Latisha Zepeda v. Nuclear Regulatory Commission

2024 MSPB 14
CourtMerit Systems Protection Board
DecidedOctober 30, 2024
DocketDA-0432-19-0539-I-1
StatusPublished

This text of 2024 MSPB 14 (Latisha Zepeda v. Nuclear Regulatory Commission) 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
Latisha Zepeda v. Nuclear Regulatory Commission, 2024 MSPB 14 (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD 2024 MSPB 14 Docket No. DA-0432-19-0539-I-1

Latisha A. Zepeda, Appellant, v. Nuclear Regulatory Commission, Agency. October 30, 2024

Kevin C. Crayon Jr. , Esquire, Kennesaw, Georgia, for the appellant.

Michael Gartman , Esquire, and Vinh Hoang , Esquire, Rockville, Maryland, for the agency.

BEFORE

Cathy A. Harris, Chairman Raymond A. Limon, Vice Chairman Henry J. Kerner, Member

OPINION AND ORDER

¶1 The agency has filed a petition for review and the appellant has filed a cross petition for review of the initial decision, which reversed the appellant’s performance-based removal but denied her affirmative defenses. For the reasons discussed below, we DENY the petition for review and the cross petition for review. Except as expressly MODIFIED to incorporate the appropriate analytical framework for the appellant’s disability discrimination claim, we AFFIRM the initial decision. 2

BACKGROUND ¶2 The following facts, as further detailed in the initial decision, are not disputed. The appellant has a lengthy history of Federal employment, most recently as a Special Agent for the agency’s Office of Investigations. Initial Appeal File (IAF), Tab 1 at 1, Tab 28 at 4, Tab 51, Initial Decision (ID) at 3. In that position, her permanent first-line supervisor was the Special Agent in Charge (SAIC). IAF, Tab 28 at 4; ID at 3. However, an Acting SAIC supervised the appellant from March to June 2018. IAF, Tab 28 at 4; ID at 4. During that period, the agency issued a performance improvement requirements memorandum (PIRM), which placed the appellant under a performance improvement period (PIP) based on unacceptable performance in three critical elements: (1) planning and preparation for assigned investigations; (2) conduct of investigations/assists to staff; and (3) preparation of reports of investigation and assists to staff closure memoranda. IAF, Tab 19 at 35-46; ID at 4. Upon expiration of the PIP, the agency proposed the appellant’s removal for unacceptable performance in the same three critical elements. IAF, Tab 15 at 79-85; ID at 4. After the appellant responded to the proposal, the deciding official sustained her removal, effective October 2018. IAF, Tab 18 at 4-12; ID at 4-5. ¶3 The appellant unsuccessfully challenged her removal in a formal equal employment opportunity (EEO) complaint with the agency. IAF, Tab 5 at 6-32; ID at 5 n.5. Upon receipt of the final agency decision, she filed the instant appeal to challenge her performance-based removal and raise several affirmative defenses. IAF, Tab 1 at 1, Tab 5 at 6. ¶4 The administrative judge developed the record and held a 2-day hearing before reversing the appellant’s removal based on the agency’s failure to prove that its performance standards were valid. ID at 3, 8-12. The administrative judge also considered but rejected the appellant’s claims of a due process violation, ID at 5-7; discrimination based on race, sex, and national origin, along 3

with associated EEO reprisal, ID at 12-21; and disability discrimination, ID at 22-26. ¶5 The agency has filed a petition for review. Petition for Review (PFR) File, Tab 1. The appellant has filed a response, PFR File, Tab 3, and the agency has replied, PFR File, Tab 5. The appellant has also filed a cross petition for review, PFR File, Tab 3, to which the agency has responded, PFR File, Tab 6.

ANALYSIS

The agency failed to prove that its performance standards were valid. ¶6 At the time the initial decision was issued, the Board’s case law stated that, to prevail in an appeal of a performance-based removal under chapter 43, the agency must establish the following by substantial evidence: 1 (1) the Office of Personnel Management (OPM) approved its performance appraisal system and any significant changes thereto; (2) the agency communicated to the appellant the performance standards and critical elements of her position; (3) the appellant’s performance standards were valid under 5 U.S.C. § 4302(b)(1); (4) the agency warned the appellant of the inadequacies of her performance during the appraisal period and gave her a reasonable opportunity to demonstrate acceptable performance; and (5) the appellant’s performance remained unacceptable in one or more of the critical elements for which she was provided an opportunity to

1 Substantial evidence is the degree of relevant evidence that a reasonable person, considering the record as a whole, might accept as adequate to support a conclusion, even though other reasonable persons might disagree. 5 C.F.R. § 1201.4(p). 4

demonstrate acceptable performance. 2 Lee v. Environmental Protection Agency, 115 M.S.P.R. 533, ¶ 5 (2010). The administrative judge applied this standard and found that the agency proved the first two elements, ID at 7-8, but failed to prove the third—the validity of its performance standards, ID at 8-12. Therefore, the administrative judge reversed the appellant’s removal without addressing the remaining elements. Since that third element is the crux of the arguments on review, our analysis will be similarly focused.

The performance standards in the appellant’s performance plan were invalid. ¶7 Under certain performance appraisal systems, including the one at issue in this appeal, performance of a critical element may fall between “fully successful” and “unacceptable.” Jackson-Francis v. Office of Government Ethics, 103 M.S.P.R. 183, ¶ 6 (2006). However, performance falling between those levels, e.g., “minimally successful” performance, would not support removal under chapter 43; only “unacceptable” performance is actionable under the statute. Id., ¶¶ 6-7. Performance standards are not valid if they do not set forth the minimum level of performance that an employee must achieve to avoid removal for unacceptable performance under chapter 43. Id., ¶ 8. Absent valid performance standards, the Board cannot consider charged performance deficiencies. Id. ¶8 As the administrative judge noted, the appellant’s performance plan included a five-tier rating system that consisted of unacceptable, minimally

2 During the pendency of the petition for review in this case, the U.S. Court of Appeals for the Federal Circuit (Federal Circuit) held in Santos v. National Aeronautics and Space Administration, 990 F.3d 1355, 1360-61, 1363 (Fed. Cir. 2021), that in addition to the five elements of the agency’s case set forth above, the agency must also “justify the institution of a PIP” by proving by “substantial evidence that the employee’s unacceptable performance ‘continued’—i.e., it was unacceptable before the PIP.” The Federal Circuit’s decision in Santos applies to all pending cases, including this one, regardless of when the events took place. Lee v. Department of Veterans Affairs, 2022 MSPB 11, ¶ 16. However, given our disposition, we need not remand for adjudication of the element described in Santos. 5

successful, fully successful, excellent, and outstanding performance. ID at 3-4; IAF, Tab 19 at 47-57. However, the plan only defined fully successful performance for each critical element; it did not define minimally successful performance that would have allowed the appellant to avoid removal under chapter 43. ID at 8; IAF, Tab 19 at 47-57. Therefore, the administrative judge found that the standards provided in the appellant’s performance plan were facially invalid. ID at 8-9. ¶9 On review, the agency disagrees that the performance standards provided in the appellant’s performance plan were facially invalid. PFR File, Tab 1 at 7-9. According to the agency, it only needed to define fully successful performance. Id. at 7-8 (citing, e.g., 5 C.F.R.

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Bluebook (online)
2024 MSPB 14, Counsel Stack Legal Research, https://law.counselstack.com/opinion/latisha-zepeda-v-nuclear-regulatory-commission-mspb-2024.