Denise Davis v. Department of Defense

CourtMerit Systems Protection Board
DecidedJune 9, 2026
DocketDC-0752-25-0273-I-1
StatusPublished

This text of Denise Davis v. Department of Defense (Denise Davis v. Department of Defense) 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
Denise Davis v. Department of Defense, (Miss. 2026).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD 2026 MSPB 5 Docket No. DC-0752-25-0273-I-1

Denise Davis, Appellant, v. Department of Defense, Agency. June 9, 2026

Laura A. O’Reilly , Esquire, Virginia Beach, Virginia, for the appellant.

Samuel Lazzaro and Emily Cook , Esquire, Fort Meade, Maryland, for the agency.

BEFORE

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

OPINION AND ORDER

¶1 The agency petitions for review of the initial decision, which reversed its action terminating the appellant from her position. For the following reasons, we DENY the appellant’s motion to dismiss the agency’s petition for review for failure to provide interim relief and DENY the agency’s petition for review. We AFFIRM the initial decision AS MODIFIED by this Opinion and Order, providing additional analysis in support of the initial decision and still reversing the agency’s action. This Opinion and Order addresses the novel question of whether a preference eligible in the U.S. Cyber Command has Board appeal rights despite not having completed the statutorily required 3-year probationary period. 2

BACKGROUND ¶2 The agency appointed the appellant, a preference eligible, to a GG-2210-12 IT Cybersecurity Specialist position in the excepted service with the Defense Information Systems Agency (DISA) pursuant to 10 U.S.C. § 1599f, effective October 11, 2021. Initial Appeal File (IAF), Tab 5 at 27. The appointment was subject to the completion of a 3-year initial probationary period. Id. On August 26, 2024, approximately 34 months later, the agency terminated the appellant during her probationary or trial period. Id. at 13-16. The agency did not afford the appellant an opportunity to respond to the termination notice before its effective date. IAF, Tab 5 at 14-16, Tab 14, Initial Decision (ID) at 3. ¶3 The appellant filed a Board appeal on January 9, 2025, arguing that she was an “employee” under 5 U.S.C. § 7511(a)(1)(B), regardless of her 3-year probationary period, and that the agency erred by removing her without providing her with an opportunity to respond to the termination notice and with notice of her adverse action appeal rights. IAF, Tab 1 at 1, Tab 13 at 4-12. The agency moved to dismiss the appeal for lack of jurisdiction and as untimely filed with no showing of good cause for the delay. IAF, Tab 5 at 8-10, Tab 12 at 6-15. ¶4 Based on the written record, the administrative judge issued an initial decision finding good cause for the filing delay because the agency did not notify the appellant of her Board appeal rights when it was required to do so. ID at 1, 3. He also held that the appellant was an employee under 5 U.S.C. § 7511(a)(1)(B) and Congress did not exclude such employees from coverage at 5 U.S.C. § 7511(b). ID at 2-3. He therefore ordered the agency to cancel her termination and retroactively restore her effective August 26, 2024, because the agency did not provide the procedural protections afforded by 5 U.S.C. § 7513. ID at 3-4. The administrative judge ordered the agency to provide interim relief if either party filed a petition for review. ID at 5. ¶5 The agency has timely petitioned for review. Petition for Review (PFR) File, Tab 1. The appellant has submitted a timely response, which includes a 3

motion to dismiss the agency’s petition for review for failure to provide interim relief. PFR File, Tab 3. The agency has timely replied. PFR File, Tab 4.

ANALYSIS

The agency complied with the administrative judge’s interim relief order. ¶6 If an appellant was the prevailing party in the initial decision, and the initial decision granted the appellant interim relief under 5 U.S.C. § 7701(b)(2)(A), an agency’s petition for review must be accompanied by a certification that the agency has complied with the interim relief order. Starkey v. Department of Housing and Urban Development, 2024 MSPB 6, ¶ 12; 5 C.F.R. § 1201.116(a). In its petition for review, the agency asserts that it complied with the interim relief order. PFR File, Tab 1 at 6-7, 16-19. ¶7 If the agency files a petition for review and the appellant believes the agency has not provided the required interim relief, she may request dismissal of the agency’s petition. 5 C.F.R. § 1201.116(c). The Board may dismiss an agency’s petition for review if it finds the agency to be in noncompliance with its interim relief obligations. Smith v. Department of the Army, 2022 MSPB 4, ¶ 12. In her motion to dismiss the agency’s petition for review, the appellant asserts that the agency has not complied with the interim relief order because the agency sent her home from work and did not provide full pay. PFR File, Tab 3 at 4. Specifically, she states that the agency incorrectly charged her for 6 hours of annual leave and 10 hours of leave without pay (LWOP) without explanation. Id. at 4, 16. ¶8 In sworn statements included with its reply brief, the agency acknowledges the error regarding the contested annual leave and LWOP. PFR File, Tab 4 at 25. The agency maintains that the error has been corrected and would be reflected in the appellant’s next leave and earnings statement. Id. As for the appellant’s duty status, the agency explains that her position and all others within DISA require a security clearance. Id. at 22. However, the appellant’s security clearance was declared as a “loss of jurisdiction” on October 11, 2024, and must be 4

readjudicated favorably for her to regain access. Id. In the meantime, the agency placed the appellant on administrative leave. Id. at 24. ¶9 The U.S. Supreme Court has held that the Board does not have the authority to review the substance of a security clearance determination. Department of the Navy v. Egan, 484 U.S. 518, 530-31 (1988). Because the agency has acknowledged and corrected its leave error, has provided evidence that the appellant has been placed on paid administrative leave since the date of the initial decision as a result of a security clearance-related undue disruption determination, PFR File, Tab 4 at 10-11, 24; see 5 U.S.C. § 7701(b)(2)(A)(ii), and we do not have the authority to review issues related to the appellant’s security clearance, we deny the appellant’s motion to dismiss the agency’s petition for review.

The appellant demonstrated good cause for the delay in filing her appeal. ¶10 The agency asserts on review that the appellant did not show good cause for the over 4-month delay in filing her appeal. PFR File, Tab 1 at 7-11. It acknowledges that it did not provide her with notice of Board appeal rights but argues that she did not act diligently in filing an appeal after the Board, in response to her inquiry, sent her a November 4, 2024 email providing information regarding the process for filing a Board appeal. Id. at 8-9.

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Denise Davis v. Department of Defense, Counsel Stack Legal Research, https://law.counselstack.com/opinion/denise-davis-v-department-of-defense-mspb-2026.