Jonathan Erickson v. Department of the Army

CourtMerit Systems Protection Board
DecidedJuly 8, 2024
DocketSF-0752-18-0227-I-1
StatusUnpublished

This text of Jonathan Erickson v. Department of the Army (Jonathan Erickson v. Department of the Army) 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
Jonathan Erickson v. Department of the Army, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

JONATHAN ERICKSON, DOCKET NUMBER Appellant, SF-0752-18-0227-I-1

v.

DEPARTMENT OF THE ARMY, DATE: July 8, 2024 Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Stephanie Bernstein , Esquire, and Tyler Sroufe , Esquire, Dallas, Texas, for the appellant.

Ian D. Clunies-Ross , Esquire, Seattle, Washington, 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.

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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 affirmed his removal for medical inability to perform the essential duties of his position. 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 analysis of the appellant’s discrimination claims and whistleblower reprisal affirmative defense, we AFFIRM the initial decision.

BACKGROUND On September 25, 2014, the appellant, a Power Plant Mechanic (PPM) for the agency’s Army Corps of Engineers in Bridgeport, Washington, incurred an on-the-job injury to both of his feet when several steel plates fell on him due to the failure of a storage rack. Initial Appeal File (IAF), Tab 1 at 1, Tab 6 at 82. Following his injury, the appellant began a long absence while he received wage replacement benefits from the OWCP. IAF, Tab 6 at 61, 78, 80. In January 2017, he reached maximum medical improvement (MMI) and the agency therefore assumed that his medical restrictions were permanent. Id. at 61. The agency 3

subsequently searched for positions, but it found there were no positions available in the machine shop at the appellant’s facility, the Chief Joseph Dam, within his medical restrictions. Id. at 66. An agency Human Resources Specialist then searched for vacant, funded positions throughout the district for which the appellant was qualified and that were within his medical restrictions, including those that were expected to open within the next 30 days, but she was also not successful. Id. at 52-59; Hearing Compact Disc (HCD) (testimony of the agency Human Resources Specialist). The agency issued a June 28, 2017 notice of proposed removal charging the appellant with medical inability to perform the essential duties of his position. Id. at 49-51. He provided written responses. Id. at 26-27, 33-44. The deciding official sustained the charge, finding that the appellant was unable to perform the essential duties of his position. Id. at 21. Because the appellant’s medical documentation did not indicate a foreseeable end to his medical condition, or that he would be able to return to work in his current position, the deciding official found that the appellant’s removal promoted the efficiency of the service and issued a decision removing the appellant effective January 8, 2018. Id. at 21-22. The appellant appealed his removal. IAF, Tab 1. After holding a hearing, the administrative judge sustained the charge and found that the appellant failed to establish his affirmative defenses of disability discrimination, retaliation for EEO activity, and whistleblower retaliation. IAF, Tab 24, Initial Decision (ID) at 10-25. He found that the agency established a nexus between the appellant’s inability to perform his duties and the efficiency of the service, and that the penalty did not exceed the tolerable bounds of reasonableness. ID at 25-26. The appellant has filed a petition for review. Petition for Review (PFR) File, Tab 4. He argues that his removal exceeds the tolerable limits of reasonableness. Id. at 7-8. He challenges the administrative judge’s findings that the appellant did not prove his affirmative defenses of status-based disability discrimination and discrimination based on a failure to accommodate. Id. at 8-10, 4

12-15. The agency has responded to the appellant’s petition for review. PFR File, Tab 6.

DISCUSSION OF ARGUMENTS ON REVIEW The administrative judge properly found that the agency proved the charge. When, as here, the appellant does not occupy a position with medical standards or physical requirements subject to medical evaluation programs, in order to establish a charge of medical inability to perform, the agency must prove a nexus between the employee’s medical condition and observed deficiencies in his performance or conduct, or a high probability, given the nature of the work involved, that his condition may result in injury to himself or others. Clemens v. Department of the Army, 120 M.S.P.R. 616, ¶¶ 4-5 (2014); Fox v. Department of the Army, 120 M.S.P.R. 529, ¶ 25 (2014). In other words, the agency must establish that the appellant’s medical condition prevents him from being able to safely and efficiently perform the core duties of his position. Clemens, 120 M.S.P.R. 616, ¶ 5. In determining whether the agency has met its burden, the Board will consider whether a reasonable accommodation exists that would enable the appellant to safely and efficiently perform those core duties. Id. However, for the limited purposes of proving the charge, the agency is not required to show that it was unable to reasonably accommodate the appellant by assigning her to a vacant position for which she was qualified; whether it could do so goes to the affirmative defense of disability discrimination or the reasonableness of the penalty. Id. The appellant explicitly declines to contest the administrative judge’s finding that he cannot perform the essential duties of his PPM position. PFR File, Tab 4 at 14; ID at 9. Based on the appellant’s medical restrictions, and the testimony before him, the administrative judge determined that the agency met its burden to prove there was a high probability, given the nature of the work involved, that the appellant’s condition might result in injury to himself or others. 5

ID at 10. Thus, he sustained the charge. Id. We discern no basis to disturb his finding.

The appellant failed to establish his affirmative defenses. Disability discrimination The appellant asserted disability discrimination, both status-based and based on the agency’s failure to accommodate his disabilities. IAF, Tab 18 at 5, Tab 20 at 3.

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Jonathan Erickson v. Department of the Army, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jonathan-erickson-v-department-of-the-army-mspb-2024.