Malik Shakur v. Department of the Air Force

CourtMerit Systems Protection Board
DecidedJuly 31, 2024
DocketDA-315H-21-0053-I-1
StatusUnpublished

This text of Malik Shakur v. Department of the Air Force (Malik Shakur v. Department of the Air Force) 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
Malik Shakur v. Department of the Air Force, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

MALIK SHAKUR, DOCKET NUMBER Appellant, DA-315H-21-0053-I-1

v.

DEPARTMENT OF THE AIR FORCE, DATE: July 31, 2024 Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Malik Shakur , Oklahoma City, Oklahoma, pro se.

Sean Lanagan , Esquire, and Michele S. McNaughton , Esquire, Tinker Air Force Base, Oklahoma, 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 dismissed his probationary termination appeal for lack of jurisdiction. Generally, we grant petitions such as this one only in the following circumstances: the initial decision contains erroneous findings of material fact; the initial decision is

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

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 petition for review and AFFIRM the initial decision, which is now the Board’s final decision. 5 C.F.R. § 1201.113(b). Because the appellant was serving in a 2-year probationary period and he had completed less than 2 years of current continuous service when he was terminated, 2 the administrative judge properly found that the appellant failed to make a nonfrivolous allegation that he qualifies as an “employee” with appeal rights to the Board under 5 U.S.C. § 7513(b). 3 Initial Appeal File (IAF), Tab 13,

2 Although the administrative judge correctly set forth the dates of the appellant’s appointment and termination and the fact that the appointment was subject to a 2-year probationary period, he inadvertently stated that the appellant was terminated before he completed 1 year of service. This minor misstatement provides no basis to disturb the initial decision. ID at 5; see Panter v. Department of the Air Force, 22 M.S.P.R. 281, 282 (1984) (explaining that an adjudicatory error that is not prejudicial to a party’s substantive rights provides no basis for reversal of an initial decision). 3 At the time of the appellant’s appointment to his competitive-service position in January 2019, an individual appointed to a permanent competitive-service position at the Department of Defense (DOD) was subject to a 2-year probationary period and only qualified as an “employee” under 5 U.S.C. § 7511(a)(1)(A)(ii) (2016) and 10 U.S.C. § 1599e (2016) if he was not serving a probationary or trial period under an initial appointment, or if he had completed 2 years of current continuous service under other than a temporary appointment limited to 1 year or less. IAF, Tab 11 at 41; see Bryant v. Department of the Army, 2022 MSPB 1, ¶ 8. In December 2021, while this appeal was pending on petition for review, Congress repealed 10 U.S.C. § 1599e and the 2-year probationary period for such DOD appointments. Bryant, 2022 MSPB 1, ¶ 8. However, this repeal was made effective December 31, 2022, and only applied to individuals 3

Initial Decision (ID) at 5. The appellant does not challenge this finding on review and we discern no reason to disturb it. For the first time on review, the appellant argues that his termination was based on partisan political reasons, marital status, and preappointment reasons and the agency did not follow the procedures of 5 C.F.R. § 315.805. Petition for Review (PFR) File Tab 1 at 2-3. The Board will generally not consider an argument raised for the first time in a petition for review absent a showing that it is based on new and material evidence not previously available despite the party’s due diligence. Banks v. Department of the Air Force, 4 M.S.P.R. 268, 271 (1980). However, the issue of jurisdiction is thus always before the Board and may be raised by either party or by the Board sua sponte at any time during a proceeding. Ney v. Department of Commerce, 115 M.S.P.R. 204, ¶ 7 (2010). For the reasons stated below, we find that the appellant has not made a nonfrivolous allegation of Board jurisdiction under 5 C.F.R. § 315.806. The appellant does not allege facts which, taken as true, would show that he was treated differently because of his marital status or that go to the essence of his marital status. Marynowski v. Department of the Navy, 118 M.S.P.R. 321, ¶ 9 (2012). He simply notes that the agency was aware that he was a single parent, PFR File, Tab 1 at 2, and childcare responsibilities per se are not dependent on an individual’s marital status and do not go to the essence of marital status. Green-Brown v. Department of Defense, 118 M.S.P.R. 327, ¶ 7 n.2 (2012). Regarding his claim of partisan political discrimination, an appellant’s allegations must consist of more than merely conclusory statements. Bante v. Merit Systems Protection Board, 966 F.2d 647, 649 (Fed. Cir. 1992). The appointed on or after that date. 10 U.S.C. § 1599e note; Bryant, 2022 MSPB 1, ¶ 8. The repeal of 10 U.S.C. § 1599e does not affect the outcome of this appeal. Because the appellant was appointed in January 2019, before the effective date of the repeal, the administrative judge properly concluded that the appellant was serving a 2-year probationary period and lacked the required 2 years of current continuous service at the time of his termination, and therefore that he was not an “employee” with adverse action appeal rights under 5 U.S.C. chapter 75. ID at 4-5; see Bryant, 2022 MSPB 1, ¶¶ 8-9. 4

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Malik Shakur v. Department of the Air Force, Counsel Stack Legal Research, https://law.counselstack.com/opinion/malik-shakur-v-department-of-the-air-force-mspb-2024.