Eva Ryals v. Department of Justice

CourtMerit Systems Protection Board
DecidedApril 29, 2024
DocketAT-0752-21-0308-I-2
StatusUnpublished

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Bluebook
Eva Ryals v. Department of Justice, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

EVA RYALS, DOCKET NUMBER Appellant, AT-0752-21-0308-I-2

v.

DEPARTMENT OF JUSTICE, DATE: April 29, 2024 Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

J.R. Pritchett , McCammon, Idaho, for the appellant.

Jeanelle L. Graham , Esquire, Atlanta, Georgia, for the agency.

BEFORE

Cathy A. Harris, Chairman Raymond A. Limon, Vice Chairman

FINAL ORDER

The appellant has filed a petition for review of the initial decision, which affirmed her 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 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

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

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 update the administrative judge’s analysis of the agency’s charge and the appellant’s claims of discrimination and retaliation, we AFFIRM the initial decision.

BACKGROUND In 2014, the appellant sustained work-related injuries to her knee, finger, ribs, and chest while serving as a GS-11 Teacher in the agency’s Bureau of Prisons (BOP) at the Federal Correctional Complex in Coleman, Florida. Ryals v. Department of Justice, MSPB Docket No. AT-0752-21-0308-I-1, Initial Appeal File (IAF), Tab 1 at 1, Tab 7 at 141-42. She never returned to work following her injuries and, in August 2020, the agency removed her for physical and medical inability to perform. IAF, Tab 6 at 16-18. As background, BOP first attempted to remove the appellant in June 2016, in part for failing to report for a fitness for duty examination (FFD). IAF, Tab 8 at 126, 140. The appellant filed an equal employment opportunity (EEO) complaint challenging the 2016 removal. Id. at 126. In October 2017, the agency issued a final agency decision (FAD) finding that BOP should have rescheduled the appellant’s FFD as a reasonable accommodation for her disability after she failed to attend the exam for medical reasons. Id. at 137-43. As a result, the agency ordered BOP to schedule an FFD examination to determine whether the appellant was able to perform the essential duties of her position and, if so, to 3

reinstate her. Id. at 142. The appellant attended an FFD in November 2017 and was found fit for duty; BOP ordered her to report to duty on February 2, 2018. IAF, Tab 6 at 127-30. However, the appellant did not return to duty and instead provided a note from her knee surgeon, stating that she was “attending physical therapy” and had “not been released from [his] care.” IAF, Tab 6 at 123-26, Tab 16 at 5. The agency placed the appellant in a leave without pay status and she continued to receive Office of Workers’ Compensation Programs (OWCP) benefits. IAF, Tab 6 at 126. Seven months later, the agency issued a letter with eight specific medical questions for her medical provider (8-point letter), including her diagnosis and estimated date of recovery. IAF, Tab 9 at 4-6. Although she did not provide responses to the eight questions, the appellant submitted medical documents, including a second opinion medical examination report requested by OWCP, which stated that she had reached maximum medical improvement and was unable to perform the physical requirements of her position. Id. at 8, 20, 23-24. As a result, the agency found that the appellant was not medically qualified to perform her duties and invited her to complete a reasonable accommodation request form. IAF, Tab 6 at 84-87, 105-07. The appellant completed the form, requesting, as relevant here, reassignment. Id. at 86. The agency conducted a search for vacant funded positions to which she could be reassigned. Id. at 51-78, 80-81. However, the agency advised the appellant that it could not find any such positions. Id. at 44-45. The appellant submitted a response, which the agency interpreted as a request for reconsideration. Id. at 40-43. In reply, the agency reiterated that it had been unable to identify any vacant funded positions to which she could be reassigned. Id. at 38-39. The agency removed the appellant in August 2020, for physical and medical inability to perform the essential duties of her position. Id. at 16-21. The appellant filed an EEO complaint challenging her 2020 removal, and the agency issued a FAD finding no discrimination. IAF, Tab 1 at 7-20. 4

The appellant then filed this appeal of her removal. Id. at 2. After holding a hearing, the administrative judge issued an initial decision affirming the removal. Ryals v. Department of Justice, MSPB Docket No. AT-0752-21-0308-I- 2, Appeal File (I-2 AF), Tab 14, Initial Decision (ID) at 2, 28. He found that the agency proved its charge of medical inability to perform by preponderant evidence. ID at 7-15. He determined that the appellant failed to prove her affirmative defenses of failure to accommodate, disparate treatment based on disability, EEO retaliation, and harmful error. ID at 16-28. He concluded that removal was reasonable because the appellant could not meet the physical requirements of her position and there were no vacant funded positions to which she could be reassigned. ID at 28. The appellant has filed a petition for review, and the agency has filed a response. Petition for Review (PFR) File, Tabs 1, 3. On review, the appellant disputes the administrative judge’s finding that the agency proved she was medically unable to meet the physical requirements of her position and, therefore, the charge. PFR File, Tab 1 at 4-5, 7-8. She also reasserts that she is a qualified individual with a disability and that the agency denied her reasonable accommodation and retaliated against her for prior EEO activity. Id. at 9-14. She disputes the denial of her harmful error affirmative defense. Id. at 14-15.

DISCUSSION OF ARGUMENTS ON REVIEW We modify the initial decision to find that the agency proved its charge under the standard articulated in Haas v. Department of Homeland Security , 2022 MSPB 36, ¶¶ 14-15. The administrative judge found that the agency proved that the appellant was medically unable to perform the physical requirements of her position. ID at 14. In reaching this conclusion, the administrative judge applied the standard for removals based on medical history, which the Board articulated in Sanders v. Department of Homeland Security, 122 M.S.P.R. 144, ¶ 11, aff’d, 625 F. App’x 549 (Fed. Cir. 2015), overruled in part by Haas, 2022 MSPB 36, 5

¶¶ 10-14. ID at 7, 15.

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Eva Ryals v. Department of Justice, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eva-ryals-v-department-of-justice-mspb-2024.