Marc Watson v. Office of Personnel Management

CourtMerit Systems Protection Board
DecidedJuly 29, 2024
DocketDC-0843-20-0477-I-1
StatusUnpublished

This text of Marc Watson v. Office of Personnel Management (Marc Watson 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
Marc Watson v. Office of Personnel Management, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

MARC ANTHONY WATSON, DOCKET NUMBER Appellant, DC-0843-20-0477-I-1

v.

OFFICE OF PERSONNEL DATE: July 29, 2024 MANAGEMENT, Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Marc Anthony Watson , Laurel, Maryland, pro se.

Tanisha Elliott , 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) that denied his application for a lump sum death benefit under the Federal Employees’ Retirement System (FERS). Generally, we grant petitions such as

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

this one only in the following circumstances: the initial decision contains erroneous findings of material fact; the initial decision is 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). On petition for review, the appellant repeats his request that his deceased spouse’s passing be considered a “Death in Service” and that he “receive the appropriate compensation.” Petition for Review (PFR) File, Tab 1 at 5. He argues that the administrative judge failed to adequately address his claims regarding the improper processing of his spouse’s application for disability retirement. Id. at 4-5. The appellant also challenges the administrative judge’s denial of his proposed witnesses during the prehearing conference. Id. at 4. 2 Finally, he requests that the Board investigate and/or interview staff from OPM and the employing agency to determine if the proper policies and procedures were followed. Id. at 5. The appellant’s arguments on review provide no basis for overturning the administrative judge’s finding that he failed to meet his burden of proving by preponderant evidence his entitlement to a basic employee death benefit because his spouse met the definition of an annuitant and not a Federal employee at the

2 During the prehearing conference, the appellant withdrew his request for a hearing. Initial Appeal File, Tab 10 at 2. 3

time of her death. Initial Appeal File (IAF), Tab 13, Initial Decision (ID) at 12-13; see 5 U.S.C. § 8401(2); Hall v. Office of Personnel Management, 51 M.S.P.R. 560, 564 (1991), aff’d, 979 F.2d 216 (Fed. Cir. 1992) (Table); 5 C.F.R. §§ 843.102, 1201.56(b)(2)(ii). Under 5 U.S.C. § 8442(b) and OPM’s implementing regulation at 5 C.F.R. § 843.309, a widower may be entitled to a basic employee death benefit under FERS based on the service of a Federal employee who dies while still in duty status, subject to certain requirements. The definition of an employee “includes a person who has applied for retirement under FERS but had not been separated from the service prior to his or her death, even if the person’s retirement would have been retroactively effective upon separation.” 5 C.F.R. § 843.102. Regardless of the appellant’s repeated assertions that OPM should not have processed his spouse’s retirement application due to her misrepresentation that she was unmarried 3 and failure to obtain his consent, the record is clear that she did not meet the definition of an employee under 5 C.F.R. § 843.102 at the time of her death. PFR File, Tab 1 at 4-5; IAF, Tab 8 at 35, Tab 11 at 5-6. OPM approved his spouse’s application for disability retirement on June 29, 2017, and she retired effective July 8, 2017. IAF, Tab 8 at 106, 114. She subsequently passed away on August 4, 2017. Id. at 83. Therefore, the appellant was not entitled to death benefits pursuant to 5 U.S.C. § 8442(b). The administrative judge properly found that the appellant had provided no authority to support his position that he should be entitled to the lump sum death benefit because he would have received it if OPM had not processed his spouse’s 3 Contrary to the appellant’s arguments that his signature and consent were required in order for his deceased spouse to submit her disability retirement application, the relevant statute and regulations prohibit an employee from electing a self-only annuity without spousal consent and did not prevent her from seeking retirement benefits in general without his consent. PFR File, Tab 1 at 4-5; IAF, Tab 11 at 5-6; see 5 U.S.C. § 8416(a)(1); 5 C.F.R. § 842.606. The appellant has acknowledged that OPM made a subsequent determination that he and the decedent were legally separated at the time of her death and has paid to him survivor annuity benefits, which are not at issue in the present appeal. IAF, Tab 8 at 63, Tab 11 at 5. 4

inaccurate retirement application prior to her death and that there is no provision of law that permits OPM to make such payments as a matter of equity. ID at 13 (citing Office of Personnel Management v. Richmond, 496 U.S. 414, 416, 434 (1990)); see Soroka v. Office of Personnel Management, 557 F. Appx. 983, 986 (Fed. Cir. 2014) (stating that the Board lacks “the authority to require OPM to award lump sum death benefits in a matter contrary to the unequivocal dictates” of the controlling statute); see also Mauldin v. U.S. Postal Service, 115 M.S.P.R.

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Related

Office of Personnel Management v. Richmond
496 U.S. 414 (Supreme Court, 1990)
Soroka v. Office of Personnel Management
557 F. App'x 983 (Federal Circuit, 2014)
Perry v. Merit Systems Protection Bd.
582 U.S. 420 (Supreme Court, 2017)

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Marc Watson v. Office of Personnel Management, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marc-watson-v-office-of-personnel-management-mspb-2024.