Robert Keating v. Department of Agriculture

CourtMerit Systems Protection Board
DecidedMay 8, 2024
DocketDC-0752-18-0767-I-1
StatusUnpublished

This text of Robert Keating v. Department of Agriculture (Robert Keating v. Department of Agriculture) 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
Robert Keating v. Department of Agriculture, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

ROBERT KEATING, DOCKET NUMBER Appellant, DC-0752-18-0767-I-1

v.

DEPARTMENT OF AGRICULTURE, DATE: May 8, 2024 Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Robert Keating , Cary, North Carolina, pro se.

Gretchen McMullen , Esquire, Mount Rainier, 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 affirmed his removal. 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 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to the facts of the case; the administrative judge’s rulings during either the course of the appeal or the initial 1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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

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 supplement the administrative judge’s mitigating factor analysis, we AFFIRM the initial decision.

BACKGROUND The appellant was employed as a GS-13 Investigator with the agency’s Internal Controls Staff (ICS), Office of the Administrator, Food Safety and Inspection Service (FSIS) in Raleigh, North Carolina. Initial Appeal File (IAF), Tab 6 at 15. In April 2018, contractors in the Office of the Chief Information Officer (OCIO), the agency’s information technology unit, flagged the appellant’s computer activity for further investigation and agency management referred the matter to ICS. IAF, Tab 6 at 83-92, Tab 7 at 4-7. In May 2018, an ICS investigator performed a forensic analysis of the appellant’s FSIS computer, which revealed that he had viewed, accessed, and downloaded pornographic or sexually explicit content since April 2016, a period of 2 years. IAF, Tab 7 at 9-21. Shortly thereafter, the agency proposed the appellant’s removal based on the charge of misuse of Government-owned equipment, supported by three specifications that described the stated conduct. IAF, Tab 6 at 73-79. After considering the appellant’s oral and written responses, in which he admitted viewing images of adult women, id. at 22-72, the agency removed the appellant from his position, effective July 20, 2018, id. at 15-21. 3

The appellant filed an appeal challenging his removal and raised a claim of reprisal for whistleblowing disclosures. IAF, Tab 1. In the order and summary of the parties’ telephonic prehearing conference, the administrative judge stated that the parties stipulated to numerous facts, the appellant admitted to engaging in the charged misconduct, he withdrew his claim of reprisal for whistleblowing, and he did not raise any other affirmative defenses. IAF, Tab 26 at 5-8, Tab 33 at 2. The administrative judge further stated that the scope of the appeal was limited to nexus and the reasonableness of the penalty. IAF, Tab 33 at 2. After holding the appellant’s requested hearing, the administrative judge issued an initial decision sustaining the removal. IAF, Tab 37, Hearing Compact Disc (HCD), Tab 38, Initial Decision (ID) at 1-2, 10. She found that the agency proved the charge by preponderant evidence, that the removal was taken for such cause as promotes the efficiency of the service, and that the penalty was within the tolerable bounds of reasonableness. ID at 2-10. The appellant has filed a petition for review. Petition for Review (PFR) File, Tab 1. The agency has filed a response. PFR File, Tab 3.

DISCUSSION OF ARGUMENTS ON REVIEW On review, the appellant does not challenge the administrative judge’s finding that the agency proved the charged misconduct, ID at 3, and we affirm her finding herein. Instead, the appellant argues that the agency did not prove nexus or the reasonableness of the penalty. PFR File, Tab 1 at 4-5, 8-22. He also argues that the administrative judge abused her discretion when she denied his motion to compel, excluded the testimony of a witness to refute the deciding official’s credibility, and disallowed the admission of additional evidence relating to the deciding official’s assessment of the penalty. Id. at 4-8. For the reasons set forth below, we find that the appellant’s arguments on review do not warrant a different outcome. 4

We affirm the administrative judge’s finding that the removal was taken for such cause as promotes the efficiency of the service. The appellant challenges the administrative judge’s nexus determination because there was no “evidence of damage to any equipment, or malfeasance or intent to do harm.” PFR File, Tab 1 at 10; ID at 3-4. The appellant misstates the nexus requirement. The nexus requirement, for purposes of whether an agency has shown that its action promotes the efficiency of the service, means there must be a clear and direct relationship between the articulated grounds for an adverse action and either the employee’s ability to accomplish his or her duties satisfactorily or some other legitimate government interest. Scheffler v. Department of Army, 117 M.S.P.R. 499, ¶ 9 (2012), aff’d, 522 F. App’x 913 (Fed. Cir. 2013). Here, the appellant’s misconduct occurred at work while he was on duty and involved misuse of Government equipment. There is sufficient nexus between an employee’s conduct and the efficiency of the service when the conduct occurs at work. Parker v. U.S. Postal Service, 819 F.2d 1113, 1116 (Fed. Cir. 1987); Miles v. Department of the Navy, 102 M.S.P.R. 316, ¶ 11 (2006). Moreover, the Board has held that a nexus between the efficiency of the service and the charge of misuse of Government equipment exists. Els v. Department of the Army, 82 M.S.P.R. 27, ¶ 11 (1999); Sternberg v. Department of Defense, 52 M.S.P.R. 547, 559 (1992). Given the sustained misconduct, we agree with the administrative judge that the agency proved nexus in this case. ID at 3-4.

We supplement the administrative judge’s penalty analysis, still finding that the penalty of removal was within the tolerable bounds of reasonableness. When, as here, the Board sustains an agency’s charge, it will defer to the agency’s penalty determination unless the penalty exceeds the range of allowable punishment specified by statute or regulation, or unless the penalty is “so harsh and unconscionably disproportionate to the offense that it amounts to an abuse of discretion.” Batara v. Department of the Navy, 123 M.S.P.R. 278, ¶ 5 (2016) 5

(quoting Parker, 819 F.2d at 1116).

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Robert Keating v. Department of Agriculture, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-keating-v-department-of-agriculture-mspb-2024.