Maria DeAngelo v. Department of the Army

CourtMerit Systems Protection Board
DecidedNovember 19, 2025
DocketPH-0752-23-0311-I-1
StatusUnpublished

This text of Maria DeAngelo v. Department of the Army (Maria DeAngelo 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
Maria DeAngelo v. Department of the Army, (Miss. 2025).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

MARIA DEANGELO, DOCKET NUMBER Appellant, PH-0752-23-0311-I-1

v.

DEPARTMENT OF THE ARMY, DATE: November 19, 2025 Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Maria DeAngelo , Pittston Township, Pennsylvania, pro se.

Shanna Walker Williamson , Esquire, and David Tomaszewski , Tobyhanna, Pennsylvania, for the agency.

BEFORE

Henry J. Kerner, Vice Chairman James J. Woodruff II, Member

FINAL ORDER

The appellant has filed a petition for review of the initial decision, which sustained her removal based on charges of conduct unbecoming a Federal employee and insubordination. Generally, we grant petitions such as this one only in the following circumstances: the initial decision contains erroneous findings of

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

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. Except as expressly MODIFIED to find that the appellant made a prima facie case of whistleblower reprisal and to SUPPLEMENT the administrative judge’s discussion of the agency’s burden to show by clear and convincing evidence that it would have removed the appellant even in the absence of her protected disclosure, we AFFIRM the initial decision.

BACKGROUND The appellant was employed as a program support assistant, GS-06, with the agency’s Tobyhanna Army Depot in Tobyhanna, Pennsylvania. Initial Appeal File (IAF), Tab 4 at 24. Effective June 30, 2023, the agency removed her based on charges of conduct unbecoming a Federal employee (three specifications) and insubordination (one specification). Id. at 25-28, 56-62. The alleged misconduct underlying the conduct unbecoming charge involves the appellant’s refusal to take on assigned duties and to follow orders, her use of disrespectful, erratic, and verbally abusive language with her supervisor and coworkers, and her failure to cooperate or “take any guidance” from the Directorate Secretary. Id. at 56-59. The alleged misconduct underlying the insubordination charge involves the appellant’s failure to provide information to a coworker despite her supervisor’s instruction to do so. Id. at 59. 3

The appellant challenged her removal on appeal to the Board and raised an affirmative defense of whistleblower reprisal. IAF, Tab 1 at 4-5, Tab 8 at 4. 2 Specifically, she claimed that she disclosed that common access cards (CAC) were being issued to Government contractors without proper vetting and that the agency removed her in reprisal for her disclosure. 3 IAF, Tab 1 at 5, Tab 8 at 4. After holding the appellant’s requested hearing, the administrative judge issued an initial decision finding that the agency proved all of the specifications, and thus, all of the charges by preponderant evidence. IAF, Tab 14, Initial Decision (ID) at 6-8. He also found that the penalty of removal promotes the efficiency of the service and is reasonable. ID at 13-15. Regarding the appellant’s affirmative defense of whistleblower reprisal, the administrative judge found that, although the appellant proved that she made a protected disclosure, she failed to prove that it was a contributing factor in the agency’s decision to remove her because she did not prove that either the proposing or deciding official was aware

2 The appellant stated below that she filed an equal employment opportunity complaint against her supervisor. IAF, Tab 8 at 4-9. The administrative judge did not construe the appellant’s assertions as an affirmative defense of reprisal in the summary of the prehearing conference. IAF, Tab 9. Nor did the appellant object to the omission, despite being given an opportunity to do so. Id. at 3. The appellant did not raise this as an affirmative defense in her petition for review. Petition for Review File, Tab 1. Accordingly, we do not address it further here. See Thurman v. U.S. Postal Service, 2022 MSPB 21, ¶ 18 (setting forth a nonexhaustive list of factors for the Board to consider when determining whether an appellant will be deemed to have waived or abandoned an affirmative defense). 3 In addition to asserting that she disclosed that CACs were being issued to contractors without proper vetting, which is a claim to be considered under 5 U.S.C. § 2302(b)(8), IAF, Tab 1 at 5, the appellant also stated that she “refused to commit an illegal act of issuing . . . CACs without vetting,” which is a claim to be considered under 5 U.S.C. § 2302(b)(9)(D), IAF, Tab 8 at 4. Below, the administrative judge construed the appellant’s claim solely as an allegation of a protected disclosure under section 2302(b) (8). IAF, Tab 14, Initial Decision at 9-10. The outcome of this affirmative defense, or the appeal as a whole, would not change based on an interpretation of the claim under section 2302(b)(9)(D). Additionally, the appellant has not challenged the administrative judge’s interpretation of this affirmative defense, and, given the outcome here, we discern no reason to disturb it. 4

of her protected disclosure. ID at 10-12. Accordingly, the administrative judge affirmed the appellant’s removal. The appellant has filed a petition for review, asserting that the administrative judge incorrectly found that the proposing and deciding officials lacked knowledge of her protected disclosure. Petition for Review (PFR) File, Tab 1 at 4. The agency has responded to the appellant’s petition for review, and the appellant has replied. PFR File, Tabs 3-4. 4

DISCUSSION OF ARGUMENTS ON REVIEW Although the appellant’s claims on review are limited to her whistleblower reprisal affirmative defense, a brief discussion of the administrative judge’s findings regarding the charges, nexus, and reasonableness of the penalty of removal is helpful context for subsequent discussion of her whistleblower reprisal claim. As such, we briefly discuss those issues first.

The administrative judge correctly sustained the charges, found that a nexus exists between the removal action and the efficiency of the service, and concluded that the penalty of removal is reasonable.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Pedeleose v. Department of Defense
343 F. App'x 605 (Federal Circuit, 2009)
Gebhardt v. Dept. Of the Air Force
180 F. App'x 951 (Federal Circuit, 2006)
Stanley B. Parker v. United States Postal Service
819 F.2d 1113 (Federal Circuit, 1987)
Rokki Knee Carr v. Social Security Administration
185 F.3d 1318 (Federal Circuit, 1999)
Todd R. Haebe v. Department of Justice
288 F.3d 1288 (Federal Circuit, 2002)
Whitmore v. Department of Labor
680 F.3d 1353 (Federal Circuit, 2012)
Perry v. Merit Systems Protection Bd.
582 U.S. 420 (Supreme Court, 2017)
Cathy Covington v. Department of the Interior
2023 MSPB 5 (Merit Systems Protection Board, 2023)
Gary Thurman v. United States Postal Service
2022 MSPB 21 (Merit Systems Protection Board, 2022)
Timothy Skarada v. Department of Veterans Affairs
2022 MSPB 17 (Merit Systems Protection Board, 2022)
Javier Soto v. Department of Veterans Affairs
2022 MSPB 6 (Merit Systems Protection Board, 2022)
Aimee Karnes v. Department of Justice
2023 MSPB 12 (Merit Systems Protection Board, 2023)
Mikhail Semenov v. Department of Veterans Affairs
2023 MSPB 16 (Merit Systems Protection Board, 2023)
Janie Young v. Department of Homeland Security
2024 MSPB 18 (Merit Systems Protection Board, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
Maria DeAngelo v. Department of the Army, Counsel Stack Legal Research, https://law.counselstack.com/opinion/maria-deangelo-v-department-of-the-army-mspb-2025.