Ronald Wiesner v. Department of Homeland Security

CourtMerit Systems Protection Board
DecidedJune 8, 2026
DocketDA-0432-25-0118-I-1
StatusUnpublished

This text of Ronald Wiesner v. Department of Homeland Security (Ronald Wiesner v. Department of Homeland Security) 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
Ronald Wiesner v. Department of Homeland Security, (Miss. 2026).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

RONALD WIESNER, DOCKET NUMBER Appellant, DA-0432-25-0118-I-1

v.

DEPARTMENT OF HOMELAND DATE: June 8, 2026 SECURITY, Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Amanda J. Moreno , Esquire, Houston, Texas, for the appellant.

Jennifer N. Milan , Esquire, and Thomas A. Behe , Esquire, Houston, Texas, for the agency.

BEFORE

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

FINAL ORDER

The appellant has filed a petition for review of the initial decision, which affirmed his removal for unacceptable performance under 5 U.S.C. chapter 43. For the reasons discussed below, we GRANT the appellant’s petition for review, REVERSE the initial decision’s findings concerning the removal action, AFFIRM

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

the initial decision’s findings regarding the discrimination affirmative defense, and ORDER the agency to reinstate the appellant to his former position.

BACKGROUND The appellant began working for the agency as a GS-13 Investigative Program Specialist (Polygraph Examiner) in or around October 2020. Initial Appeal File (IAF), Tab 9 at 4. His job duties included completing polygraph examinations of applicants for Customs and Border Protection law enforcement positions. IAF, Tab 34 at 16. The potential results of a polygraph examination are no significant response (NSR), significant response (SR), no opinion-countermeasures (NO-CM), and no opinion (NO). Id. at 19. NSR is a passed polygraph and SR is a failed polygraph. Id. According to the appellant’s supervisor, a NO-CM result is when there is atypical physiology consistent with an attempt to manipulate polygraph data. Id. A NO opinion is when the data does not support a NSR, SR, or NO-CM decision. Id. NSR, SR, and NO-CM are conclusive results and NO is inconclusive. Id. at 20. According to the appellant’s supervisor, NO opinions typically require a retest but there are other reasons besides NO opinions that can trigger a retest. Id. The appellant received successful performance ratings for fiscal years 2021-2023. IAF, Tab 22 at 8-13. On March 4, 2024, the appellant’s supervisor sent an email identifying deficiencies in the appellant’s performance. IAF, Tab 5 at 99-101. In relevant part, he asserted that the appellant’s NO rate was 30%, more than double the national average and 12 points higher than the Team Central Texas average of 18%. Id. at 101. On June 11, 2024, the agency notified the appellant that he was being placed on an Employee Proficiency Plan (EPP) because he was deficient in the core competency area of “professionalism.” Id. at 86-91. The EPP described the appellant’s deficient performance in the following areas: (1) he failed to timely submit cases within agency guidelines on no less than six occasions; (2) the length of his post-test interview for applicants 3

was unnecessarily prolonged on three occasions; and (3) his NO rate of 26% exceeded the 18% average rate of the CAD [Credibility Assessment Division] and Team Central Texas over the past 9 months. Id. at 89-90. The improvement period was to run from July 15 through August 13, 2024, but was extended through September 4, 2024, based on the appellant’s use of sick leave during the EPP period. Id. at 39, 90. During the EPP, the appellant’s supervisor and other managers repeatedly requested that the appellant conference in a supervisor to his polygraph examinations for guidance and observation. Id. at 44-48, 53-66. The appellant did not comply with these requests, stating on at least one occasion that the EPP was retaliatory. 2 Id. at 46. On September 20, 2024, the appellant’s supervisor proposed his removal from Federal service for unacceptable performance. Id. at 27-31. The proposal stated that, at the completion of the EPP period, his NO rate remained at 25%, which was 8% above the average rates of Team Central Texas and CAD. Id. at 28. The proposal stated that the areas of timely submission of assessments and conducting appropriate length post-tests, i.e., subelements 1 and 2 of the EPP, were “not able to be addressed appropriately” during the performance period. Id. The appellant did not reply to the proposed removal. Id. at 22. The agency sustained the proposal, and the appellant’s removal was effective November 22, 2024. Id. at 24-26; IAF, Tab 9 at 4. This appeal followed. IAF, Tab 1. The administrative judge issued an initial decision on the written record. IAF, Tab 36, Initial Decision (ID). She concluded that the agency met each element of its chapter 43 case by substantial evidence and that the appellant failed to prove his affirmative defense of disability discrimination. The appellant has filed a petition for review, and the agency has filed a response. Petition for Review (PFR) File, Tabs 4, 6. On review, the appellant reasserts the same arguments that

2 The appellant did not explicitly raise a reprisal affirmative defense before the administrative judge or on review. 4

he raised before the administrative judge and states that the agency failed to prove its case by substantial evidence. PFR File, Tab 4 at 9-31.

DISCUSSION OF ARGUMENTS ON REVIEW An agency may remove an employee for unacceptable performance under 5 U.S.C. § 4303 when it proves the following by substantial evidence: (1) the Office of Personnel Management approved the agency’s performance appraisal system and any significant changes thereto; (2) the agency communicated to the appellant the performance standards and critical elements of his position; (3) the appellant’s performance standards are valid under 5 U.S.C. § 4302(c)(1); (4) the appellant’s performance during the appraisal period was unacceptable in one or more critical elements; (5) the agency warned the appellant of the inadequacies of his performance during the appraisal period and gave him an adequate opportunity to demonstrate acceptable performance; and (6) after an adequate improvement period, the appellant’s performance remained unacceptable in one or more of the critical elements. Lee v. Department of Veterans Affairs, 2022 MSPB 11, ¶ 15. We disagree with the administrative judge’s finding that the agency proved its performance standards are valid, ID at 6-8, as discussed below. We therefore reverse the appellant’s removal. Performance standards must, to the maximum extent feasible, permit the accurate appraisal of performance based on objective criteria. 5 U.S.C. § 4302(c)(1); Guillebeau v. Department of the Navy, 362 F.3d 1329, 1335-36 (Fed. Cir. 2004). Standards must be specific enough to provide an employee with a firm benchmark toward which to aim his performance and must be sufficiently precise to invoke general consensus as to their meaning and content. Zepeda v. Nuclear Regulatory Commission, 2024 MSPB 14, ¶ 22. Facially invalid standards may be cured through subsequent communications to the employee. Zepeda, 2024 MSPB 14, ¶ 11; Dancy v.

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Ronald Wiesner v. Department of Homeland Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ronald-wiesner-v-department-of-homeland-security-mspb-2026.