Lee McDonald v. Office of Personnel Management

CourtMerit Systems Protection Board
DecidedJune 11, 2024
DocketCH-0841-22-0286-I-1
StatusUnpublished

This text of Lee McDonald v. Office of Personnel Management (Lee McDonald v. Office of Personnel Management) 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
Lee McDonald v. Office of Personnel Management, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

LEE A. MCDONALD, DOCKET NUMBER Appellant, CH-0841-22-0286-I-1

v.

OFFICE OF PERSONNEL DATE: June 11, 2024 MANAGEMENT, Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Lee A. McDonald , Crown Point, Indiana, pro se.

Michael Shipley , Washington, D.C., for the agency.

BEFORE

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

FINAL ORDER

The appellant has filed a petition for review of the initial decision, which affirmed the reconsideration decision of the Office of Personnel Management (OPM) denying his request to change his deferred annuity commencing date. 2 For 1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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 OPM uses the terms “commencing date” and “commencement date” interchangeable. E.g., Initial Appeal File, Tab 13 at 6-7. For clarity, we have used the term 2

the reasons discussed below, we GRANT the appellant’s petition for review, REVERSE the initial decision and OPM’s reconsideration decision, and ORDER OPM to change the appellant’s deferred annuity commencing date to May 1, 2015, and to retroactively recalculate the appellant’s annuity based on that commencing date.

BACKGROUND The appellant separated from Federal service in 1997 at 43 years of age with over 10 years of creditable service under the Federal Employees’ Retirement System. Initial Appeal File (IAF), Tab 13 at 42-50. In July 2020, at age 67, he applied for deferred retirement benefits with OPM. Id. at 36-41. In his application, he designated May 1, 2009, a date on which he was 56 years of age, as the date he wanted benefits to begin accruing. Id. at 40. Based on his application, OPM awarded the appellant an annuity in April 2021 retroactive to a May 1, 2009 commencing date. Id. at 32-35. The appellant then contacted OPM to challenge, among other things, his annuity’s commencing date. Id. at 22-28. He alleged that he filed a second retirement application in September 2020 amending the commencing date to May 1, 2015, a date on which he was 62 years old. Id. at 17-23. OPM issued a reconsideration decision declining to change the commencing date. Id. at 6-7. The appellant appealed the reconsideration decision to the Board. IAF, Tab 1. The administrative judge affirmed OPM’s reconsideration decision in her initial decision, finding that, even if OPM received the appellant’s September 2020 application, OPM correctly designated May 1, 2009, as his annuity commencing date. IAF, Tab 23, Initial Decision (ID). She specifically determined that 5 U.S.C. § 8413(b) prohibited the commencement of the appellant’s annuity on May 1, 2015, a date after his 62nd birthday. ID at 6. She found that, under 5 U.S.C. § 8413(b), OPM was correct to set the appellant’s

“commencing date” throughout our decision. 3

benefits to commence on May 1, 2009, by which date he had attained his minimum retirement age (MRA) of 56 but had not yet turned age 62. ID at 4, 6. She also found that 5 C.F.R. § 842.212(b)(4), which states that the election of a commencing date “becomes irrevocable when OPM authorizes the first annuity payment,” prevented OPM from amending the appellant’s annuity commencing date after it authorized his first payment in April 2021. ID at 6. The appellant has filed a petition for review, and the agency has submitted a pro forma response. Petition for Review (PFR) File, Tabs 1, 4. The appellant has filed a reply. PFR File, Tab 5.

ANALYSIS

The appellant is entitled to a deferred annuity with a May 1, 2015 commencing date. In relevant part, 5 U.S.C. § 8413(a) provides that an employee separated after completing 5 years of Federal service is entitled to an annuity after age 62. Meanwhile, 5 U.S.C. § 8413(b) provides that an employee separated after completing 10 years of service but before attaining his MRA may select an annuity commencing date between his MRA and the date he turns 62 years old. 5 U.S.C. § 8413(b)(1). But under 5 U.S.C. § 8413(b)(2)(B), the election of an annuity under “this subsection,” i.e., 5 U.S.C. § 8413(b), is not effective unless the employee “will not otherwise be eligible to receive an annuity within 31 days after filing the election.” It is undisputed that the appellant filed an application for a deferred annuity in July 2020. IAF, Tab 13 at 6, 10. Though the appellant had 10 years of creditable service and elected an annuity commencing on his MRA—56 years of age—in that application, 5 U.S.C. § 8412(h)(1)(C), he filed that application when he was 67 years old. Id. at 40. Because the appellant had completed over 5 years of credible service and attained age 62 when he filed his July 2020 application, he was eligible when he filed that application to receive an annuity under 5 U.S.C. 4

§ 8413(a), and thus his election of an annuity under 5 U.S.C. § 8413(b)— including the May 1, 2009 commencing date—was not effective under 5 U.S.C. § 8413(b)(2). In other words, because the appellant was already entitled to an annuity under 5 U.S.C. § 8413(a) beginning at age 62 at the time of his July 2020 application, under 5 U.S.C. § 8413(b)(2), no designation of a commencing date before age 62 in that application could have been effective. Under 5 C.F.R. § 842.212, the regulation promulgated to implement 5 U.S.C. § 8413, the appellant’s annuity should have begun on the first day of the month after he attained age 62, i.e., May 1, 2015. 5 C.F.R. § 842.212(a); IAF, Tab 13 at 42. In explaining this regulation, OPM expressed its intent to ensure that, consistent with 5 U.S.C. § 8413

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Lee McDonald v. Office of Personnel Management, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lee-mcdonald-v-office-of-personnel-management-mspb-2024.