Jason Peel v. Department of Agriculture

CourtMerit Systems Protection Board
DecidedFebruary 20, 2025
DocketSF-0752-19-0236-I-2
StatusUnpublished

This text of Jason Peel v. Department of Agriculture (Jason Peel v. Department of Agriculture) 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
Jason Peel v. Department of Agriculture, (Miss. 2025).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

JASON PEEL, DOCKET NUMBER Appellant, SF-0752-19-0236-I-2

v.

DEPARTMENT OF AGRICULTURE, DATE: February 20, 2025 Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Morgan Velasquez , Esquire, and Tyler Sroufe , Esquire, Dallas, Texas, for the appellant.

Janet Robinson-Card , and Noreen Joice , Kansas City, Missouri, for the agency.

Patricia McNamee , Washington, D.C., for the agency.

BEFORE

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

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

FINAL ORDER

The appellant has filed a petition for review of the initial decision, which sustained his 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 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 supplement the administrative judge’s penalty analysis, we AFFIRM the initial decision.

BACKGROUND The following facts, as further detailed in the initial decision, are not disputed. The appellant most recently held the position of Assistant Director. Peel v. Department of Agriculture, MSPB Docket No. SF-0752-19-0236-I-1, Initial Appeal File (IAF), Tab 1 at 1; Peel v. Department of Agriculture, MSPB Docket No. SF-0752-19-0236-I-2, Appeal File (I-2 AF), Tab 22, Initial Decision (ID) at 1-2. In December 2018, the agency proposed his removal, based on six charges, most of which included multiple specifications. IAF, Tab 9 at 35-44. After the appellant responded, id. at 23-34, the deciding official sustained all charges and specifications, along with the proposed removal, id. at 18-22. 3

The appellant filed the instant appeal, challenging his removal. IAF, Tab 1. The administrative judge developed the record and held a hearing. I-2 AF, Tab 15, Hearing Recording, Day 1 (HR1), Tab 17, Hearing Recording, Day 2 (HR2); ID at 2. The administrative judge found that the agency proved five of its six charges but not all the underlying specifications. ID at 3-24. He also found that the appellant failed to prove his affirmative defenses, which included discrimination based on religion, ID at 24-27, sex, ID at 27-29, and disability, ID at 29-34. Finally, the administrative judge found that the agency proved the requisite nexus and reasonableness of its penalty, affirming the removal action. ID at 34-36. The appellant has filed a timely petition for review. Peel v. Department of Agriculture, MSPB Docket No. SF-0752-19-0236-I-2, Petition for Review (PFR) File, Tabs 1-3. In his petition, the appellant disputes the administrative judge’s findings regarding the charges, nexus, and penalty. PFR File, Tab 3 at 7-16. He also reasserts each of the affirmative defenses raised below. Id. at 16-21. Finally, the appellant argues that the administrative judge erred by allowing the agency to submit some evidence and identify a witness after its deadline for doing so. Id. at 21-22. The agency has filed a response. PFR File, Tab 6.

DISCUSSION OF ARGUMENTS ON REVIEW The administrative judge did not abuse his discretion regarding the agency’s submission of evidence or requests for witnesses. Regarding the appellant argument on review that the administrative judge erred by allowing the agency to untimely submit some evidence and identify a witness, PFR File, Tab 3 at 21-22, we are not persuaded. In his prehearing submissions, the appellant requested one particular witness to testify about parking and key cards. IAF, Tab 19 at 8. The agency objected because that individual left the area years before the events leading to the appellant’s removal from his position. IAF, Tab 25 at 4-5. Nevertheless, the administrative judge allowed the witness. Id. In response, the agency requested 4

permission to locate a witness of its own regarding the same matter, and the administrative judge agreed. Id. at 5. The administrative judge indicated that the witness must be identified by May 28, 2019. Id. After the deadline for doing so, the agency submitted a pleading identifying the witness it located, while also providing some untimely documentary evidence. I-2 AF, Tab 4. The appellant objected to the agency’s untimely identified witness and documentation. I-2 AF, Tab 5 at 4-6. The administrative judge overruled the appellant’s objection, noting that the agency’s untimeliness was the result of technical difficulties with the Board’s e-Appeal system. I-2 AF, Tab 8 at 1-2; HR1 (opening remarks). At the hearing, and over the appellant’s objection, the administrative judge also admitted documentation of an agency policy that had been referenced throughout the record but not yet provided in full. HR1 (opening remarks); I-2 AF, Tab 14. The Board’s regulations give the administrative judge wide discretion in these areas. 5 C.F.R. § 1201.41(b)(3), (6), (8), (10); see, e.g., Rodgers v. Department of the Navy, 122 M.S.P.R. 559, ¶ 21 (2015) (finding no abuse of discretion where an administrative judge ruled on discovery motions and allowed an appellant to supplement the record at the start of a hearing); Hooper v. Department of the Interior, 120 M.S.P.R. 658, ¶¶ 19-20 (2014) (finding no abuse of discretion where an administrative judge permitted an agency witness that the appellant characterized as untimely identified). Although the appellant disagrees with the administrative judge’s decision to allow the agency’s untimely submissions, we find that the administrative judge did not abuse his discretion.

The administrative judge properly sustained charges 1, 3, 4, 5, and 6. As mentioned above, the administrative judge sustained five of six charges but not all the underlying specifications. 2 ID at 3-24. Our discussion will focus

2 The charge that the administrative judge did not sustain was charge 2, unauthorized use of a government-owned-vehicle. IAF, Tab 9 at 36-37; ID at 6-8. 5

on the sustained specifications and charges, along with the appellant’s arguments about the same. PFR File, Tab 3 at 7-13.

Charge 1 – Inappropriate Conduct The agency’s first charge, inappropriate conduct, included two specifications. IAF, Tab 9 at 36.

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Jason Peel v. Department of Agriculture, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jason-peel-v-department-of-agriculture-mspb-2025.