Ernesto Pelayo v. Department of Homeland Security

Merit Systems Protection Board·Decided January 15, 2025·No. SF-0752-20-0286-I-1·Unpublished

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

ERNESTO PELAYO, DOCKET NUMBER Appellant, SF-0752-20-0286-I-1

v.

DEPARTMENT OF HOMELAND DATE: January 15, 2025 SECURITY, Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Ryan C. Nerney , Esquire, Ladera Ranch, California, for the appellant.

Lauren J. Johnson , Esquire, San Diego, California, for the agency.

BEFORE

Cathy A. Harris, Chairman Raymond A. Limon, Vice Chairman Henry J. Kerner, Member

FINAL ORDER

The appellant has filed a petition for review of the initial decision, which affirmed his 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 interpretation of statute

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

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 recognize and apply the proper standards for the agency’s charge and the appellant’s disability discrimination claims and to address the appellant’s argument that the agency’s requirement that he undergo a fitness for duty examination constituted disability discrimination, we AFFIRM the initial decision. The following facts, as further detailed in the parties’ stipulations and the initial decision, appear to be undisputed. Initial Appeal File (IAF), Tab 18 at 16-18; Tab 22 at 8-11; Tab 24 at 3-6; Tab 35, Initial Decision (ID) at 2-5. The appellant began working as a Customs and Boarder Protection Officer (CBPO) in 2005. ID at 2. In November 2016, he had an off-duty accident in which he suffered multiple fractures in his spine and hip. Id. After 2 months of leave and extensive medical treatment, the appellant returned to a light duty assignment. ID at 2-3. A couple of months later, the appellant returned to his assignment with the agency’s Anti-Terrorism Contraband Enforcement Team, though his physician indicated that he could work no more than 8 hours per day. ID at 3. That restriction continued until August 2017, when the appellant’s physician indicated that he could work no more than 12 hours per day. Id. Subsequent communications from the appellant’s physician maintained similar restrictions, 3

citing degenerative joint disease in the hip, as well as pain and stiffness. Id.; IAF, Tab 5 at 22. In February 2019, the agency ordered that the appellant undergo a fitness for duty examination. ID at 4; IAF, Tab 17 at 20. This included an independent medical exam by a family practitioner in April, IAF, Tab 5 at 7-16, followed by an independent medical exam by an orthopedist in June, IAF, Tab 4 at 72-78, Tab 5 at 41-47, then a review of medical information by a third physician in August, IAF, Tab 4 at 66-68. The latter two provided their opinion about the appellant’s condition as it related to his position, with each concluding that he was not medically fit for duty as a CBPO. IAF, Tab 4 at 66-71. In September 2019, the agency proposed the appellant’s removal for inability to perform the full range of duties. IAF, Tab 4 at 62-64. The appellant responded to the proposal and provided a note from the physician who performed his 2016 surgery indicating that the appellant was fit for duty. ID at 4; IAF, Tab 5 at 39. At that point, the fitness for duty physicians who had previously opined that the appellant was not fit issued a supplemental report indicating that their opinions were unchanged. IAF, Tab 4 at 52-60. Then, in January 2020, the agency offered to reassign the appellant to a non-law enforcement position, but he declined the offer. Id. at 33, 61. The next month, February 2020, the deciding official effectuated the appellant’s removal. ID at 5; IAF, Tab 4 at 47-50. The appellant filed the instant appeal to challenge his removal. IAF, Tab 1. After developing the record and holding the requested hearing, the administrative judge affirmed the action. She first found that the agency proved its charge. ID at 14-21. Next, the administrative judge found that the appellant failed to prove his claims of disparate treatment disability discrimination, ID at 21-24, disability discrimination based on a failure to accommodate, ID at 25-29, harmful procedural error, ID at 29-32, or a violation of due process rights, ID at 32-33. Lastly, she found that the agency established the requisite nexus and reasonableness of its penalty. ID at 33-35. 4

The appellant has filed a petition for review. Petition for Review (PFR) File, Tab 1. He challenges the administrative judge’s findings regarding proof of the charge and credibility, id. at 9-14, 22-26, disability discrimination, id. at 14-19, harmful procedural error, id. at 19-21, and nexus, id. at 21-22. The agency has filed a response. PFR File, Tab 3.

The administrative judge applied an inapplicable legal standard to the agency’s charge. Once again, the agency proposed and then effectuated the appellant’s removal based on a single charge of inability to perform the full range of his CBPO duties. IAF, Tab 4 at 47, 62. The administrative judge analyzed this charge under 5 C.F.R. § 339.206 and the standard set out in Sanders v. Department of Homeland Security, 122 M.S.P.R. 144, ¶ 11, aff’d per curiam, 625 F. App’x 549 (Fed. Cir. 2015), finding that the agency proved its charge by establishing that the appellant had a disqualifying medical condition that poses a reasonable probability of causing substantial harm. ID at 13-14, 21. Though not raised by either party on review, we find section 339.206 and the Sanders standard inapplicable. See 5 C.F.R. § 1201.115(e) (providing that, although the Board normally will consider only issues raised by the parties on review, it reserves the authority to consider any issue in an appeal before it). As explained below, section 339.206 and Sanders do not apply to this appeal because the agency did not remove the appellant based solely on his medical history; rather, it removed the appellant based on a current medical condition and inability to perform. In Haas v. Department of Homeland Security, 2022 MSPB 36, we revisited the Board’s precedent concerning a medical inability to perform charge when the employee occupied a position that was subject to medical standards, e.g., the position of CBPO.

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Ernesto Pelayo v. Department of Homeland Security, (Miss. 2025).

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Related

Sanders v. Department of Homeland Security
625 F. App'x 549 (Federal Circuit, 2015)
Perry v. Merit Systems Protection Bd.
582 U.S. 420 (Supreme Court, 2017)
George Haas v. Department of Homeland Security
2022 MSPB 36 (Merit Systems Protection Board, 2022)