Kathy Jones v. Department of the Army

CourtMerit Systems Protection Board
DecidedJuly 8, 2022
DocketDC-0351-16-0049-I-1
StatusUnpublished

This text of Kathy Jones v. Department of the Army (Kathy Jones 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
Kathy Jones v. Department of the Army, (Miss. 2022).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

KATHY ANN JONES, DOCKET NUMBER Appellant, DC-0351-16-0049-I-1

v.

DEPARTMENT OF THE ARMY, DATE: July 8, 2022 Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Kevin Smith, Columbia, Maryland, for the appellant.

Michael A. Egan, Fort McNair, Virginia, for the agency.

Rebecca Bedford, Esquire, Washington, D.C., for the agency.

BEFORE

Cathy A. Harris, Vice Chairman Raymond A. Limon, Member Tristan L. Leavitt, Member

FINAL ORDER

¶1 The appellant has filed a petition for review of the initial decision, which dismissed the appeal of her alleged involuntary resignation for lack of jurisdiction. Generally, we grant petitions such as this one only when: the initial

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

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 peti tion for review and AFFIRM the initial decision, which is now the Board’s final decision. 5 C.F.R. § 1201.113(b).

BACKGROUND ¶2 The appellant held an Assistant Inspector General position at the agency’s Office of Inspector General. Initial Appeal File (IAF), Tab 14 at 17. Her assigned duty station was Fort Meade, Maryland. Id. On July 21, 2015, the agency identified the position she held for abolishment through a reduction-in-force (RIF) action. Id. at 28. However, during the RIF proceedings, the agency deemed the appellant to have a higher standing within her competitive level than that of an Assistant Inspector General assigned to Fort Belvoir, Virginia. Id. at 25. As a result, on August 3, 2015, the agency directed the appellant’s reassignment to the Fort Belvoir position, thereby displacing the employee who held that position pursuant to RIF procedures. Id. In its letter informing the appellant of the directed reassignment, the agency advised her that, if she refused the reassignment, it would separate her from Federal service. Id. The agency also advised her that refusal to accept the reassignment would make her ineligible for severance pay and that she would not be permitted to register 3

for the Priority Placement Program. Id. The appellant declined the directed reassignment and resigned, effective October 3, 2015. Id. at 22. Consequently, the agency informed the employee who was holding the Assistant Inspector General position at Fort Belvoir that she could remain in the position. Id. at 19. ¶3 The appellant appealed her resignation to the Board, primarily arguing that the agency forced her to resign because the reassigned position at Fort Belvoir was outside her local commuting area. IAF, Tab 1 at 6. The administrative judge advised the appellant of her jurisdictional burden, IAF, Tab 12, held a jurisdictional hearing, IAF, Tab 29, and issued an initial decision dismissing the appeal for lack of jurisdiction, IAF, Tab 31, Initial Decision (ID). The administrative judge found that the appellant failed to show that her resignation was the product of coercion, duress, or misrepresentation on the part of the agency, or that her working conditions were so intolerable that a reasonable person in her position would have felt compelled to re sign. ID at 8-11. As to her argument that Fort Belvoir was outside the local commuting area, the administrative judge found that, even if correct, this factor alone would not be enough to show that the appellant had no choice but to resign. ID at 10 -11. He additionally found that the Board lacked jurisdiction over the appellant’s independent claims concerning her lateral reassignment, the agency’s decision to deny her priority placement and severance pay, and disability discrimination. ID at 8, 11. The appellant has filed a petition for review, and the agency has replied in opposition. Petition for Review (PFR) File, Tabs 1, 3.

DISCUSSION OF ARGUMENTS ON REVIEW ¶4 An employee-initiated action, such as a resignation or retirement, is presumed to be voluntary, and thus outside the Board’s jurisdiction, unless the employee presents sufficient evidence to establish that the action was obtained through duress or coercion, or shows that a reasonable person would have been misled by the agency. Green v. Department of Veterans Affairs, 112 M.S.P.R. 59, 4

¶ 8 (2009). In cases such as this one, when the employee alleges that the agency took actions that made working conditions so intolerable that the employee was driven to an involuntary resignation, the Board will find an action involuntary only if the employee demonstrates that the employer engaged in a course of action that made working conditions so difficult or unpleasant that a reasonable person in that employee’s position would have felt compelled to resign. Vitale v. Department of Veterans Affairs, 107 M.S.P.R. 501, ¶ 20 (2007). The Board addresses allegations of discrimination and reprisal in connection with an alleged involuntary resignation only insofar as those allegations relate to the issue of voluntariness. Id. ¶5 In her petition for review, the appellant reasserts her contention that her resignation was involuntary because the Fort Belvoir position was outside her local commuting area. 2 PFR File, Tab 1 at 1. First, we agree with the administrative judge’s explanation that, for purposes of the RIF, the agency did not attempt to reassign the appellant to a location outside of the local commuting area. ID at 10. Specifically, the administrative judge found, and we agree, based on the totality of the evidence presented below, that the distance between Fort Meade and Fort Belvoir was not so great as to be beyond what employees could “reasonably be expected to travel back and forth daily to their usual employment.” Id. (quoting 5 C.F.R. § 351.203). Second, and significantly, we agree with the administrative judge’s conclusion that, even if the Fort Belvoir position was outside the local commuting area as the appellant contends, she did not present evidence to show that she had no choice but to resign rather than accept the reassignment. ID at 10-11. The record reflects that the administrative judge considered the appellant’s arguments concerning the extended daily

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Kathy Jones v. Department of the Army, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kathy-jones-v-department-of-the-army-mspb-2022.