Michael Sopko v. Department of Veterans Affairs

2026 MSPB 1
CourtMerit Systems Protection Board
DecidedJanuary 22, 2026
DocketDC-4324-21-0052-I-4
StatusPublished

This text of 2026 MSPB 1 (Michael Sopko v. Department of Veterans Affairs) 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 Sopko v. Department of Veterans Affairs, 2026 MSPB 1 (Miss. 2026).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD 2026 MSPB 1 Docket No. DC-4324-21-0052-I-4

Michael Sopko, Appellant, v. Department of Veterans Affairs, Agency. January 22, 2026

Brian Lawler , Esquire, San Diego, California, for the appellant.

Christian Piatt , Esquire, Baltimore, Maryland, for the agency.

BEFORE

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

OPINION AND ORDER

¶1 The appellant has filed a petition for review of the initial decision, which denied his request for corrective action under the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA) (codified as amended at 38 U.S.C. §§ 4301-4335). For the reasons discussed below, we GRANT the petition for review, REVERSE the initial decision as to the appellant’s entitlement to differential pay under 5 U.S.C. § 5538(a), and ORDER corrective action under that provision. We otherwise AFFIRM the initial decision. 2

BACKGROUND ¶2 The appellant is an agency employee and a member of the U.S. Air Force Reserve. Sopko v. Department of Veterans Affairs, MSPB Docket No. DC-4324-21-0052-I-1, Initial Appeal File (IAF), Tab 6 at 7, Tab 8 at 17, 19. Pursuant to 10 U.S.C. § 12301(d), he was ordered to active duty to complete Officer Training School at Maxwell Air Force Base in Montgomery, Alabama, from August 25 until October 21, 2020. IAF, Tab 6 at 7-9. ¶3 Based on his active-duty service, the appellant requested that the agency pay him differential pay pursuant to 5 U.S.C. § 5538(a), provide him 22 work days of additional military leave under 5 U.S.C. § 6323(b)(2)(B), and allow him 5 days of excused absence upon his return to duty pursuant to a November 14, 2003 memorandum issued by then-President George W. Bush. IAF, Tab 1 at 9-11; Sopko v. Department of Veterans Affairs, MSPB Docket No. DC-4324-21-0052-I-4, Appeal File (I-4 AF), Tab 6 at 4-10. After the agency denied these requests, the appellant filed a Board appeal alleging that the denials violated USERRA. IAF, Tab 1 at 8-9, 11-12, Tab 8 at 28-31. ¶4 Following the appellant’s withdrawal of his hearing request, the administrative judge issued an initial decision on the written record denying the appellant’s request for corrective action. I-4 AF, Tab 11, Initial Decision (ID) at 1, 3, 16. As to the appellant’s claims under 5 U.S.C. §§ 5538(a) and 6323(b), the administrative judge found that the appellant’s service was not in support of a contingency operation under 10 U.S.C. § 101(a)(13) as necessary for differential pay and up to 22 days of leave. ID at 5, 10-14. The administrative judge further reasoned that the appellant was not entitled to the additional leave provided for under 5 U.S.C. § 6323(b) because he did not meet the statutory prerequisite of qualifying as an “employee” as defined under 5 U.S.C. § 2105. ID at 6-10. The administrative judge also concluded that, in any event, the benefit under section 6323(b) did not entitle an employee to additional leave but merely allowed him to use leave he had otherwise accrued. ID at 13. Finally, as to the 3

appellant’s claim that he was entitled to 5 days of excused absence pursuant to President Bush’s November 14, 2003 memorandum , the administrative judge found that the appellant did not qualify for this benefit because he did not serve in the Global War on Terrorism or in connection with any of the military operations identified in the memorandum, such as Operation Noble Eagle and Operation Enduring Freedom. ID at 15-16. ¶5 The appellant has filed a petition for review in which he disagrees with the administrative judge’s conclusions that, as a matter of law, the appellant is not entitled to the benefits he seeks. Petition for Review (PFR) File, Tab 1 at 7-16. He also argues that, after the record closed below, he was awarded the Global War on Terrorism Service Medal. Id. at 15-16. He argues that this medal proves that his service supported the Global War on Terrorism and a contingency operation. Id. at 16. The agency has filed a response, and the appellant has filed a reply. PFR File, Tabs 3-4. ¶6 The appellant also filed a motion to stay proceedings on review for the U.S. Supreme Court’s anticipated decision in Feliciano v. Department of Transportation. PFR File, Tab 5. After the Court issued its decision in that case, Feliciano v. Department of Transportation, 605 U.S. 38 (2025), he filed a motion to lift the stay of the proceedings, PFR File, Tab 6. Therefore, we need not address the appellant’s motion.

ANALYSIS

The appellant is entitled to differential pay pursuant to 5 U.S.C. § 5538 (a). ¶7 Section 5538(a) of Title 5 “requires the [G]overnment to provide differential pay to a [F]ederal civilian employee reservist when the military orders him to active-duty service ‘under . . . a provision of law referred to in [10 U.S.C. §] 101(a)(13)(B).’” Feliciano, 605 U.S. at 42 (quoting 5 U.S.C. § 5538(a)). Section 101(a)(13)(B), in turn, defines certain types of military operations as “contingency operation[s],” including a catchall category for those that result “in 4

the call or order to, or retention on, active duty . . . under . . . any other provision of law during a war or during a national emergency declared by the President or Congress.” In its decision in Feliciano, which was issued after the initial decision in this case, the U.S. Supreme Court interpreted the term “during” in section 101(a)(13)(B) to mean “contemporaneous with” a national emergency. Feliciano, 605 U.S. at 44-45. The Court rejected the U.S. Court of Appeals for the Federal Circuit’s determination in Adams v. Department of Homeland Security, 3 F.4th 1375, 1379-80 (Fed. Cir. 2021), abrogated by Feliciano, 605 U.S. at 43-56, that differential pay is contingent on “directly . . . serv[ing] in a contingency operation.” Accordingly, to be entitled to differential pay under 5 U.S.C. § 5538(a), an appellant is only required to show that his active -duty service occurred at the same time as a national emergency. ¶8 In light of the Feliciano decision, which was not available to the administrative judge when he issued the initial decision, we reverse the administrative judge’s finding that the appellant was not entitled to differential pay under 5 U.S.C. § 5538(a). Like Mr. Feliciano, the appellant was ordered to active duty under 10 U.S.C. § 12301(d). Feliciano, 605 U.S.

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Bluebook (online)
2026 MSPB 1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-sopko-v-department-of-veterans-affairs-mspb-2026.