Joshua Brown v. Social Security Administration

CourtMerit Systems Protection Board
DecidedMay 6, 2024
DocketCB-7121-23-0004-V-1
StatusUnpublished

This text of Joshua Brown v. Social Security Administration (Joshua Brown 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
Joshua Brown v. Social Security Administration, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

JOSHUA BROWN, DOCKET NUMBER Appellant, CB-7121-23-0004-V-1

v.

SOCIAL SECURITY DATE: May 6, 2024 ADMINISTRATION, Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Charlette Paulk , Ball, Louisiana, for the appellant.

Kendria Brown , Esquire, Grand Prairie, Texas, for the appellant.

Joshua Peter Dehnke and Lyndsey Frushour , Esquire, 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 an arbitrator’s decision that denied his grievance of his removal. For the reasons set forth below, 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1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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

appellant’s request for review is DISMISSED as untimely filed without good cause shown. 5 C.F.R. § 1201.155(b).

BACKGROUND The appellant was formerly employed as a Senior Case Technician with the agency. Request for Review (RFR) File, Tab 5 at 2. On January 18, 2023, he filed an appeal challenging an arbitration decision, which was issued on December 6, 2022. 2 RFR File, Tab 1 at 1, 51. The appeal was forwarded to the Office of the Clerk of the Board for docketing as a request for review of an arbitrator’s decision. RFR File, Tab 2 at 1. The Office of the Clerk of the Board issued an acknowledgment order that advised the appellant that he appeared to have filed his request 8 days late. Id. at 3. It further notified the appellant of the timeliness requirements that he must meet to obtain review of the arbitration decision and ordered the appellant to file evidence and argument to prove that the request for review was timely and/or there existed good cause for any delay in filing his request for review. Id. at 3-4. The appellant responded alleging that the attorney who represented him during arbitration did not notify him of the adverse arbitration decision until December 14, 2022. RFR File, Tab 7 at 2-3. The agency has submitted a response to the appellant’s request for review. RFR File, Tab 8.

DISCUSSION OF ARGUMENTS ON REVIEW The appellant’s request for review is untimely filed without good cause shown for the delay. A request for review of an arbitrator’s decision is timely if filed 35 days from the issuance of the arbitration decision or, if the appellant shows that he received the decision more than 5 days after it was issued, within 30 days after the date he received the decision. Kirkland v. Department of Homeland Security, 119 M.S.P.R. 74, ¶ 4 (2013); 5 C.F.R. § 1201.155(b). As previously noted, the 2 The appellant’s union raised a claim of disability discrimination before the arbitrator. RFR File, Tab 1 at 5. 3

arbitrator’s decision was issued on December 6, 2022. RFR File, Tab 1 at 51. According to the appellant, the decision was sent directly to the attorney who represented him during the arbitration, but he does not otherwise allege that his attorney received the decision more than 5 days after it was issued on December 6, 2022. RFR File, Tab 7 at 3. To the contrary, the agency submitted a copy of the December 6, 2022 email that the arbitrator sent to the agency and the appellant’s attorney, which contained a copy of the arbitration decision. RFR File, Tab 8 at 83. Receipt of a decision by an appellant’s designated representative constitutes constructive receipt by the appellant. Fain v. Department of Education, 98 M.S.P.R. 162, ¶ 5 (2005). Thus, under the 35-day standard, the appellant should have filed his request by January 10, 2023. The appellant alleges that his attorney did not send him a copy of the arbitration decision until December 14, 2022, and therefore the deadline should not begin to toll until that date. RFR File, Tab 7 at 2-3. We find this argument unpersuasive. The appellant’s delay in receiving the decision from his attorney, whether justified or not, does not extend the deadline for filing. See, e.g., Earls v. Department of the Treasury, 95 M.S.P.R. 391, ¶ 4, aff’d sub nom. Earls v. Merit Systems Protection Board, 113 F. App’x 924 (Fed. Cir. 2004). In any event, even if we assume that the filing deadline did not begin to toll until the appellant personally received the arbitration decision on December 14, 2022, his request for review was still untimely filed under the 30 -day standard, as it should have been filed by January 13, 2023. Because the appellant did not file his request for review until January 18, 2023, via facsimile, we find that it was untimely. See Dooley v. Department of the Air Force, 57 M.S.P.R. 684, 686 (1993) (holding that the date of filing by facsimile is the date imprinted on the facsimile), aff’d sub nom. Dooley v. Merit Systems Protection Board , 22 F.3d 1105 (Fed. Cir. 1994) (Table). The appellant has the burden of proving by preponderant evidence that the request was timely filed with the Board. 5 C.F.R. § 1201.56(b)(2)(i)(B). The 4

Board will dismiss an untimely request unless the appellant establishes good cause for the delayed filing. Kirkland, 119 M.S.P.R. 74, ¶ 5. To establish good cause, the appellant must show that he exercised due diligence or ordinary prudence under the particular circumstances of the case. Id.; see Alonzo v. Department of the Air Force, 4 M.S.P.R. 180, 184 (1980). To determine whether an appellant has shown good cause, the Board will consider the length of the delay, the reasonableness of the excuse and the showing of due diligence, whether the appellant is proceeding pro se, and whether he has presented evidence of the existence of circumstances beyond his control that affected his ability to timely file the request for review. Kirkland, 119 M.S.P.R. 74, ¶ 5; see Moorman v. Department of the Army, 68 M.S.P.R. 60, 62-63 (1995), aff’d sub nom. Moorman v. Merit Systems Protection Board, 79 F.3d 1167 (Fed. Cir. 1996) (Table). We also find that the appellant’s claim that his attorney did not send him a copy of the arbitrator’s decision until December 14, 2022, does not constitute good cause for his delayed filing. To the extent the appellant is claiming that his attorney’s delay was improper, it is well settled that an appellant is responsible for any errors of his chosen representative. See, e.g., Miller v. Department of Homeland Security, 110 M.S.P.R. 258, ¶ 11 (2008); Sofio v. Internal Revenue Service, 7 M.S.P.R. 667, 670 (1981); cf. McCurn v. Department of Defense, 119 M.S.P.R. 226, ¶ 13 (2013) (acknowledging the well-settled principle that an appellant is responsible for the errors of his representative and clarifying that the critical issue in that case was not the appellant’s attorney’s failure to inform the appellant of his Board appeal rights but the agency’s failure to give the appellant proper notice of his right to request review of the arbitration decision before the Board).

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Related

Pacilli v. Merit Systems Protection Board
404 F. App'x 466 (Federal Circuit, 2010)
John A. Dooley v. Merit Systems Protection Board
22 F.3d 1105 (Federal Circuit, 1994)
Garland E. Moorman v. Merit Systems Protection Board
79 F.3d 1167 (Federal Circuit, 1996)
Earls v. Merit Systems Protection Board
113 F. App'x 924 (Federal Circuit, 2004)
Perry v. Merit Systems Protection Bd.
582 U.S. 420 (Supreme Court, 2017)

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Joshua Brown v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joshua-brown-v-social-security-administration-mspb-2024.