Minchih Chen v. National Credit Union Administration

CourtMerit Systems Protection Board
DecidedApril 16, 2024
DocketNY-0752-21-0066-I-1
StatusUnpublished

This text of Minchih Chen v. National Credit Union Administration (Minchih Chen v. National Credit Union 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
Minchih Chen v. National Credit Union Administration, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

MINCHIH JULIE CHEN, DOCKET NUMBER Appellant, NY-0752-21-0066-I-1

v.

NATIONAL CREDIT UNION DATE: April 16, 2024 ADMINISTRATION, Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Elaine Fitch , Esquire, Washington, D.C., for the appellant.

Alex R. Roberson , Alexandria, Virginia, 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 sustained her removal for excessive absence and absence without leave (AWOL). 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 interpretation of statute or regulation

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

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 agency proved its AWOL charge because it properly denied the appellant’s leave without pay (LWOP) request, correct the analytical framework applied to the appellant’s Family and Medical Leave Act of 1993 (FMLA) retaliation claim, and clarify the administrative judge’s findings regarding the appellant’s reasonable accommodation claim and whistleblower reprisal claim, we AFFIRM the initial decision.

BACKGROUND The appellant was employed as a CU-12 Credit Union Examiner with the agency. Initial Appeal File (IAF), Tab 7 at 21. From September 30 to December 12, 2019, the appellant was on FMLA-protected LWOP due to “postpartum related issues,” such as depression, anxiety, and stress. Id. at 59-60, 62, 132-33. After exhausting her FMLA-protected leave, the appellant submitted medical notes on an almost-monthly basis stating that she needed an extension of LWOP to the following month to continue treatment for her medical conditions. Id. at 50-52, 57-59, 81. The agency granted the appellant’s requests, and she was placed in a long-term LWOP status. Id. at 133-37. However, in a letter dated July 17, 2020, the appellant’s supervisor requested more information regarding her ongoing absence, explaining that the agency had granted her 1,248 hours of 3

LWOP and it could no longer tolerate the appellant’s prolonged absence, and ordered her to return to work on July 27, 2020, warning her that failure to do so may result in adverse action, including removal. Id. at 48-49. The appellant responded to the letter, explaining, among other things, that she had to strictly isolate because she suffers from chronic obstructive pulmonary disease (COPD) and was at high risk for COVID-19; that the self-isolation exacerbated her depression, anxiety, and stress; and that she would probably not be able to return to work until 2021 due to COVID-19. Id. at 44-45. In response, the agency granted the appellant LWOP through July 31, 2020, but ordered her to return to duty on August 3, 2020. Id. at 40. When the appellant did not return to duty on August 3, 2020, the agency started charging her with AWOL, and then proposed her removal on October 26, 2020, based on charges of excessive absence and AWOL. Id. at 28-32, 137-38. After reviewing the evidence, including a medical note from the appellant stating that she could return to work in September 2021, the deciding official sustained both charges, removing the appellant effective February 15, 2021. Id. at 21-27, 33. The appellant filed a Board appeal, and after holding a hearing, the administrative judge issued an initial decision affirming the removal. IAF, Tab 31, Initial Decision (ID). First, the administrative judge found that the agency proved the merits of both charges, established nexus, and established that removal was within the bounds of reasonableness. ID at 10-31. Next, with respect to the appellant’s affirmative defenses, the administrative judge found that she failed to establish her claim of disability discrimination because she failed to establish that she was an otherwise qualified individual entitled to reasonable accommodation, and she failed to establish a prima facie case of disability discrimination or that her disability was a motivating factor in her removal. 2 ID at 32-43. With respect to the appellant’s claim of FMLA 2 The administrative judge also found that, even if the appellant had established a prima facie case of disability discrimination, the agency articulated a legitimate nondiscriminatory reason for her removal, and she had failed to establish that this 4

retaliation, the administrative judge found that the appellant failed to establish there was a causal connection between her invocation of FMLA-protected leave and her removal. ID at 43-45. Finally, regarding the appellant’s whistleblower reprisal claim, the administrative judge found that the appellant failed to establish that she engaged in a protected activity when she requested reasonable accommodation, and she failed to establish that she made a protected disclosure in two emails sent to the deciding official on July 20, 2020, and July 31, 2020. ID at 45-49. The appellant filed a petition for review arguing, among other things, that the agency’s charges should not have been sustained 3 and that the agency failed to reasonably accommodate her and retaliated against her for whistleblowing. Petition for Review (PFR) File, Tab 9 at 18-27, 29-36. The agency filed a response in opposition to the appellant’s petition for review, and the appellant replied to the response. 4 PFR File, Tabs 13-14.

reason was mere pretext for discrimination. ID at 43. 3 Although the appellant’s subheading in her petition for review appears to challenge the administrative judge’s finding of nexus, the contents of the argument challenged the merits of the agency’s charges. PFR File, Tab 9 at 24-27. Nevertheless, to the extent that the appellant challenges the administrative judge’s finding of nexus, it is well established that attendance-related misconduct impacts the efficiency of the service, and thus, the agency established nexus. See Davis v. Veterans Administration, 792 F.2d 1111, 1113 (Fed. Cir. 1986) (finding nexus between the appellant’s prolonged AWOL and the efficiency of the service because absence, by its very nature, disrupts the efficiency of the service).

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Bluebook (online)
Minchih Chen v. National Credit Union Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/minchih-chen-v-national-credit-union-administration-mspb-2024.