Janelle Mason v. Office of Personnel Management

CourtMerit Systems Protection Board
DecidedJune 27, 2024
DocketDC-844E-20-0306-I-1
StatusUnpublished

This text of Janelle Mason v. Office of Personnel Management (Janelle Mason v. Office of Personnel Management) 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
Janelle Mason v. Office of Personnel Management, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

JANELLE MASON, DOCKET NUMBER Appellant, DC-844E-20-0306-I-1

v.

OFFICE OF PERSONNEL DATE: June 27, 2024 MANAGEMENT, Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Janelle Mason , District Heights, Maryland, pro se.

Linnette Scott , Washington, D.C., for the agency.

BEFORE

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

*Member Kerner did not participate in the adjudication of this appeal.

FINAL ORDER

The appellant has filed a petition for review of the initial decision, which dismissed for failure to prosecute her appeal of a decision by the Office of Personnel Management. On review, she argues that she was unable to attend 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1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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

scheduled telephonic hearing below due to a “pandemic medical emergency.” 2 Petition for Review (PFR) File, Tab 1 at 3; Initial Appeal File, Tab 7 at 1. 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 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). If a party fails to prosecute or defend an appeal, the sanction of dismissal with prejudice may be imposed. Davis v. Department of Commerce, 120 M.S.P.R. 34, ¶ 17 (2013); Williams v. U.S. Postal Service, 116 M.S.P.R. 377, ¶ 7 (2011) (citing Ahlberg v. Department of Health and Human Services, 804 F.2d 1238, 1242 (Fed. Cir. 1986) and 5 C.F.R. § 1201.43(b)). Such an extreme sanction is only appropriate when necessary to serve the ends of justice and

2 The appellant indicates in her petition for review that she is including with her pleading medical documents surrounding a medical emergency. Petition for Review (PFR) File, Tab 1 at 2. However, it does not appear that she has included any such documents. Rather, it seems that the appellant attempted to scan medical documentation, as one of the pages of the attachments contains the phrase “in 1 -2 days for reeval,” but this documentation is illegible and incomplete. Id. at 4-5. Recognizing that certain medical documentation could have an impact on the success of the appellant’s petition for review, the Office of the Clerk of the Board provided the appellant with an opportunity to resubmit the attachments, but the appellant did not do so. PFR File, Tab 4. 3

should only be imposed when (1) a party has failed to exercise basic due diligence in complying with Board orders or (2) a party has exhibited negligence or bad faith in its efforts to comply. Davis, 120 M.S.P.R. 34, ¶ 18; Williams, 116 M.S.P.R. 377, ¶ 7. If an appellant repeatedly fails to respond to multiple Board orders, such inaction reflects a failure to exercise basic due diligence, and the imposition of the sanction of dismissal for failure to prosecute is appropriate. Williams, 116 M.S.P.R. 377, ¶ 9; Heckman v. Department of the Interior, 106 M.S.P.R. 210, ¶ 16 (2007); Murdock v. Government Printing Office, 38 M.S.P.R. 297, 299 (1988). Absent a showing of abuse of discretion, the Board will not reverse an administrative judge’s determination regarding the imposition of sanctions, including the sanction of dismissal with prejudice. Turner v. U.S. Postal Service, 123 M.S.P.R. 640, 644-45 (2016), aff’d, 681 F. App’x 934 (Fed. Cir. 2017). Based on our review of the record, we find no abuse of discretion on the part of the administrative judge in this appeal. 3

NOTICE OF APPEAL RIGHTS 4 You may obtain review of this final decision. 5 U.S.C. § 7703(a)(1). By statute, the nature of your claims determines the time limit for seeking such 3 As noted above, the appellant claims in her petition for review that she was unable to attend a hearing because of a “pandemic medical emergency.” PFR File, Tab 1 at 3. However, she has not explained why she was unable to respond to the administrative judge’s orders regarding prehearing submissions, nor has she explained why she failed to respond to the order to show cause. Id. Moreover, she has not explained how a medical emergency impacted her ability to respond to any of the administrative judge’s orders. Id. Importantly, she has not provided any evidence to support her claim of a “pandemic medical emergency,” despite having multiple opportunities to do so. PFR File, Tabs 1, 4. The Board typically will not entertain a claim of a medical emergency absent corroborating evidence. See, e.g., Martin v. Office of Personnel Management, 51 M.S.P.R. 360, 361 (1991) (stating that an appellant’s claim that he was ill is a “mere assertion” when it is unsupported by medical documentation when analyzing a timeliness issue and whether an appellant’s assertion of illness constituted good cause). Accordingly, the appellant’s petition for review does not provide a basis to disturb the initial decision. 4 Since the issuance of the initial decision in this matter, the Board may have updated the notice of review rights included in final decisions. As indicated in the notice, the Board cannot advise which option is most appropriate in any matter. 4

review and the appropriate forum with which to file. 5 U.S.C. § 7703(b). Although we offer the following summary of available appeal rights, the Merit Systems Protection Board does not provide legal advice on which option is most appropriate for your situation and the rights described below do not represent a statement of how courts will rule regarding which cases fall within their jurisdiction. If you wish to seek review of this final decision, you should immediately review the law applicable to your claims and carefully follow all filing time limits and requirements. Failure to file within the applicable time limit may result in the dismissal of your case by your chosen forum.

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Related

Turner v. Merit Systems Protection Board
681 F. App'x 934 (Federal Circuit, 2017)
Perry v. Merit Systems Protection Bd.
582 U.S. 420 (Supreme Court, 2017)

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Janelle Mason v. Office of Personnel Management, Counsel Stack Legal Research, https://law.counselstack.com/opinion/janelle-mason-v-office-of-personnel-management-mspb-2024.