Julia Downs v. Department of Commerce

CourtMerit Systems Protection Board
DecidedMay 2, 2024
DocketDC-1221-21-0223-W-1
StatusUnpublished

This text of Julia Downs v. Department of Commerce (Julia Downs v. Department of Commerce) 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
Julia Downs v. Department of Commerce, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

JULIA DOWNS, DOCKET NUMBER Appellant, DC-1221-21-0223-W-1

v.

DEPARTMENT OF COMMERCE, DATE: May 2, 2024 Agency.

THIS ORDER IS NONPRECEDENTIAL 1

George M. Chuzi , Esquire, Washington, D.C., for the appellant.

Kristin Murrock , Esquire, Suitland, Maryland, for the agency.

BEFORE

Cathy A. Harris, Chairman Raymond A. Limon, Vice Chairman

REMAND 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. For the reasons discussed below, we GRANT the appellant’s petition for review, VACATE the initial decision, and REMAND the case to the regional office for further adjudication in accordance with this Remand Order.

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

BACKGROUND The appellant, a GS-15 Assistant Division Chief for Human Resources Policy, Talent Development, and Performance Management within the Human Resources Division of the agency’s Census Bureau (CB), filed an appeal with the Board alleging that agency officials took several actions against her in retaliation for her disclosures to agency management, the agency’s Office of Inspector General (IG or OIG), and the Office of Special Counsel (OSC). Initial Appeal File (IAF), Tab 1 at 1, 4, Tab 9 at 6-9. With her appeal, the appellant submitted a December 4, 2020 letter from OSC advising her that it had terminated its inquiry into her allegations. IAF, Tab 1 at 4-5. The administrative judge issued an order setting forth the appellant’s burden to establish the Board’s jurisdiction over her IRA appeal. IAF, Tab 3. The appellant submitted an unsworn response. IAF, Tab 9 at 3. In her response, she provided details regarding her purported disclosures and activities. Id. at 6-14. Specifically, she identified them as follows: 1. In January 2020, [she] disclosed to [the Chief Human Capital Officer] and the IG [her first-level supervisor’s] gross waste of $145,000 and abuse of authority regarding the performance management pilot project; 2. On May 19, 2020, [she] disclosed to the OSC [her second-level supervisor’s] violation of law, rule, or regulation regarding Census’[s] implementation of COVID leave, presenting a substantial and specific danger to public health or safety; and 3. On August 11, 2020, [she] disclosed to [the CB Director, CB Deputy Director, and the appellant’s first- and second-level supervisors] [her second-level supervisor’s] gross mismanagement regarding Census’[s] implementation of COVID leave, presenting a substantial and specific danger to public health or safety.

Id. at 9-10. The administrative judge issued an initial decision based on the written record, dismissing the appeal for lack of jurisdiction. IAF, Tab 15, Initial Decision (ID) at 1, 6-7. Specifically, after apprising the appellant of her 3

jurisdictional burdens and considering the parties submissions on the issue, he found that the appellant failed to prove that she exhausted her OSC remedy as to the disclosures and activities she raised on appeal. IAF, Tabs 3, 9-10; ID at 4-6. The appellant has filed a petition for review of the initial decision. Petition for Review (PFR) File, Tab 1. The agency has responded to the appellant’s petition. PFR File, Tab 4.

DISCUSSION OF ARGUMENTS ON REVIEW Under the Whistleblower Protection Enhancement Act of 2012 (WPEA), the Board has jurisdiction over an IRA appeal if the appellant has exhausted her administrative remedies before OSC and makes nonfrivolous allegations that (1) 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 (2) the disclosure or protected activity was a contributing factor in the agency’s decision to take or fail to take a personnel action as defined by 5 U.S.C. § 2302(a). Salerno v. Department of the Interior, 123 M.S.P.R. 230, ¶ 5 (2016). 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. Id. If the appellant proves that her protected disclosure or activity was a contributing factor in a personnel action taken against her, the agency is given an opportunity to prove, by clear and convincing evidence, that it would have taken the same personnel action in the absence of the protected disclosure or activity. 5 U.S.C. § 1221(e)(1)-(2); Salerno, 123 M.S.P.R. 230, ¶ 5.

The appellant proved exhaustion of her claimed protected activities and protected disclosures before OSC. Under 5 U.S.C. § 1214(a)(3), an employee is required to “seek corrective action from [OSC] before seeking corrective action from the Board” through an IRA appeal. Miller v. Federal Deposit Insurance Corporation, 122 M.S.P.R. 3, ¶ 6 (2014), aff’d, 626 F. App’x 261 (Fed. Cir. 2015). The substantive 4

requirements of exhaustion are met when an appellant has provided OSC with a sufficient basis to pursue an investigation. Chambers v. Department of Homeland Security, 2022 MSPB 8, ¶ 10. The Board’s jurisdiction over an IRA appeal is limited to those issues that have been previously raised with OSC, but appellants may give a more detailed account of their whistleblowing activities before the Board than they did to OSC. Id. An appellant may demonstrate exhaustion through her initial OSC complaint, evidence that she amended the original complaint, including but not limited to OSC’s determination letter and other letters from OSC referencing any amended allegations, and the appellant’s written responses to OSC referencing the amended allegations. Mason v. Department of Homeland Security, 116 M.S.P.R. 135, ¶ 8 (2011). In this case, the administrative judge found the appellant’s submissions insufficient to prove by preponderant evidence that she exhausted her administrative remedies before OSC. ID at 4-6. The administrative judge reasoned that her submissions lacked necessary details and failed to reflect “that the disclosures and personnel actions alleged in her [OSC] complaint match[ed] the allegations made to the Board.” 2 Id.

The appellant exhausted the activity and disclosure she identified as “disclosure (1).” On review, the appellant argues that the allegations she made to OSC, as reflected in its December 4, 2020 letter, were sufficient to meet her exhaustion requirement as to disclosure (1). PFR File, Tab 1 at 10-14. We agree. 2 The appellant argues on review that the administrative judge erred in finding that the jurisdictional response she submitted below was entitled to little probative weight. PFR File, Tab 1 at 19; ID at 4. We find it unnecessary to reach this argument.

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Julia Downs v. Department of Commerce, Counsel Stack Legal Research, https://law.counselstack.com/opinion/julia-downs-v-department-of-commerce-mspb-2024.