Michael Keegan v. Social Security Administration

CourtMerit Systems Protection Board
DecidedMay 20, 2024
DocketPH-1221-15-0121-W-1
StatusUnpublished

This text of Michael Keegan v. Social Security Administration (Michael Keegan v. Social Security Administration) 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
Michael Keegan v. Social Security Administration, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

MICHAEL J. KEEGAN, DOCKET NUMBER Appellant, PH-1221-15-0121-W-1

v.

SOCIAL SECURITY DATE: May 20, 2024 ADMINISTRATION, Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Daniel E. Kenney , Esquire, Chevy Chase, Maryland, for the appellant.

Edward C. Tompsett , Esquire, Philadelphia, Pennsylvania, for the agency.

Joseph Langkamer , Esquire, Seattle, Washington, for the agency.

BEFORE

Cathy A. Harris, Chairman Raymond A. Limon, Vice Chairman

FINAL ORDER

The appellant has filed a petition for review of the initial decision, which denied his request for corrective action. 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the initial decision contains erroneous findings of material fact; the initial decision is based on an erroneous 1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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

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 (1) reflect the proper analysis for determining whether a hostile work environment constitutes a personnel action under 5 U.S.C. § 2302(a)(2)(A), and (2) find that two of the appellant’s disclosures regarding the National Computing Center (NCC) and the National Support Center (NSC) were protected disclosures under 5 U.S.C. § 2302(b)(8), we AFFIRM the initial decision.

BACKGROUND The appellant was an ES-0342 Associate Commissioner for the agency’s Office of Facilities and Supply Management (OFSM). Initial Appeal File (IAF), Tab 1 at 2, Tab 12 at 39. On May 21, 2013, the appellant was notified by the Deputy Regional Commissioner that he would be investigated due to equal employment opportunity (EEO) related complaints against him. IAF, Tab 18 at 21. The letter also informed him that because “[t]he [Equal Employment Opportunity Commission (EEOC)] also requires the agency, under certain circumstances, to take temporary measures to separate the parties during the investigation,” he would be detailed to the Assistant Associate Commissioner position in the agency’s Office of Central Operations. Id. On July 31, 2014, he retired from the agency. IAF, Tab 12 at 39. 3

Thereafter, the appellant filed an individual right of action (IRA) appeal with the Board in which he alleged that, in retaliation for his protected whistleblowing, the agency removed his supervisory duties, detailed him to a position with fewer responsibilities, and ultimately forced him to retire. 2 IAF, Tab 1 at 143-45, Tab 6 at 15-16, Tab 88 at 13. The administrative judge found that the Board had jurisdiction over the appeal and granted a hearing on the merits of the appeal. IAF, Tab 28. Following a 4-day hearing that was conducted by video-conference, the administrative judge issued an initial decision denying the appellant’s request for corrective action. IAF, Tab 106, Initial Decision (ID). The administrative judge first found that the appellant failed to establish a prima facie case of whistleblower reprisal. In that regard, he found that the appellant raised six disclosures in both his Office of Special Counsel (OSC) complaint and his Board appeal. ID at 3. The first three disclosures concerned the agency’s decision to replace the existing NCC with a new NSC. Id. In his fourth disclosure, the appellant contended that the agency had awarded hundreds of millions of dollars in poorly developed and in some cases unneeded projects, including work being performed on the agency’s Wabash office building construction project. ID at 3, 8. In his fifth and sixth disclosures, the appellant alleged that OFSM

2 The administrative judge noted that the appellant filed his Office of Special Counsel (OSC) complaint prior to his retirement and that, in his OSC complaint, the appellant only claimed that the agency retaliated against him by subjecting him to a hostile work environment. IAF, Tab 106, Initial Decision at 2. Thus, the voluntariness of the appellant’s retirement is not at issue in this appeal. In addition, we note that the appellant’s retired status has no effect on his ability to file an IRA appeal. In Guzman v. Office of Personnel Management, 53 F. App’x 927, 929-30 (Fed. Cir. 2002), our reviewing court held that the Whistleblower Protection Act permits a former employee to bring a claim “as to disclosures made, and retaliation taken, during the period that the complainant was an employee or applicant.” The Board may follow nonprecedential decisions by the U.S. Court of Appeals for the Federal Circuit to the extent that we find them to be persuasive. Weed v. Social Security Administration, 113 M.S.P.R. 221, ¶ 11 (2010). 4

employees were not complying with the agency’s overtime and travel policies. ID at 3. The administrative judge found that the appellant failed to establish that he made disclosures (1)-(4) prior to the alleged acts of retaliation. ID at 24-26. He therefore found that these disclosures could not have been contributing factors in the agency’s alleged actions. ID at 26. In addition, the administrative judge found that disclosures (2) and (4) did not constitute protected disclosures. ID at 26-28. Regarding disclosures (5) and (6), the administrative judge found that the appellant failed to establish that these disclosures were a contributing factor in a personnel action. ID at 28-29. As to the alleged personnel actions, the administrative judge found that the appellant was raising a claim that he had been subjected to a hostile work environment. ID at 13. He found that the agency investigation into the appellant’s purported EEO violation and the appellant’s detail to a position with allegedly fewer duties may have contributed to a hostile work environment. Id. However, he determined that the appellant’s hostile work environment claim was not actionable because the appellant failed to establish contributing factor. Id. Because the administrative judge determined that the appellant did not meet his burden of proving that any of the alleged protected disclosures were a contributing factor in any of the personnel actions at issue, he found that there was no need to address whether the agency could have shown by clear and convincing evidence that it would have taken any of these actions in the absence of the alleged protected disclosures. ID at 30-31.

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Michael Keegan v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-keegan-v-social-security-administration-mspb-2024.