Melvin Cosely v. Department of the Army

CourtMerit Systems Protection Board
DecidedApril 3, 2026
DocketDE-3330-25-0129-I-1
StatusUnpublished

This text of Melvin Cosely v. Department of the Army (Melvin Cosely 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
Melvin Cosely v. Department of the Army, (Miss. 2026).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

MELVIN L. COSELY SR., DOCKET NUMBER Appellant, DE-3330-25-0129-I-1

v.

DEPARTMENT OF THE ARMY, DATE: April 3, 2026 Agency.

THIS ORDER IS NONPRECEDENTIAL 1

Melvin L. Cosely Sr ., North Chesterfield, Virginia, pro se.

Leah S. Serrano , Washington, D.C., for the agency.

April Emerson and Larry F. Estrada , Los Angeles, California, for the agency.

BEFORE

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

REMAND ORDER

The appellant has filed a petition for review of the initial decision, which dismissed for lack of jurisdiction his appeal alleging that the agency violated his veteran’s preference under the Veterans Employment Opportunities Act of 1998 (VEOA) when it denied him the opportunity to compete for two vacancies. For

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

the reasons discussed below, we GRANT the appellant’s petition for review, AFFIRM the finding dismissing the appellant’s VEOA claims for lack of jurisdiction, and REMAND the case to the Denver Field Office for further adjudication of the appellant’s Uniformed Services Employment and Reemployment Rights Act of 1994 (codified as amended at 38 U.S.C. §§ 4301-4335) (USERRA) claim in accordance with this Remand Order.

BACKGROUND On January 31, 2025, the administrative judge docketed this appeal concerning the appellant’s allegation that the agency violated his veteran’s preference under VEOA and USERRA when it denied him the opportunity to compete. Initial Appeal File (IAF), Tab 2. The administrative judge issued an order informing the appellant of the criteria required to meet his burden of proving jurisdiction over a VEOA appeal, including the exhaustion and timeliness prerequisites that must be fulfilled to pursue a VEOA claim with the Board. IAF, Tab 4. In response, the appellant alleged that he was denied the opportunity to compete in 2017 under vacancy announcement NCFV170804102338 and in 2019 under vacancy announcement NCFV183216989095S, and that he believed the Board had jurisdiction over the appeal under USERRA and VEOA. IAF, Tab 5 at 8, 19, Tab 8 at 15. Without holding the appellant’s requested hearing, the administrative judge dismissed the appeal for lack of jurisdiction. IAF, Tabs 5, 7-8, Tab 9, Initial Decision (ID) at 1, 6. She reasoned that the appellant had previously filed an appeal in December 2019 alleging that the agency violated his veteran’s preference under VEOA when it denied him the opportunity to compete in 2017 under vacancy announcement NCFV170804102338, and in 2019 under vacancy announcement NCFV183216989095S. ID at 5; Cosely v. Department of the Army, MSPB Docket No. DC-3330-20-0207-I-1, Initial Appeal File (0207 IAF), Tab 1 at 10. On April 21, 2020, the administrative judge assigned to the appeal 3

issued an initial decision dismissing for lack of jurisdiction the appellant’s claim as to the 2017 vacancy announcement because the appellant had not established that he had exhausted his administrative remedy with the Department of Labor (DOL) as to that vacancy. 0207 IAF, Tab 6 at 1, 5-6, Tab 9, Initial Decision (0207 ID) at 2 n.1. As to the appellant’s claim concerning the 2019 vacancy announcement, the administrative judge found that the Board had jurisdiction over the appeal but denied the appellant’s claim for corrective action under VEOA on the merits. 0207 IAF, Tab 6 at 2-3; 0207 ID at 2-4. That initial decision became the final decision of the Board on May 26, 2020, when neither party petitioned for review. 0207 ID at 4. Thus, the administrative judge here found that the appellant’s claim as to the 2017 vacancy announcement was barred by collateral estoppel and that his claim as to the 2019 vacancy announcement was barred by res judicata. ID at 4-6. The appellant has filed a petition for review, arguing that the preclusive doctrines of collateral estoppel and res judicata do not apply. Petition for Review (PFR) File, Tab 1 at 23-31, 33. He argues that the Board has jurisdiction over this appeal as a mixed case. Id. at 5, 17-20. He alleges that the agency’s actions constitute discrimination or other prohibited personnel practices and denied him due process. Id. at 6, 9-11, 18, 30. Lastly, he argues that the administrative judge did not consider his claim under USERRA. Id. at 6, 29. The agency has responded, and the appellant has replied. PFR File, Tabs 3-4.

DISCUSSION OF ARGUMENTS ON REVIEW

The administrative judge correctly dismissed the appellant’s claims under VEOA.

The 2017 vacancy announcement is barred by collateral estoppel. Collateral estoppel, or issue preclusion, is appropriate when the issue is identical to that involved in the prior action, the issue was actually litigated in the prior action, the determination of the issue in the prior action was necessary to the resulting judgment, and the party against whom issue preclusion is sought had 4

a full and fair opportunity to litigate the issue in the prior action, either as a party to the earlier action or as one whose interests were otherwise fully represented in that action. Hau v. Department of Homeland Security, 123 M.S.P.R. 620, ¶ 13 (2016), aff’d sub nom. Bryant v. Merit Systems Protection Board , 878 F.3d 1320 (Fed. Cir. 2017). The “actually litigated” element is satisfied when the issue was “properly raised by the pleadings, was submitted for determination, and was determined.” Johnson v. Department of the Air Force, 92 M.S.P.R. 370, ¶ 13 (2002) (quoting Banner v. United States, 238 F.3d 1348, 1354 (Fed. Cir. 2001). The Board has held that collateral estoppel may be grounds for dismissing an appeal for lack of jurisdiction if a jurisdictional determination in a prior decision is afforded collateral estoppel effect and the appellant provides no other valid basis of Board jurisdiction. Noble v. U.S. Postal Service, 93 M.S.P.R. 693, ¶ 11 (2003). Here, the administrative judge correctly found that both appeals decided the same jurisdictional issue necessary to determining whether the Board has jurisdiction over the appellant’s claim that he was denied the opportunity to compete under VEOA for the 2017 vacancy announcement NCFV170804102338, i.e., whether the appellant exhausted his administrative remedy by filing a complaint with DOL. ID at 5-6; 0207 IAF, Tab 6 at 1, 5-6; 0207 ID at 2 n. 1. She also correctly determined that the issue was actually litigated in the prior appeal because the administrative judge assigned to the appeal provided the appellant with notice of his burden of establishing jurisdiction over his VEOA appeal, including the exhaustion and timeliness requirements; both parties were given an opportunity to respond; and the issue was determined when the administrative judge found that the appellant had not exhausted his 2017 claim with DOL. 0207 IAF, Tab 2 at 2-3, Tab 6 at 1, 5-6; 0207 ID at 2 n. 1. Also, as noted above, the initial decision dismissing the appellant’s 2017 claim for lack of jurisdiction became final when neither party petitioned for review.

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Melvin Cosely v. Department of the Army, Counsel Stack Legal Research, https://law.counselstack.com/opinion/melvin-cosely-v-department-of-the-army-mspb-2026.