Phillip Spyropoulos v. Social Security Administration

CourtMerit Systems Protection Board
DecidedApril 17, 2024
DocketNY-0752-17-0121-I-1
StatusUnpublished

This text of Phillip Spyropoulos v. Social Security Administration (Phillip Spyropoulos 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
Phillip Spyropoulos v. Social Security Administration, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

PHILLIP SPYROPOULOS, DOCKET NUMBER Appellant, NY-0752-17-0121-I-1

v.

SOCIAL SECURITY DATE: April 17, 2024 ADMINISTRATION, Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Robert Glazer , Esquire, and Stephen Goldenzweig , Esquire, Houston, Texas, for the appellant.

Vernon Norwood , Esquire, New York, New York, for the agency.

John Kelly , Esquire, and David B. Myers , Esquire, Baltimore, Maryland, 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 his removal. 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petitions such as this one only in the following circumstances: the initial decision contains erroneous findings of 1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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 (1) VACATE the administrative judge’s finding that the agency proved specification 4 under its lack of candor charge; (2) incorporate the correct standards for the appellant’s claims of disparate treatment disability discrimination and retaliation for requesting reasonable accommodation; (3) VACATE the administrative judge’s alternative finding that the agency proved by clear and convincing evidence that it would have removed the appellant in the absence of his alleged protected disclosures; and (4) supplement the administrative judge’s analysis on the appellant’s claim of disparate penalties, we AFFIRM the initial decision.

BACKGROUND The appellant was a GS-12 Attorney Advisor with the agency’s Office of Disability, Adjudication, and Review in Newark, New Jersey. Initial Appeal File (IAF), Tab 8 at 16. On October 27, 2016, the agency proposed his removal based on the following four charges: (1) failure to safeguard Personally Identifiable Information (PII); (2) lack of candor; (3) misuse of position; and (4) misuse of Government property. IAF, Tab 7 at 5-16. By letter dated March 20, 2017, the 3

deciding official sustained the proposed removal. Id. at 18-37. The appellant’s removal was effective that same date. IAF, Tab 8 at 16. The appellant subsequently filed a Board appeal challenging the basis for the removal action and raising numerous affirmative defenses. IAF, Tab 1 at 7; Tab 43 at 2-3. Following a hearing, the administrative judge issued an initial decision affirming the agency’s action. IAF, Tab 52, Initial Decision (ID). Regarding Charge 1, failure to safeguard PII, the administrative judge found that the agency proved 29 of the 32 specifications underlying this charge and, therefore, she sustained the charge. 2 ID at 8-19. The administrative judge also sustained Charge 2, lack of candor, finding that the agency established all 4 supporting specifications. ID at 19-26. The administrative judge also sustained Charge 3, misuse of position, and Charge 4, misuse of Government property, finding that the agency established the 1 specification underlying the former charge and both specifications underlying the latter charge. ID at 27-33. As to the appellant’s affirmative defenses, the administrative judge found that he failed to establish his claims of harmful procedural error, due process violation, disability discrimination based on failure to accommodate and disparate treatment, retaliation for requesting reasonable accommodation, retaliation for filing grievances, and whistleblower reprisal. 3 ID at 33-61. Lastly, the 2 While the administrative judge noted at the end of her analysis of Charge 1 that she was sustaining 28 of the 32 specifications, ID at 19, this is a typographical error. Specifically, the administrative judge found that the agency failed to sustain only 3 of the 32 specifications underlying this charge and noted earlier in her analysis that the agency established 29 of the specifications under this charge. ID at 17-18. 3 In considering the appellant’s allegation of reprisal for filing grievances, the administrative judge applied the general reprisal standard. ID at 46-47. However, the statutory changes made as part of the Whistleblower Protection Enhancement Act of 2012 (WPEA) significantly narrowed the scope of cases to which this standard applies. See Alarid v. Department of the Army, 122 M.S.P.R. 600, ¶ 15 & n.7 (2015). Specifically, the general reprisal standard is inapplicable to claims that are subject to the burden-shifting framework set forth in 5 U.S.C. § 1221(e), such as a reprisal claim under 5 U.S.C. § 2302(b)(9)(A)(i), which makes it a prohibited personnel practice “to take or fail to take, or threaten to take or fail to take, any personnel action against any employee or applicant for employment because of the exercise of any appeal, complaint, 4

administrative judge found that the agency established the nexus requirement and that the penalty of removal was reasonable under the circumstances. ID at 61-66. The appellant has filed a petition for review. Petition for Review (PFR) File, Tab 5. On review, he contends that the agency failed to prove that the emails at issue under Charge 1 contained PII, that the administrative judge failed to apply the proper legal standard to Charge 2, that the administrative judge did not apply the proper factors in conducting her penalty analysis, and that the administrative judge erred in finding that the appellant did not establish his affirmative defense of whistleblower reprisal. 4 PFR File, Tab 5 at 9-28. The agency has filed a response in opposition to the appellant’s petition. PFR File, Tab 7.

DISCUSSION OF ARGUMENTS ON REVIEW The appellant has failed to provide a basis for disturbing the administrative judge’s findings regarding Charge 1, failure to safeguard PII. Under its charge of failure to safeguard PII, the agency charged that, on 32 separate instances, the appellant sent emails containing PII of claimants who or grievance right granted by any law, rule, or regulation, with regard to remedying a violation” of 5 U.S.C. § 2302(b)(8). Clay v. Department of the Army, 123 M.S.P.R. 245, ¶ 10 (2016).

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