Deborah Khan v. Department of Justice

CourtMerit Systems Protection Board
DecidedJanuary 9, 2026
DocketDC-0432-21-0205-I-4
StatusUnpublished

This text of Deborah Khan v. Department of Justice (Deborah Khan v. Department of Justice) 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
Deborah Khan v. Department of Justice, (Miss. 2026).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

DEBORAH VERONICA KHAN, DOCKET NUMBER Appellant, DC-0432-21-0205-I-4

v.

DEPARTMENT OF JUSTICE, DATE: January 9, 2026 Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Christopher H. Bonk , Esquire, and James A. Hill , Esquire, Silver Spring, Maryland, for the appellant.

Asmaa Abdul-Haqq , Esquire, and Anna Wang , Esquire, Washington, D.C., for the agency.

BEFORE

Henry J. Kerner, Vice Chairman James J. Woodruff II, Member

FINAL ORDER

The appellant has filed a petition for review of the initial decision, which sustained her chapter 43 removal. 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

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

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 as expressly MODIFIED to find that the agency’s performance standards as communicated to the appellant before the initiation of her Performance Improvement Plan (PIP) were valid, we AFFIRM the initial decision.

BACKGROUND The appellant began her employment with the agency in 2000 and last held the position of Information Technology Specialist, a GS-14 position, in the agency’s Antitrust Division in Washington, D.C. Khan v. Department of Justice, MSPB Docket No. DC-0432-21-0205-I-4, Appeal File (I-4 AF), Tab 21 at 3, Stipulations 1-2. In October 2019, the agency issued the appellant her Fiscal Year (FY) 2020 Performance Work Plan (PWP), which identified six critical performance elements and described performance of those elements at the “successful” level. I-4 AF, Tab 5 at 508-14, Tab 21 at 3-4, Stipulations 6-9. The PWP identified five rating levels and defined each of the five rating levels based on the quality, quantity, manner, and/or timeliness of the performance. I-4 AF, Tab 5 at 508-09. The PWP stated that, if any critical element was rated “unacceptable,” then the overall rating must be “unacceptable.” Id. at 509. By notice dated May 26, 2020, the agency informed the appellant that her performance was “unacceptable” in three critical performance elements—Job 3

Element (JE) 1, JE 3, and JE 5—and placed the appellant on a PIP for a period of 60 calendar days. I-4 AF, Tab 5 at 410-21, Tab 21 at 4, Stipulations 15, 18. The agency later extended the appellant’s PIP through August 12, 2020, for a total PIP period of 79 calendar days. I-4 AF, Tab 5 at 236-37, 107, Tab 21 at 4, Stipulations 16-17. During the PIP, the appellant’s first- and second-level supervisors met with the appellant weekly to discuss her performance and provided her with notes from the meetings. I-4 AF, Tab 5 at 243-367, Tab 21 at 5, Stipulations 24-26. The agency ultimately rated the appellant’s FY 2020 performance “unacceptable” in critical performance element JE 1 and, therefore, rated her overall FY 2020 performance as “unacceptable.” I-4 AF, Tab 19 at 15-17, Tab 21 at 6, Stipulations 28-29. On November 6, 2020, the appellant’s first-level supervisor proposed her removal based on unacceptable performance. I-4 AF, Tab 5 at 107-26. The appellant, through her legal representative, provided a written response to the proposal letter. Id. at 46-105. On December 30, 2020, her second-level supervisor issued a decision affirming her removal, effective that day. Id. at 31-44. The appellant timely filed an appeal of her removal with the Board. Khan v. Department of Justice, MSPB Docket No. DC-0432-21-0205-I-1, Initial Appeal File (IAF), Tab 1. Her appeal was dismissed without prejudice three times due to potential Appointments Clause issues. I-4 AF, Tab 21 at 11-12, Stipulations 66-68. The instant appeal was refiled by the Board at the appellant’s request. I-4 AF, Tabs 1-2. In addition to challenging her performance-based removal, the appellant raised affirmative defenses of retaliation for protected whistleblower activity and a violation of her due process right to a timely, post-deprivation hearing. IAF, Tab 1 at 6; I-4 AF, Tab 15 at 4-15. She withdrew her claim of whistleblower retaliation during the prehearing conference. I-4 AF, Tab 21 at 2, 12. After holding the appellant’s requested hearing, the administrative judge issued an initial decision affirming the agency’s chapter 43 4

removal action and finding that the appellant failed to prove her affirmative defense of a due process violation. I-4 AF, Tab 25, Initial Decision (ID). The appellant has filed a petition for review challenging the administrative judge’s findings affirming her removal. PFR (Petition for Review) File, Tab 3 at 7-23. She does not reraise any affirmative defenses. Id. The agency has responded in opposition to the appellant’s petition for review, PFR File, Tab 7, and the appellant has replied to the agency’s response, PFR File, Tab 8.

DISCUSSION OF ARGUMENTS ON REVIEW Since the U.S. Court of Appeals for the Federal Circuit issued its decision in Santos v. National Aeronautics and Space Administration , 990 F.3d 1355, 1360-61 (Fed. Cir. 2021), the Board has required the agency to defend an action under chapter 43 by proving the following by substantial evidence: (1) the Office of Personnel Management (OPM) approved its performance appraisal system and any significant changes thereto; (2) the agency communicated to the appellant the performance standards and critical elements of her position; (3) the appellant’s performance standards are valid under 5 U.S.C. § 4302(c)(1); (4) the appellant’s performance during the appraisal period was unacceptable in one or more critical elements; (5) the agency warned the appellant of the inadequacies in her performance during the appraisal period and gave her an adequate opportunity to demonstrate acceptable performance; and (6) after an adequate improvement period, the appellant’s performance remained unacceptable in at least one critical element. See Lee v. Department of Veterans Affairs, 2022 MSPB 11, ¶ 15. The appellant has not disputed that the agency’s appraisal system was approved by OPM, I-4 AF, Tab 21 at 6, Stipulation 36; I-4 AF, Tab 5 at 523-25, but she argues that the agency failed to prove the remaining elements, I-4 AF, Tab 19; PFR File, Tab 3.

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

Related

John Depauw v. U.S. International Trade Commission
782 F.2d 1564 (Federal Circuit, 1986)
George E. Eibel v. Department of the Navy
857 F.2d 1439 (Federal Circuit, 1988)
Van Prichard v. Department of Defense
484 F. App'x 489 (Federal Circuit, 2012)
Perry v. Merit Systems Protection Bd.
582 U.S. 420 (Supreme Court, 2017)
Kelly Lee v. Department of Veterans Affairs
2022 MSPB 11 (Merit Systems Protection Board, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
Deborah Khan v. Department of Justice, Counsel Stack Legal Research, https://law.counselstack.com/opinion/deborah-khan-v-department-of-justice-mspb-2026.