IAF), Tab 1 at 1. She filed an IRA appeal with the Board and requested a hearing. Id. at 1. In her initial filing, she alleged that she was stabbed with a used hypodermic needle by a VA nurse in January 2018, the agency and the VA police failed to conduct a proper investigation of the incident, and agency employees mocked her and told her to get over it. Id. at 2. The administrative judge issued two show cause orders , which notified the appellant that the Board might not have jurisdiction over her appeal, informed her of her jurisdictional burden, and directed her to file evidence and argument on the issue. IAF, Tabs 3, 9. ¶3 After the record on jurisdiction closed, the administrative judge is sued an initial decision dismissing the appeal for lack of jurisdiction without holding the appellant’s requested hearing. IAF, Tab 1 at 1, Tab 15, Initial Decision (ID) at 1, 19. She determined that the appellant had exhausted with the Office of Special Counsel (OSC) her claims that she made protected disclosures when she reported the needle-stick incident and an alleged threat of gun violence by the same nurse colleague who stabbed her with the used needle and that she engaged in protected activity when she complained to the Office of the Inspector General (OIG) about the needle-stick incident. ID at 7-8. The administrative judge also concluded that the appellant had nonfrivolously alleged that she made disclosures that a reasonable person in her position would believe evidenced a violation of law in connection with these two events. ID at 9-10. Specifically, she found the appellant’s allegation that a nurse intentionally stuck her with a needle disclosed an assault and the appellant’s allegation that a nurse threatened her with gun 3

violence disclosed a misdemeanor threat under North Carolina statute, N.C. Gen. Stat. § 14-277.1. ID at 9-10; 5 U.S.C. § 2302(b)(8)(A)(i). Additionally, she determined that the appellant had nonfrivolously alleged that she engaged in protected activity when she filed a complaint with the OIG for the Department of Health and Human Services (DHHS). ID at 10-11. In that complaint, the appellant raised concerns about the agency’s response to the needle-stick disclosure, arguing that the police investigation into the incident was inadequate and that the agency endangered her safety by allowing the nurse who assaulted her to remain employed with the agency. IAF, Tab 12 at 6-9. ¶4 Regarding the purported personnel actions, the administrative judge concluded that the appellant exhausted with OSC the following allegations: (1) she had been subjected to a hostile work environment, (2) her duties and working conditions were changed, and (3) she had been denied a promised raise or promotion. ID at 8, 15. Nevertheless, she determined that the appellant failed to nonfrivolously allege facts sufficient to establish that any of these incidents amounted to a personnel action. ID at 11-16. She also concluded that the appellant neither exhausted her claim that she had been subjected to a negative suitability determination nor nonfrivolously alleged she was subjected to such a determination. ID at 8 & n.3. She found that the appellant, therefore, failed to establish jurisdiction over her appeal. ¶5 Alternatively, the administrative judge determined that even assuming the appellant made a nonfrivolous allegation that she was subjected to personnel actions in connection with these claims, she failed to nonfrivolously allege that her protected disclosures or activities were a contributing factor in the agency ’s decision to take or not take these alleged actions, based on either the knowledge/timing test or other evidence. ID at 16-18. Specifically, she found that the appellant’s pleadings did not provide sufficient details concerning who took the alleged actions against her and whether any such individuals were aware of her disclosures or activities. ID at 16-17. Consequently, she concluded that, 4

despite being provided two opportunities to do so, the appellant “failed to identify any specific acting agency official or officials, what personnel actions they took, failed to take or threatened to take and why the y did so,” and so, she failed to establish that any of the appellant’s disclosures or activities were a contributing factor in any of the challenged personnel actions. ID at 17-18. ¶6 The appellant has filed a petition for review and a supplement to her petition for review. Petition for Review (PFR) File, Tabs 1-2. The agency has filed a response in opposition to the petition for review. PFR File, Tab 4. The appellant has not filed a reply.

DISCUSSION OF ARGUMENTS ON REVIEW ¶7 On review, the appellant argues that she would be able to establish her claims if she were permitted a hearing and the ability to call witnesses and reargues that the agency’s investigation into the needle-stick incident was insufficient and flawed. PFR File, Tab 1 at 3-7. Additionally, she asserts that she has newly discovered evidence in the form of emails from a former agency employee showing that he contacted agency administrators and supervisors several times on her behalf and told them about the hostile actions being taken against the appellant, and she provides copies of those emails in her supplemental petition for review. PFR File, Tab 1 at 3-4, Tab 2 at 2-8. The appellant also has included an additional narrative statement setting forth a timeline of events starting with the January 2018 needle-stick incident and the subsequent investigation and running through June 2020, when she purportedly was denied a title change and a corresponding pay increase. PFR File, Tab 2 at 9-12. In this pleading, she also asserts that she was subjected to a negative suitability determination when she was stabbed by the agency employee with the used syringe. Id. at 9. 5

The administrative judge properly determined that the appellant nonfrivolously alleged she made protected disclosures and engaged in protected activity and that she exhausted those claims with OSC.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Burlington Industries, Inc. v. Ellerth
524 U.S. 742 (Supreme Court, 1998)
Stoglin v. Merit Systems Protection Board
640 F. App'x 864 (Federal Circuit, 2016)
Kerrigan v. Merit System Protection Board
833 F.3d 1349 (Federal Circuit, 2016)
El v. Merit Systems Protection Board
663 F. App'x 921 (Federal Circuit, 2016)
Timothy Skarada v. Department of Veterans Affairs
2022 MSPB 17 (Merit Systems Protection Board, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
Davette Buchanan v. Department of Veterans Affairs, Counsel Stack Legal Research, https://law.counselstack.com/opinion/davette-buchanan-v-department-of-veterans-affairs-mspb-2022.