Eric Meekins v. Department of Veterans Affairs

CourtMerit Systems Protection Board
DecidedFebruary 28, 2023
DocketSF-0432-17-0005-I-1
StatusUnpublished

This text of Eric Meekins v. Department of Veterans Affairs (Eric Meekins 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
Eric Meekins v. Department of Veterans Affairs, (Miss. 2023).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

ERIC MEEKINS, DOCKET NUMBER Appellant, SF-0432-17-0005-I-1

v.

DEPARTMENT OF VETERANS DATE: February 28, 2023 AFFAIRS, Agency.

THIS ORDER IS NONPRECEDENTIAL 1

Justin Prato, Esquire, San Diego, California, for the appellant.

Joseph Manuel Briones, Esquire, Los Angeles, California, 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 affirmed his removal from his position as a Rating Veterans Service Representative (RVSR) for unacceptable performance under 5 U.S.C. chapter 43 and found that he failed to prove his affirmative defenses of (1) disability

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

discrimination on the basis of failure to accommodate, (2) disparate treatment disability discrimination, and (3) retaliation for prior protected equal employment opportunity (EEO) activity. For the reasons set forth below, we GRANT the petition for review. We MODIFY the initial decision to clarify the legal standard applicable to the appellant’s claim of retaliation for prior protected EEO activity, and we REMAND the appeal to the regional office for further adjudication consistent with the U.S. Court of Appeals for the Federal Circuit’s decision in Santos v. National Aeronautics and Space Administration, 990 F.3d 1355 (Fed. Cir. 2021).

DISCUSSION OF ARGUMENTS ON REVIEW The appellant’s arguments on review do not provide a basis to disturb the initial decision. ¶2 On petition for review, the appellant first argues that the administrative judge erred in denying two of his requested witnesses. Petition for Review (PFR) File, Tab 1 at 6-7. He contends that the testimony of these two Veterans Service Representative (VSR) employees was relevant to show that he was not afforded a reasonable opportunity to improve his performance because they would have testified as to how his supervisor manipulated work numbers and took away work from employees as well as tactics they witnessed the appellant’s supervisor use to retaliate against other employees. Id. The record reflects that the administrative judge initially denied these requested witnesses because their proffered testimony concerning the appellant’s supervisor’s actions in removing work from the appellant would have been duplicative of the appellant’s testimony and testimony of another VSR employee, who the appellant proffered would testify that he witnessed the appellant’s supervisor remove work from the appellant and give other RVSR’s credit for the appellant’s work. Initial Appeal File (IAF), Tab 14 at 2-3. ¶3 However, the administrative judge indicated that he would reconsider denied witnesses based on a more detailed proffer of the relevance of their 3

testimony and a statement indicating that the requesting party discussed and /or attempted to discuss the anticipated testimony with the requested witness. Id. at 3. The appellant objected to the administrative judge’s ruling regarding these witnesses and provided a more detailed proffer. IAF, Tab 15 at 4-5. The administrative judge then denied the appellant’s request on the basis that he failed to indicate that he attempted to discuss the anticipated testimony with either of the individuals as required by the order. IAF, Tab 17 at 1-2. We find no abuse of discretion in the administrative judge’s denial of the appellant’s witness es based on his failure to discuss their anticipated testimony in advance. See Lopes v. Department of the Navy, 119 M.S.P.R. 106, ¶ 11 (2012) (stating that rulings regarding the exclusion of evidence are subject to review by the Board under an abuse of discretion standard). Without talking to the witnesses, the appellant could not confirm the accuracy of his proffers. See Franco v. U.S. Postal Service, 27 M.S.P.R. 322, 325 (1985) (finding that an administrative judge has wide discretion to exclude witnesses when it has not been shown that their testimony would be relevant, material, and nonrepetitious). ¶4 Next, the appellant challenges the administrative judge’s conclusion that he failed to prove his affirmative defense of disability discrimination on the basis of failure to accommodate. PFR File, Tab 1 at 7-9. To this end, the appellant argues that the administrative judge erred in finding that he failed to show that he was a qualified individual with a disability and contends that the agency should have accommodated him by granting his request for a voluntary change to a lower-graded position as a Military Service Coordinator (MSC). Id. The record reflects that the appellant requested an accommodation in the f orm of a transfer to a new position away from his current supervisor with flexible hours, the option to telework, and/or a change to a new work environment in which he would be able to interact with other coworkers, veterans, and the general public. IAF, Tab 6 at 99-100. In addressing the appellant’s claim that the agency failed to reasonably accommodate him, the administrative judge found that, assuming that 4

the appellant met the definition of disabled, he was not a qualified individual with a disability because he did not identify any accommodation or manner of modifying his RVSR position that would have allowed him to perform the essential functions of his position and he failed to explain how he was qualified to fill the MSC position based on his résumé and personnel file. IAF, Tab 19, Initial Decision (ID) at 19-21. The administrative judge also credited testimony that RVSRs and MSCs review similar documents and follow a similar process of examining and evaluating cases at the intake level and, thus, found that the appellant was not qualified for the MSC position based on his unacceptable performance as an RVSR. ID at 20-21. We discern no material error in the administrative judge’s analysis and, therefore, discern no basis to disturb his conclusion that the appellant failed to show that the agency discriminated against him by failing to provide him with a reasonable accommodation. ¶5 Moreover, to the extent the appellant’s request for a transfer amounted merely to a request for reassignment to a new supervisor, such a request does not constitute a request for reasonable accommodation. See, e.g., Roberts v. Permanente Medical Group, Inc., 690 F. App’x 535, 536 (9th Cir. 2017) (holding that a request for a new supervisor is per se unreasonable under Equal Employment Opportunity Commission guidelines); Gaul v. Lucent Technologies Inc., 134 F.3d 576, 581 (3d Cir. 1998) (holding that a request to be transferred away from a supervisor who was causing a plaintiff stress was unre asonable as a matter of law); Weiler v. Household Finance Corporation, 101 F.3d 519, 526-27 (7th Cir. 1996) (holding that failure to grant the plaintiff’s request for reassignment to a different supervisor did not constitute a failure to grant a reasonable accommodation).

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Bluebook (online)
Eric Meekins v. Department of Veterans Affairs, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eric-meekins-v-department-of-veterans-affairs-mspb-2023.