Gabriel Kotsis v. Department of Transportation

CourtMerit Systems Protection Board
DecidedApril 24, 2024
DocketAT-0432-16-0006-B-1
StatusUnpublished

This text of Gabriel Kotsis v. Department of Transportation (Gabriel Kotsis v. Department of Transportation) 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
Gabriel Kotsis v. Department of Transportation, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

GABRIEL KOTSIS, DOCKET NUMBER Appellant, AT-0432-16-0006-B-1

v.

DEPARTMENT OF DATE: April 24, 2024 TRANSPORTATION, Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Gabriel Kotsis , Atlanta, Georgia, pro se.

Dolores Francis , Washington, D.C., 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 his performance-based removal. On petition for review, among other things, the appellant attributes his failure to respond to the administrative judge’s orders below to his representative’s failure to timely inform him of the termination of his representation. Generally, we grant petitions such as this one 1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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

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 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 and AFFIRM the initial decision, which is now the Board’s final decision. 5 C.F.R. § 1201.113(b).

DISCUSSION OF ARGUMENTS ON REVIEW In the remand proceedings below, the administrative judge ordered the parties to advise him whether additional discovery or reconvening of the hearing would be required pursuant to the Board’s August 9, 2022 Remand Order. Kotsis v. Department of Transportation, MSPB Docket No. AT-0432-16-0006-B-1, Remand File (RF), Tab 5 at 1. Because neither party responded, the administrative judge issued a close of record order setting a date by which additional evidence and argument must be received. RF, Tab 6 at 1. Neither party responded to this order either. The administrative judge then issued a remand initial decision, affirming the appellant’s removal and finding his affirmative defenses without merit. In his pro se petition for review, the appellant appears to attribute his failure to respond to the administrative judge’s orders to his representative’s failure to timely inform him of the termination of his representation. Kotsis v. Department of Transportation, MSPB Docket No. AT-0432-16-0006-B-1, 3

Remand Petition for Review (RPFR) File, Tab 1 at 4. Although an appellant is bound by the errors of his chosen representative, the Board has held that, when an appellant’s diligent efforts to prosecute his appeal were thwarted by his representative’s negligence or malfeasance, the appellant and his representative were not acting as one, and the representative’s negligence or malfeasance should not be attributed to the appellant. Caracciolo v. Office of Personnel Management, 86 M.S.P.R. 601, ¶ 5 (2000). Here, it is not clear from the petition for review or the circumstances that the appellant’s prior representative committed negligence or malfeasance such that relief would be appropriate. After the appellant’s representative filed the petition for review in the initial appeal, the appellant filed his reply to the agency’s response as well as the motion to excuse the untimely filing of his reply, both pro se. Kotsis v. Department of Transportation, MSPB Docket No. AT-0432-16-0006-I-1, Petition for Review File, Tabs 4, 6. These pleadings indicate that the appellant should have been aware when he filed them in 2016 that his prior representative had ceased representing him. This was many years before the Board’s August 2022 Remand Order and subsequent proceedings. Further, the circumstances indicate that the appellant was less than diligent in prosecuting his appeal during the remand proceedings. In his petition for review, the appellant states that he was informed when he visited his representative’s firm’s offices in person on October 11, 2022, after the issuance of the remand initial decision, that his representative no longer worked for the firm and the firm no longer represented him in his appeal. RPFR File, Tab 1 at 4. Because the appellant was a registered e-filer, it can be presumed that he received both the administrative judge’s September 6, 2022 Order inviting the parties to request discovery or a hearing and the September 14, 2022 Close of Record Order stating that neither party had done so. RF, Tabs 5-6; see 5 C.F.R. § 1201.14(m)(2) (documents served electronically on registered e-filers are deemed received on the date of electronic submission). Yet 4

the appellant’s statements indicate that he chose to wait until after the October 6, 2022 Remand Initial Decision to first contact his representative about the remand proceedings. RPFR File, Tab 1 at 1. It thus appears that the appellant’s failures to respond to the administrative judge’s orders in the remand proceedings were attributable foremost to his failure to diligently prosecute his appeal. See Rowe v. Merit Systems Protection Board, 802 F.2d 434, 438 (Fed. Cir. 1986) (stating that an appellant has a personal duty to monitor the progress of his appeal at all times and not leave it entirely to his attorney). Under these circumstances, we find that the appellant is not entitled to any relief regarding this issue. 2

2 The appellant raises several new arguments on review, namely what appears to constitute an age discrimination affirmative defense and claims related to his performance appraisals and his supervisor’s feedback. RPFR File, Tab 1 at 5-6. The appellant failed to raise these claims below or show that they are based on new and material evidence not previously available despite due diligence, and we thus decline to consider them. Clay v. Department of the Army, 123 M.S.P.R. 245, ¶ 6 (2016). In any event, the evidence is insufficient to support an age discrimination affirmative defense or the appellant’s claim regarding his 2017 performance appraisal, and the appellant’s claim that the deciding official did not give him performance feedback has no bearing on whether the agency proved the elements of a performance -based removal under 5 U.S.C. chapter 43. The appellant also appears to raise on review a national origin discrimination affirmative defense, which he raised in his initial appeal but at no point thereafter until the petition for review of the remand initial decision.

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Norman R. Rowe v. Merit Systems Protection Board
802 F.2d 434 (Federal Circuit, 1986)
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2022 MSPB 21 (Merit Systems Protection Board, 2022)

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Gabriel Kotsis v. Department of Transportation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gabriel-kotsis-v-department-of-transportation-mspb-2024.