Margaret Considine v. Department of the Treasury

CourtMerit Systems Protection Board
DecidedJune 27, 2024
DocketPH-1221-17-0279-W-1
StatusUnpublished

This text of Margaret Considine v. Department of the Treasury (Margaret Considine v. Department of the Treasury) 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
Margaret Considine v. Department of the Treasury, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

MARGARET M. CONSIDINE, DOCKET NUMBER Appellant, PH-1221-17-0279-W-1

v.

DEPARTMENT OF THE TREASURY, DATE: June 27, 2024 Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Richard R. Renner , Esquire, Chapel Hill, North Carolina, for the appellant.

Neil M. Robinson , Esquire, and Amber Melton , Esquire, Washington, D.C., for the agency.

Lamine Hendrix , Esquire, Washington, D.C., for amicus curiae, the Office of Special Counsel.

BEFORE

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

*Member Kerner recused himself and did not participate in the adjudication of this appeal.

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

FINAL ORDER

The agency has filed a petition for review, and the appellant has filed a cross petition for review of the initial decision, which granted corrective action in this individual right of action (IRA) appeal. For the reasons discussed below, we DENY the appellant’s motion to dismiss the agency’s petition for review for failure to comply with an interim relief order, GRANT the agency’s petition for review, DENY the appellant’s cross petition for review, REVERSE the initial decision, and DENY the appellant’s request for corrective action.

BACKGROUND By notice dated June 22, 2016, the agency terminated the appellant from her excepted-service position as a Bank Examiner with the Office of the Comptroller of the Currency (OCC) in New Jersey during her trial period due to inadequate performance, effective close of business on June 23, 2016. Initial Appeal File (IAF), Tab 5 at 27, Tab 6 at 4. Thereafter, the appellant filed a complaint with the Office of Special Counsel (OSC) alleging that the agency terminated her in retaliation for whistleblowing disclosures. IAF, Tab 1 at 13-14. By notice dated March 31, 2017, OSC notified her that it was closing her complaint without action and summarized her disclosures as follows: 1. In early February 2016, you disclosed to two supervisors that a bond on a certain bank’s trial balance sheet appeared to violate the Volcker rule 2 and to present a conflict of interest. 2. On several occasions beginning in February 2016, you complained to management officials that loud conversations and other commotion in the examination rooms disrupted your efforts to concentrate on your work assignments. 3. In June 2016, you reported to management officials that the Functional Examiner-in-Charge [(FEIC)] provided false information to a bank official by stating that the OCC had consented to a proposal to backdate a legal document. 2 In relevant part, the Volcker Rule prohibits banks from engaging in certain investment activity using customer deposits. See 12 U.S.C. § 1851; 12 C.F.R. part 44; IAF, Tab 5 at 11, Tab 11 at 11. 3

4. On two separate occasions in June 2016, you informed the [FEIC] that commercial real estate loans had been financed without any evidence that hazardous environmental conditions noted in a phase one assessment had been addressed or remedied. Id. at 13. The appellant timely filed the instant IRA appeal arguing that the agency terminated her from her position in retaliation for the disclosures identified in OSC’s closure letter. IAF, Tab 1 at 6, Tab 11 at 23-29. The administrative judge found that the appellant established jurisdiction over her appeal and held the hearing she requested. IAF, Tabs 18, 42-43. In the initial decision, the administrative judge found that disclosure 3, which pertained to the FEIC falsely informing a bank that the OCC consented to its backdating proposal, was protected and that the appellant engaged in protected activity by filing a prior Board appeal. IAF, Tab 46, Initial Decision (ID) at 8-9, 11. He found that disclosures 2 and 4 were not protected because a reasonable person would not believe that a noisy workplace or a loan collateralized by real property that may not have been properly appraised evidenced one of the categories of wrongdoing covered by the Whistleblower Protection Enhancement Act (WPEA). ID at 8-9. In addition, he found that disclosures 1 and 4 were not protected because, pursuant to Aviles v. Merit Systems Protection Board, 799 F.3d 457 (5th Cir. 2015), disclosures of misconduct by non-Governmental entities are not covered by the WPEA unless there is an allegation of Government complicity in the private wrongdoing. ID at 7-8. The administrative judge concluded that the appellant’s third disclosure and prior Board appeal contributed to the agency’s decision to terminate her, and that the agency failed to show by clear and convincing evidence that it would have taken the same action in the absence of her protected activity. ID at 12-14. Accordingly, he granted the appellant’s request for corrective action and ordered the agency to reinstate her. ID at 14. The initial decision did not contain a statement on interim relief. 4

The agency has filed a petition for review of the initial decision, the appellant has responded, and the agency has replied. Petition for Review (PFR) File, Tabs 1, 5, 7. The appellant has filed a motion to dismiss the agency’s petition for review on the grounds that it did not provide her interim relief, and the agency has responded in opposition to this motion. PFR File, Tabs 3-4. The appellant has also filed a cross petition for review, and the agency has responded. 3 PFR File, Tabs 5, 8. OSC has filed an amicus curiae brief in which it argues that the Board should hold, contrary to Aviles, that the WPEA broadly protects Federal employee disclosures of wrongdoing by non-Governmental entities or, in the alternative, that such disclosures are protected if they implicate the Government’s good name and interests, rather than only when there are allegations of Government complicity in the private wrongdoing. 4 PFR File, Tab 12. The agency and the appellant have responded to OSC’s amicus brief. 5 PFR File, Tabs 14-15.

3 On December 4, 2018, after the record closed on review, the appellant filed a motion for leave to reply to the agency’s response to her cross petition for review. PFR File, Tab 10. She argues that this additional pleading is needed to clarify the applicability of Aviles to this appeal, to respond to the agency’s argument that it had no duty to provide interim relief, and to explain that her request for additional witnesses is conditional upon the agency prevailing on its petition for review. PFR File, Tab 1 at 4-5. However, as the Office of the Clerk of the Board advised her, the Board’s regulations do not provide for a reply to a response to a cross petition for review and generally preclude consideration of evidence or argument submitted after the close of the record absent a showing that it was not readily available before the record closed. PFR File, Tab 9; 5 C.F.R. § 1201.114(a)(5), (k).

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Margaret Considine v. Department of the Treasury, Counsel Stack Legal Research, https://law.counselstack.com/opinion/margaret-considine-v-department-of-the-treasury-mspb-2024.