Rafael Arroyo v. Social Security Administration

CourtMerit Systems Protection Board
DecidedApril 2, 2024
DocketCB-7121-21-0018-V-1
StatusUnpublished

This text of Rafael Arroyo v. Social Security Administration (Rafael Arroyo 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
Rafael Arroyo v. Social Security Administration, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

RAFAEL ARROYO, DOCKET NUMBER Appellant, CB-7121-21-0018-V-1

v.

SOCIAL SECURITY DATE: April 2, 2024 ADMINISTRATION, Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Suzanne Pillari , Esquire, Syracuse, New York, for the appellant.

Fergus Kaiser , Esquire, New York, New York, for the agency.

BEFORE

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

FINAL ORDER

The appellant has filed a petition for review of an arbitration decision that mitigated his removal to a time-served suspension. For the reasons set forth below, we DISMISS the request for review for lack of jurisdiction.

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

BACKGROUND Effective October 11, 2018, the agency removed the appellant from his position as a Claims Specialist based on the charges of conduct unbecoming of a Federal employee and absence without official leave. Request for Review (RFR) File, Tab 1 at 34-42. The appellant’s union filed a grievance on his behalf, which the agency denied, and the union invoked arbitration. Id. at 43-52. On June 22, 2021, the arbitrator issued an award finding that the agency did not have just cause to remove the appellant and ordering the agency to reinstate the appellant, with the time between his removal and reinstatement to be considered a disciplinary suspension with no back pay. Id. at 71-79. On July 22, 2021, the appellant filed the instant request for review of the arbitrator’s award. Id. at 1-15. The appellant asserts, among other things, that the Board has jurisdiction to review the arbitration decision because he alleged reprisal and because he raised issues under Article 18 of his collective bargaining agreement (CBA), entitled “Equal Employment Opportunity,” on his “Standard Grievance Form,” “during testimony,” and “in the Union’s requested findings in the associated Post-Hearing Brief.” Id. at 9-11, 43-45, 53-70, 80-89. The agency has filed a response asserting, among other things, that the Board lacks jurisdiction over this matter because the appellant failed to raise allegations of discrimination before the arbitrator and has not even identified the type of discrimination he is claiming, and because his claim of reprisal is not covered. RFR File, Tab 4 at 6-10.

ANALYSIS As explained in our acknowledgement order, the appellant has the burden of proving by preponderant evidence that the Board has jurisdiction over his request for review. RFR File, Tab 2 at 3; see 5 C.F.R. § 1201.56(b)(2)(i)(A). As we further explained, the Board has jurisdiction over a request for review of an arbitration decision if (1) the subject matter of the grievance is one over which 3

the Board has jurisdiction; (2) the appellant either (i) raised a claim of discrimination under 5 U.S.C. § 2302(b)(1) with the arbitrator in connection with the underlying action, or (ii) raises a claim of discrimination in connection with the underlying action under 5 U.S.C. § 2302(b)(1) for the first time with the Board if such allegations could not be raised in the negotiated grievance procedure; and (3) a final decision has been issued. RFR File, Tab 2 at 2; see Jones v. Department of Energy, 120 M.S.P.R. 480, ¶ 8 (2013), aff’d, 589 F. App’x 972 (Fed. Cir. 2014); see 5 C.F.R. § 1201.155(a)(1), (c). Here, we find that conditions (1) 2 and (3) are satisfied. RFR File, Tab 1 at 44, 73-79. However, we conclude that the appellant failed to meet his burden as to condition (2). As noted above, the appellant alleges that he raised a claim of discrimination before the arbitrator by raising Article 18 of the CBA on his “Standard Grievance Form,” during testimony, and in his post-hearing brief. Id. at 10, 43-45, 53-70. But the appellant’s reliance on his grievance form to the agency, which simply cites Article 18, is misplaced. Id. at 44. To satisfy condition (2), it was incumbent upon the appellant to prove that he raised discrimination under 5 U.S.C. § 2302(b)(1) with the arbitrator. See Jones, 120 M.S.P.R. 480, ¶ 8; see also Scanlin v. Social Security Administration, 2022 MSPB 10, ¶ 5 (finding unavailing the appellant’s assertion that she had raised a claim of disability discrimination in her grievance with the agency because the jurisdictionally dispositive issue was whether she had raised discrimination with the arbitrator). Although the appellant also claims that Article 18 was “addressed extensively during testimony,” he has not submitted any testimony with his request for review, and the record does not contain any such evidence. RFR File, Tab 1 at 10. With respect to his post-hearing brief to the arbitrator, the appellant only alleges he “raised issues under the [CBA] at Article 18 (Equal Employment 2 The appellant’s removal, which was the subject matter of the grievance, is an action appealable to the Board under chapter 75 of Title 5 of the United States Code. 5 U.S.C. §§ 7512(1), 7513(d). 4

Opportunity) . . . in the Union’s requested findings in the associated Post-Hearing Brief.” Id. The appellant provided the Board with a copy of his post-hearing brief, and, in the brief, he simply requested that the arbitrator find that the agency failed to show that its removal decision “was issued with just cause and within contractual parameters given violations of Article 3, Sections 1, 2(A); Article 23; Article 31, Section 5; and Article 18.” Id. at 55. The appellant did not elaborate on the relevancy of Article 18, raise any sort of issue of discrimination relative to a violation of Article 18, or even discuss discrimination in any other way. We do not find that, at most, a mere allusion to discrimination via Article 18 shows that the appellant raised a claim of discrimination under 5 U.S.C. § 2302(b)(1) with the arbitrator, as required. See Scanlin, 2022 MSPB 10, ¶ 6 (finding that the generic posing of the question, “was the removal discriminatory,” without more, was insufficient to prove that the appellant raised a claim of discrimination under 5 U.S.C. § 2302(b)(1) with the arbitrator). With respect to the appellant’s brief assertion that he also raised issues of reprisal in this case, we note that in the appellant’s post-hearing brief, he also stated “[i]f it is determined that the [a]gency acted in a discriminatory manner and in retaliation against the [g]rievant for his Union role, the arbitrator is asked to consider and award compensatory damages as appropriate pursuant to the applicable EEOC retaliation provisions.” RFR File, Tab 1 at 10, 56.

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Related

Jones v. Merit Systems Protection Board
589 F. App'x 972 (Federal Circuit, 2014)
Perry v. Merit Systems Protection Bd.
582 U.S. 420 (Supreme Court, 2017)
Traci Scanlin v. Social Security Administration
2022 MSPB 10 (Merit Systems Protection Board, 2022)

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Rafael Arroyo v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rafael-arroyo-v-social-security-administration-mspb-2024.