Louis Tutt v. Department of the Army

CourtMerit Systems Protection Board
DecidedApril 3, 2024
DocketDC-1221-22-0234-W-1
StatusUnpublished

This text of Louis Tutt v. Department of the Army (Louis Tutt 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
Louis Tutt v. Department of the Army, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

LOUIS M. TUTT, DOCKET NUMBER Appellant, DC-1221-22-0234-W-1

v.

DEPARTMENT OF THE ARMY, DATE: April 3, 2024 Agency.

THIS ORDER IS NONPRECEDENTIAL 1

Luis M. Melendez , Esquire, Washington, D.C., for the appellant.

Joseph A. Fedorko , Esquire, Mary J. Bradley , Esquire, Washington, D.C., 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 his 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decision, and REMAND the case to the regional office for further adjudication in accordance with this Remand Order. 1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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 previously served as the Director of Audit Readiness for the agency’s Office of the Assistant Secretary (Acquisition, Logistics, and Technology) in Arlington, Virginia. Initial Appeal File (IAF), Tab 12 at 4, 47, 60. In October 2021, the appellant filed a whistleblower complaint with the Office of Special Counsel (OSC), alleging that, between 2018 and 2021, the agency took multiple personnel actions against him in retaliation for his disclosures and activities. IAF, Tab 1 at 4; Petition for Review (PFR) File, Tab 5 at 35-37. On December 13, 2021, OSC issued two letters notifying him that it had closed its investigation into his claims and that he could file an appeal with the Board. IAF, Tab 12 at 11-14; PFR File, Tab 5 at 48. The appellant filed the instant appeal, disagreeing with OSC’s decision to close its investigation. IAF, Tab 1 at 3, 8-9. He requested a hearing. Id. at 2. The administrative judge notified the appellant of his jurisdictional burden and ordered him to file evidence and argument on the jurisdictional issue. IAF, Tab 11. In response, the appellant submitted a sworn statement along with supporting documentation, alleging that he made the following protected disclosures and engaged in the following protected activities: (1) he reported contractor fraud to the Deputy Assistant Secretary of the Army (Plans, Programs, Resources) (Deputy Assistant) and the agency’s Criminal Investigation Division (CID); (2) he filed and pursued a U.S. Court of Appeals for the Fourth Circuit (Fourth Circuit) case against the agency; and (3) he participated as a witness in an equal employment opportunity (EEO) complaint in support of his coworker. IAF, Tab 12 at 3, 5, 7-8, 11, 23-26, 47-50, 60-63, 80. The appellant alleged that, in retaliation for his protected disclosures and activities, the agency initiated an Army Regulation (AR) 15-6 investigation against him, placed him on a temporary detail, then permanently reassigned him, and eventually proposed his removal. Id. at 4-8. The appellant resigned on October 28, 2021. Id. at 13; PFR File, Tab 5 at 48. 3

After the record closed on jurisdiction, the administrative judge issued an initial decision dismissing the appeal for lack of jurisdiction. IAF, Tab 14, Initial Decision (ID) at 1, 8. He found that the appellant failed to exhaust some of his disclosures and activities before OSC, and that the appellant failed to make a nonfrivolous allegation that any of his remaining disclosures and activities were protected. ID at 7-8. The appellant has filed a petition for review. PFR File, Tab 5. The agency has filed a response, and the appellant has replied. PFR File, Tabs 8, 11. We find that the appellant established jurisdiction over his IRA appeal and remand this appeal to the regional office for a hearing on the merits.

DISCUSSION OF ARGUMENTS ON REVIEW The Board has jurisdiction over an IRA appeal if the appellant has exhausted his administrative remedies before OSC and makes nonfrivolous allegations that: (1) he made a 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 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). McCray v. Department of the Army, 2023 MSPB 10, ¶ 11. Any doubt or ambiguity as to whether the appellant made nonfrivolous jurisdictional allegations should be resolved in favor of finding jurisdiction. Skarada v. Department of Veterans Affairs, 2022 MSPB 17, ¶ 6. In cases involving multiple alleged protected disclosures or activities and multiple alleged personnel actions, the Board has jurisdiction if the appellant has exhausted his administrative remedies before OSC and makes a nonfrivolous allegation that at least one alleged personnel action was taken in reprisal for at least one alleged protected disclosure or activity. Usharauli v. Department of Health & Human Services, 116 M.S.P.R. 383, ¶ 19 (2011). 4

We find that the appellant did not exhaust his CID disclosures and did exhaust his participation in a coworker’s EEO complaint. An employee seeking corrective action for whistleblower reprisal under 5 U.S.C. § 1221 is required to seek corrective action from OSC before seeking corrective action from the Board. Chambers v. Department of Homeland Security, 2022 MSPB 8, ¶ 5. After the initial decision was issued in this case, the Board clarified the substantive requirements of exhaustion in Chambers. Id., ¶¶ 10-11. The exhaustion requirement is met when an appellant has provided OSC with a sufficient basis to pursue an investigation. Id., ¶ 10. The Board’s jurisdiction is limited to those issues that have been previously raised with OSC. Id. However, an appellant may give a more detailed account of his whistleblowing activities before the Board than he did to OSC. Id. An appellant may demonstrate exhaustion through his initial OSC complaint or correspondence with OSC. Id., ¶ 11. In the alternative, exhaustion may be proven through other sufficiently reliable evidence, such as an affidavit or declaration attesting that the appellant raised with OSC the substance of the facts in his Board appeal. Id. The administrative judge below did not have the benefit of the Chambers decision. Further, for the first time on review, the appellant has provided a copy of his OSC complaint and additional correspondence with OSC to support his burden as to the administrative exhaustion requirement. PFR File, Tab 5 at 27-48. These documents provide new information regarding the appellant’s alleged disclosures that the administrative judge did not have available below. Under 5 C.F.R. § 1201.115

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Louis Tutt v. Department of the Army, Counsel Stack Legal Research, https://law.counselstack.com/opinion/louis-tutt-v-department-of-the-army-mspb-2024.