Krista Walker v. Department of Homeland Security

CourtMerit Systems Protection Board
DecidedMarch 26, 2026
DocketDA-114M-24-0485-Y-1
StatusUnpublished

This text of Krista Walker v. Department of Homeland Security (Krista Walker v. Department of Homeland Security) 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
Krista Walker v. Department of Homeland Security, (Miss. 2026).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

KRISTA T. WALKER, DOCKET NUMBER Appellant, DA-114M-24-0485-Y-1

v.

DEPARTMENT OF HOMELAND DATE: March 26, 2026 SECURITY, Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Krista T. Walker , McKinney, Texas, pro se.

Sandra Whittington , Esquire, Irving, Texas, for the agency.

Christine Joy Epres , Esquire, San Francisco, California, for the agency.

BEFORE

Henry J. Kerner, Vice Chairman James J. Woodruff II, Member

FINAL ORDER

The agency has filed a petition for review challenging the administrative judge’s finding that it failed to provide the appellant sufficient notice of her proposed indefinite suspension. For the reasons discussed below, we GRANT the agency’s petition for review. Except AS MODIFIED to REVERSE 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1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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

administrative judge’s finding that the appellant was statutorily entitled to 30 days’ advance written notice of the adverse action and her order that the agency provide back pay and benefits for the remainder of the 30-day notice period, we AFFIRM the initial decision. The agency’s indefinite suspension is SUSTAINED. We FORWARD to the Dallas Regional Office for docketing as a new appeal the appellant’s claim that the agency has improperly continued the indefinite suspension past the occurrence of the condition subsequent. The appellant was appointed to the position of Transportation Security Officer (TSO) with the Transportation Security Administration (TSA) on October 15, 2017. Initial Appeal File (IAF), Tab 8 at 77. As a TSO, the appellant was assigned to perform security functions, such as screening baggage and passengers. Id. at 189. On June 26, 2024, the agency suspended the appellant’s national security eligibility upon learning that the appellant had been arrested for threatening to shoot employees at the apartment complex where she lived if they entered her residence related to her eviction. IAF, Tab 2 at 7-8, Tab 8 at 59. On June 28, 2024, the agency issued the appellant a notice of her proposed indefinite suspension from her TSO position based on the suspension of her national security eligibility. IAF, Tab 8 at 55-59. The notice informed the appellant that, pursuant to TSA Management Directive (MD) 1100.75-3, she had a right to reply to the proposed action within 7 days of receipt of the notice. Id. at 56. The appellant provided an oral and written reply on July 3, 2024. Id. at 44-54. By letter dated July 9, 2024, the deciding official informed the appellant of his decision to indefinitely suspend her based on the sustained charge, effective July 10, 2024. Id. at 25-30. This appeal followed. IAF, Tab 1. After holding the appellant’s requested hearing, the administrative judge issued an initial decision affirming the indefinite suspension. IAF, Tab 37, Initial Decision (ID). Specifically, she found that the agency proved by preponderant evidence that the appellant’s position required national security eligibility, that the appellant’s eligibility was suspended, and that the indefinite suspension had 3

an ascertainable end and promotes the efficiency of the service. ID at 4-6. However, she found that the agency did not provide the appellant with 30 days’ advance notice and time to respond to the proposed action, as required under 5 U.S.C. § 7513(b)(1). 2 ID at 13-14, 15. Accordingly, while she did not find that the agency committed harmful procedural error, she modified the indefinite suspension to commence on July 30, 2024, and ordered the agency to compensate the appellant for the full 30-day period, to include back pay, interest, and an adjustment of benefits. 3 ID at 16. As noted, the agency has filed a petition for review arguing that the administrative judge erred in modifying the indefinite suspension, because it was not required to provide the appellant 30 days’ advance notice pursuant to 5 U.S.C. § 7513(b)(1). Petition for Review (PFR) File, Tab 1. We agree. Because the appellant is a TSA employee, this appeal is governed by the provisions of the Aviation and Transportation Security Act (ATSA). Buelna v. Department of Homeland Security, 121 M.S.P.R. 262, ¶ 5 n.2 (2014); Winlock v. Department of Homeland Security, 110 M.S.P.R. 521, ¶ 5 (2009), aff’d, 370 F. App’x 119 (Fed. Cir. 2010). Pursuant to ATSA, TSA employees are covered by the personnel management system that is applicable to employees of the Federal Aviation Administration (FAA) under 49 U.S.C. § 40122, except to the extent the Administrator of TSA modifies that system as it applies to TSA

2 The administrative judge also found that the appellant failed to prove her affirmative defenses of equal employment opportunity reprisal and race and sex discrimination and did not establish that the indefinite suspension was in violation of law, violated the appellant’s right to due process, or was a prohibited personnel practice under 5 U.S.C. § 2302(b)(9)(D). ID at 6-15. These findings are not at issue on petition for review, and having reviewed the record, we discern no basis to disturb them. See Clay v. Department of the Army, 123 M.S.P.R. 245, ¶ 6 (2016) (finding no reason to disturb the administrative judge’s findings when she considered the evidence as a whole, drew appropriate inferences, and made reasoned conclusions); Crosby v. U.S. Postal Service, 74 M.S.P.R. 98, 105-06 (1997) (same). 3 The administrative judge did not order interim relief pursuant to 5 U.S.C. § 7701(b)(2)(A), as she found that it was not appropriate under the circumstances. ID at 17. 4

employees. Buelna, 121 M.S.P.R. 262, ¶ 5 n.2; Winlock, 110 M.S.P.R. 521, ¶ 5; see 49 U.S.C. § 114(n). Under 49 U.S.C. § 40122(g)(2), many Title 5 provisions, including chapter 75, do not apply to TSA employees. See Buelna, 121 M.S.P.R. 262, ¶ 5 n.2; Winlock, 110 M.S.P.R. 521, ¶ 5. Instead, the FAA’s internal procedures are generally applicable, and the Administrator of TSA has modified those procedures by issuing MD 1100.75-3, which sets forth the agency’s policies and procedures on the use of disciplinary and adverse actions to address employee performance and conduct. Winlock, 110 M.S.P.R. 521, ¶¶ 6-7. MD 1100.75-3 provides that the notice of a proposed adverse action “must include . . . [a] statement that the employee has the right to present an oral and/or written reply to the proposal within seven calendar days,” and that the “time limit may be extended for good cause shown.” IAF, Tab 8 at 177. Thus, the administrative judge erred in finding that the appellant was entitled under 5 U.S.C. § 7513

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Krista Walker v. Department of Homeland Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/krista-walker-v-department-of-homeland-security-mspb-2026.