Santiano Rivera v. Department of Agriculture

CourtMerit Systems Protection Board
DecidedAugust 21, 2023
DocketSF-0752-20-0711-I-2
StatusUnpublished

This text of Santiano Rivera v. Department of Agriculture (Santiano Rivera 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
Santiano Rivera v. Department of Agriculture, (Miss. 2023).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

SANTIANO RIVERA, DOCKET NUMBER Appellant, SF-0752-20-0711-I-2

v.

DEPARTMENT OF AGRICULTURE, DATE: August 21, 2023 Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Lesa L. Donnelly, Anderson, California, for the appellant.

Rachel Trafican, Esquire, and Marcus Mitchell, Esquire, Albuquerque, New Mexico, for the agency.

BEFORE

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

FINAL ORDER

¶1 The appellant has filed a petition for review of the initial decision, which affirmed the agency’s removal action. For the reasons discussed below, we GRANT the appellant’s petition for review, REVERSE the initial decision, and DO NOT SUSTAIN the appellant’s removal.

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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 ¶2 The appellant was a GS-09 Natural Resource Specialist with the agency’s San Bernardino National Forest. Rivera v. Department of Agriculture, MSPB Docket No. SF-0752-20-0711-I-1, Initial Appeal File (IAF), Tab 7 at 14-15. On January 6, 2020, the agency proposed to remove him based on charges of conduct unbecoming and lack of candor. Id. at 37-39. The proposal stemmed from the appellant’s arrest by a county sheriff’s office and resulting incarceration between September 29 and 30, 2019, while on detail to the position of GS-11 Realty Specialist at the agency’s Mt. Hood National Forest. Id. at 37, 39-40; Rivera v. Department of Agriculture, MSPB Docket No. SF-0752-20-0711-I-2, Appeal File (I-2 AF), Tab 3 at 41. The agency alleged that the appellant’s conduct during his September 29, 2019 arrest was unbecoming because he pounded his head on a plastic window inside the patrol car, yelled, and accused the officers , without evidence, of arresting him and targeting him based on his race (Hispanic). IAF, Tab 1 at 8, Tab 7 at 28, 37. The agency also alleged his conduct was unbecoming because, following his incarceration, on October 11, 2019, the appellant submitted a timecard wherein “[he] coded Sick Leave (62) for [his absenc e on] September 30, 2019,” a date on which he was incarcerated. IAF, Tab 7 at 37. ¶3 Subsequently, the appellant admitted that the off-duty traffic accident he reported to his detail supervisor as the reason for his September 30th absence did not happen. Id. at 71-72. Based on that admission, the agency alleged the appellant lacked candor when he told his detail supervisor that he was absent on September 30, 2019, due to his falsely claimed accident. Id. at 37. The proposal set forth aggravating factors, such as the appellant’s prior disciplinary record. Id. at 41-44. It also listed a number of mitigating factors. Id. Among the factors the proposing official listed as mitigating was that the appellant and his wife “recently lost an unborn child.” Id. at 44. ¶4 The appellant responded, both orally and in writing . Id. at 23-31. He argued that the penalty of removal was too severe because , as relevant here, his 3

behavior was affected by his and his wife’s grief at the loss of their baby 1 week before he left for his detail at Mt. Hood. Id. at 28-31. The deciding official issued a removal decision, effective February 5, 2020, sustaining the agency’s charge and removal penalty. Id. at 15-17. Attached to the removal decision was a “Douglas Factors Work Sheet” filled out by the deciding official, setting forth various aggravating and mitigating factors. Id. at 15-22. She acknowledged on the worksheet that the appellant and his wife’s “recent loss of their unborn child” was a mitigating factor but found it did not “outweigh or negate the seriousness of the misconduct.” Id. at 22. ¶5 The appellant filed this appeal to the Board, arguing that the agency did not prove that the actions at issue in the conduct unbecoming charge amounted to misconduct, that there was a nexus between this off-duty misconduct and the efficiency of the service, and that the penalty of removal was reasonable. IAF, Tab 1 at 4, 6; I-2 AF, Tab 6 at 5-6, 9-10. He also raised the affirmative defenses of race discrimination and reprisal for prior equal employment opportunity (EEO) activity. IAF, Tab 1 at 6; I-2 AF, Tab 6 at 10-11, Tab 8 at 3-5. In his closing argument, he further alleged, based in part on the deciding official’s hearing testimony, that the agency violated his due process ri ghts. I-2 AF, Tab 13, Hearing Recording, Day 2 (HR 2) (the appellant’s closing argument). ¶6 The administrative judge issued an initial decision sustaining the specifications and charges related to the appellant’s removal. I-2 AF, Tab 15, Initial Decision (ID) at 3-19. The administrative judge also determined that the agency established a nexus between the charged misconduct and the efficiency of the service and that the penalty of removal was reasonable. ID at 28 -32. Finally, the administrative judge found that the appellant failed to prove his affirmative defenses. ID at 22-28. Consequently, the administrative judge affirmed the removal. ID at 1, 32. ¶7 The appellant has filed a petition for review. Petition for Review (PFR) File, Tab 1. He argues that the agency violated his due process rights and 4

committed procedural error. Id. at 4-8. He also argues the administrative judge improperly limited the amount of time he had to present his closing argument. Id. at 7. The agency has responded. PFR File, Tab 3.

DISCUSSION OF ARGUMENTS ON REVIEW ¶8 The parties do not challenge on review the administrative judge’s determinations that the agency proved its charges by preponderant evidence , a nexus existed between the appellant’s actions and the efficiency of the service, and the penalty of removal was reasonable. ID at 3-19, 28-32. They also do not dispute his finding that the appellant did not prove that his race or EEO activity was a motivating factor in the agency’s decision to remove him. ID at 22 -28. Rather, the appellant’s arguments on review are limited to claims that the agency violated his due process rights and committed procedural error and that the administrative judge erred in limiting his closing argument. PFR File, Tab 1 at 4-8. Because, as discussed below, we agree with the appellant that the agency violated his due process rights by considering his “poor judgment” following the death of his unborn child as an aggravating factor without providing notice and an opportunity to respond, we must reverse his removal. In light of this finding, we find it unnecessary to address his other arguments on review.

The agency’s removal process violated the appellant’s due process rights. ¶9 The essential requirements of procedural due process are prior notice of the charges and evidence against the employee and a meaningful opportunity to respond to those charges and evidence. Cleveland Board of Education v. Loudermill, 470 U.S. 532, 546 (1985). The appellant argued below and reasserts on review that the agency violated his due process rights when, as relevant here, the deciding official considered information not included in the notice of proposed removal. PFR File, Tab 1 at 4-6; HR 2 (the appellant’s closing argument). Pursuant to Ward v. U.S. Postal Service, 634 F.3d 1274

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Santiano Rivera v. Department of Agriculture, Counsel Stack Legal Research, https://law.counselstack.com/opinion/santiano-rivera-v-department-of-agriculture-mspb-2023.