Janel Smith v. Department of Justice

CourtMerit Systems Protection Board
DecidedApril 23, 2024
DocketCH-1221-22-0137-W-1
StatusUnpublished

This text of Janel Smith v. Department of Justice (Janel Smith v. Department of Justice) 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
Janel Smith v. Department of Justice, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

JANEL N. SMITH, DOCKET NUMBER Appellant, CH-1221-22-0137-W-1

v.

DEPARTMENT OF JUSTICE, DATE: April 23, 2024 Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Richard R. Renner , Esquire, Silver Spring, Maryland, for the appellant.

Elaine Fitch , Esquire, Washington, D.C., for the appellant.

Jennifer A. Weger , 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 dismissed her individual right of action (IRA) appeal for lack of jurisdiction. Generally, we grant petitions such as this one only in the following circumstances: the initial decision contains erroneous findings of material fact;

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

BACKGROUND The appellant is employed as a GS-9 Investigative Analyst at the agency’s Kansas City Field Division in Fairview Heights, Illinois. Initial Appeal File (IAF), Tab 9 at 4. On January 17, 2022, the appellant filed the instant IRA appeal alleging that the agency failed to provide her training and select her for a new position in retaliation for her protected whistleblowing disclosures and activities, and she requested a hearing on her appeal. IAF, Tab 1 at 2, 5, 8, Tab 9 at 6. With her initial appeal, the appellant provided a copy of a Board appeal rights letter from the Office of Special Counsel (OSC) dated November 19, 2021. IAF, Tab 1 at 8. The administrative judge issued a jurisdictional order in which she apprised the appellant of the applicable law and burden of proof requirements for an IRA appeal and ordered her to submit evidence and argument establishing Board jurisdiction over her appeal. IAF, Tab 3. The administrative judge also directed the appellant to file a statement detailing the specific elements of her claim. Id. In response, the appellant provided a sworn declaration asserting that she made 3

protected disclosures, engaged in protected activity, and further described the actions she alleged were taken in retaliation for the same. IAF, Tab 9 at 4-8. She also included a copy of her OSC complaint. Id. at 9-29, 98-105. In an initial decision based on the written record, the administrative judge found that the appellant exhausted her claims with OSC but failed to make a nonfrivolous allegation that her protected disclosure or protected activity was a contributing factor in the agency’s decision to take a personnel action against her. IAF, Tab 14, Initial Decision (ID) at 1, 10. Specifically, she found it undisputed that the appellant made a protected disclosure in 2010 and engaged in protected activity when she filed a Board appeal in 2013 and a petition for review in 2015 relating to her protected disclosure. ID at 5. She also found that the agency subjected her to a personnel action when it failed to select her for an Industry Operations Investigator (IOI) position, but she concluded that the appellant failed to demonstrate that her disclosure or activity was a contributing factor in the agency’s decision to not select her for the IOI position. ID at 7-10. Therefore, the administrative judge dismissed the appeal for lack of jurisdiction without holding the requested hearing. ID at 1, 10. The appellant has timely filed a petition for review of the initial decision. Petition for Review (PFR) File, Tab 1. The agency has filed a response in opposition. PFR File, Tab 4. The appellant has filed a reply. PFR File, Tab 8.

DISCUSSION OF ARGUMENTS ON REVIEW The Board has jurisdiction over an IRA appeal if the appellant exhausts her administrative remedies before OSC and makes nonfrivolous allegations that she made a protected disclosure described under 5 U.S.C. § 2302(b)(8) or engaged in protected activity described under 5 U.S.C. § 2302(b)(9)(A)(i), (B), (C), or (D), and the disclosure or protected activity was a contributing factor in the agency’s decision to take or fail to take a personnel action. Chambers v. Department of Homeland Security, 2022 MSPB 8, ¶ 14; see Hessami v. Merit Systems Protection 4

Board, 979 F.3d 1362, 1367 (Fed. Cir. 2020). The Board’s regulations define a nonfrivolous allegation as an assertion that, if proven, could establish the matter at issue. 5 C.F.R. § 1201.4(s). 2 The U.S. Court of Appeals for the Federal Circuit has found that, in the context of an IRA appeal, a nonfrivolous allegation is an allegation of “sufficient factual matter, accepted as true, to state a claim that is plausible on its face.” Hessami, 979 F.3d at 1364, 1369. Once an appellant establishes jurisdiction over her IRA appeal, she is entitled to a hearing on the merits of her claim, which she must prove by preponderant evidence. Rebstock Consolidation v. Department of Homeland Security, 122 M.S.P.R. 661, ¶ 9 (2015). For the reasons discussed below, we agree with the administrative judge that the appellant has shown that she exhausted her administrative remedies before OSC but failed to nonfrivolously allege that her protected disclosure or protected activity was a contributing factor in her nonselection.

The appellant exhausted her administrative remedies with OSC. To satisfy the exhaustion requirement of 5 U.S.C. § 1214(a)(3), an appellant must have provided OSC with a sufficient basis to pursue an investigation into her allegations of whistleblower reprisal. Chambers, 2022 MSPB 8, ¶ 10.

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Janel Smith v. Department of Justice, Counsel Stack Legal Research, https://law.counselstack.com/opinion/janel-smith-v-department-of-justice-mspb-2024.