Haneefah Mahmood v. Social Security Administration

CourtMerit Systems Protection Board
DecidedMay 7, 2024
DocketSF-0752-17-0677-I-2
StatusUnpublished

This text of Haneefah Mahmood v. Social Security Administration (Haneefah Mahmood v. Social Security Administration) 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
Haneefah Mahmood v. Social Security Administration, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

HANEEFAH R. MAHMOOD, DOCKET NUMBER Appellant, SF-0752-17-0677-I-2

v.

SOCIAL SECURITY DATE: May 7, 2024 ADMINISTRATION, Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Andrew Kim , Esquire, Atlanta, Georgia, for the appellant.

Joshua Fizer and Matthew C. Miller , Baltimore, Maryland, 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 sustained 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

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

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 make clear that, consistent with the Board’s decision in Boo v. Department of Homeland Security, 122 M.S.P.R. 100 (2014), the agency provided evidence demonstrating that the appellant made the statements identified in both specifications of the false statement charge for her own private material gain, and to clarify the administrative judge’s findings concerning the appellant’s affirmative defense of reprisal for equal employment opportunity (EEO) activity, we AFFIRM the initial decision.

BACKGROUND The appellant was previously employed as a Senior Case Technician with the agency’s Disability Adjudication and Review office in Seattle, Washington. Mahmood v. Social Security Administration, MSPB Docket No. SF-0752-17- 0677-I-1, Initial Appeal File (IAF), Tab 15 at 34. By a letter dated May 2, 2017, the agency proposed to remove the appellant based on four charges: (1) failure to cooperate with an administrative investigation, with a single specification; (2) conduct unbecoming a Federal employee, with four specifications; (3) lack of candor, with two specifications; and (4) false statements, with two specifications. Id. at 94-113. The charges arose out of the appellant’s interactions with her supervisor on three separate occasions: on January 19, 2017, during the agency’s effort to investigate another employee’s failure to receive two original emails; on 3

March 14, 2017, during the agency’s investigation into allegations that the appellant had harassed another employee; and during a conversation and subsequent emails on March 29, 2017, regarding whether the appellant was completing one of her assigned duties. Id. at 94-100. The appellant provided written and oral replies to the proposed removal. Id. at 60-90. After considering the appellant’s responses, the deciding official issued a decision sustaining all of the charges and specifications and removing the appellant, effective August 4, 2017. Id. at 35-49. The appellant timely filed an appeal with the Board challenging her removal. IAF, Tab 1. The appellant also raised a number of affirmative defenses, including a violation of her Weingarten rights, 2 retaliation for her EEO activity, a due process violation based on ex parte communications between several agency officials involved in her removal, and a violation of the applicable collective bargaining agreement. Id. at 2-12; Mahmood v. Social Security Administration, MSPB Docket No. SF-0752-17-0677-I-2, Refiled Appeal File (RAF), Tab 15 at 2. The appeal was dismissed without prejudice to refiling at the parties’ request, and was subsequently automatically refiled. IAF, Tab 30; RAF, Tab 1; see RAF, Tab 6. Following the first day of the appellant’s requested hearing in the refiled appeal, the parties informed the administrative judge that they had reached a tentative resolution of the appeal, and consequently, the administrative judge postponed the remaining scheduled hearing days. RAF, Tabs 29-30, 35. After the parties were unable to reach a final agreement to settle the appeal, see RAF, Tab 31 at 1, the appellant withdrew her request for a hearing and requested a decision on the written record, RAF, Tabs 39, 40.

2 Weingarten rights involve a private sector employee’s right, articulated in National Labor Relations Board v. J. Weingarten, Inc., 420 U.S. 251, 260 (1975), to request union representation at an investigatory interview that the employee reasonably believes might result in disciplinary action. See Howard v. Office of Personnel Management, 31 M.S.P.R. 617, 621 (1986), aff’d, 837 F.2d 1098 (Fed. Cir. 1987) (Table). Congress granted Federal employees Weingarten-type rights in the Civil Service Reform Act. 5 U.S.C. § 7114(a)(2)(B). 4

After the parties submitted their close of record briefs, RAF, Tabs 41-43, the administrative judge issued an initial decision affirming the agency’s removal action, RAF, Tab 44, Initial Decision (ID). The administrative judge found that the agency proved all four charges and all of the attendant specifications. ID at 8-25. She also found that the appellant failed to prove any of her affirmative defenses. ID at 25-32. Finally, the administrative judge found that the agency established a nexus between the misconduct and the efficiency of the service, and determined that the removal penalty was reasonable under the circumstances. ID at 32-35. The appellant has timely filed a petition for review. Petition for Review (PFR) File, Tab 1. The agency has filed a response. PFR File, Tab 3.

DISCUSSION OF ARGUMENTS ON REVIEW On review, the appellant challenges the administrative judge’s finding that the agency proved the charge of failure to cooperate with an agency investigation, arguing that her conduct did not rise to the level of a refusal to cooperate. PFR File, Tab 1 at 9-12. The appellant also argues that the administrative judge erroneously credited her supervisor’s version of events related to the conduct unbecoming and lack of candor charges, even where it was in conflict with the documentary evidence or was insufficiently specific. Id. at 12-16.

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Haneefah Mahmood v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/haneefah-mahmood-v-social-security-administration-mspb-2024.