Steven McKinnis v. Department of the Interior

CourtMerit Systems Protection Board
DecidedSeptember 7, 2023
DocketDA-1221-18-0200-W-1
StatusUnpublished

This text of Steven McKinnis v. Department of the Interior (Steven McKinnis v. Department of the Interior) 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
Steven McKinnis v. Department of the Interior, (Miss. 2023).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

STEVEN A. MCKINNIS, DOCKET NUMBER Appellant, DA-1221-18-0200-W-1

v.

DEPARTMENT OF THE INTERIOR, DATE: September 7, 2023 Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Susan L. Kruger, Esquire, Washington, D.C., for the appellant.

Conor Cleary, Tulsa, Oklahoma, for the agency.

BEFORE

Cathy A. Harris, Vice Chairman Raymond A. Limon, Member Tristan L. Leavitt, Member 2 Member Leavitt recused himself and did not participate in the adjudication of this appeal.

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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 Member Leavitt’s name is included in decisions on which the three -member Board completed the voting process prior to his March 1, 2023 departure. 2

FINAL ORDER

¶1 The appellant has filed a petition for review of the initial decision, which denied his request for corrective action under the Whistleblower Protection Act . 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 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 with respect to the issues of protected activity, contributing factor, and the agency’s affirmative defense, as set forth in ¶¶ 6-15 below, we AFFIRM the initial decision.

BACKGROUND ¶2 The appellant was a GS-12 Auditor for the agency’s Office of Natural Resources Revenue. McKinnis v. Department of the Interior, MSPB Docket No. DA-0432-18-0199-I-1, Initial Appeal File (0199 IAF), Tab 1 at 1, 9. 3 The appellant’s major job duties entailed conducting audits and compliance reviews of

3 The instant appeal was joined, for a time, with McKinnis v. Department of the Interior, MSPB Docket No. DA-0432-18-0199-I-1, which was the lead case in the joinder. McKinnis v. Department of the Interior, MSPB Docket No. DA-1221-18-0220- W-1, Initial Appeal File, Tab 9. Much of the evidence pertinent to the instant individual right of action appeal is contained in that case file. 3

oil and gas leases on Federal and Indian lands to ensure the proper payment of royalties. Hearing Recording (HR), Track 1 at 12:40 (testimony of the appellant). The appellant filed an individual right of action (IRA) appeal, claiming that the agency took multiple personnel actions against him in retaliation for several protected disclosures. McKinnis v. Department of the Interior, MSPB Docket No. DA-1221-18-0220-W-1, Initial Appeal File (0200 IAF), Tab 1, Tab 6 at 4-7. ¶3 After a hearing, the administrative judge issued an initial decision denying the appellant’s request for corrective action on the merits. 0200 IAF, Tab 16, Initial Decision (ID). She found that several of the appellant’s claimed disclosures were not protected, and that the remaining disclosures were either not contributing factors in the claimed personnel actions or that the agency proved by clear and convincing evidence that it would have taken the same actions notwithstanding the disclosures. ID at 7-26. The appellant has filed a petition for review, disputing the administrative judge’s analysis of the agency’s affirmative defense with respect to two of the personnel actions at issue: his placement on a performance improvement plan (PIP) and the removal. 4 Petition for Review (PFR) File, Tab 1 at 5-9. The agency has filed a response. PFR File, Tab 3.

ANALYSIS ¶4 In the merits phase of an IRA appeal, the appellant has the burden of proving by preponderant evidence that he engaged in protected activity described under 5 U.S.C. § 2302(b)(8) or (b)(9)(A)(i), (B), (C), or (D), and that this activity was a contributing factor in a personnel action as described under 5 U.S.C. § 2302(a)(2)(A). Salerno v. Department of the Interior, 123 M.S.P.R. 230, ¶ 5 (2016). If the appellant meets his burden, the Board will order corrective action

4 Also at issue in this appeal were a letter of warning, a grievance decision, a denial of telework, and a 14-day suspension. ID at 12. The appellant does not challenge the administrative judge’s findings concerning these personnel actions, and we therefore do not address these issues on review. See Blackhat v. Department of Health and Human Services, 117 M.S.P.R. 552, ¶ 3 n.2 (2012); 5 C.F.R. § 1201.115. 4

unless the agency proves by clear and convincing evidence that it would have taken the same personnel action in the absence of the protected activity. 5 U.S.C. § 1221(e); Salerno, 123 M.S.P.R. 230, ¶ 5. However, the Board may only address the agency’s affirmative defense after the appellant has proven his case in chief. Scoggins v. Department of the Army, 123 M.S.P.R. 592, ¶ 28 (2016). For the reasons set forth below, we find that the appellant has not proven his case. ¶5 The administrative judge addressed the following alleged protected activit y in her initial decision: (1) complaints to the agency’s Office of Inspector General and the Federal Labor Relations Authority, ID at 7-9; (2) disclosures during a grievance regarding the agency’s alleged violation of travel regulations and the Family and Medical Leave Act (FMLA), ID at 9; (3) disclosures regarding the agency’s alleged violation of its leave policy, ID at 10; and (4) equal employment opportunity (EEO) complaints and participation in an administrative investigation, ID at 10-11. The administrative judge found that the appellant only proved with respect to activities (2) and (4) that he engaged in protected activity that was exhausted before the Office of Special Counsel. ID at 7-11. She also found that this protected activity was a contributing factor in the PIP and the removal. ID at 12-15. Although neither party challenges these findings per se, under the particular circumstances of this case, we find it appropriate to assess them further. See 5 C.F.R. § 1201.115(e).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Roland Spruill v. Merit Systems Protection Board
978 F.2d 679 (Federal Circuit, 1992)
Robert v. Serrao v. Merit Systems Protection Board
95 F.3d 1569 (Federal Circuit, 1996)
McCarthy v. International Boundary and Water Commission
497 F. App'x 4 (Federal Circuit, 2012)
Perry v. Merit Systems Protection Bd.
582 U.S. 420 (Supreme Court, 2017)
Marguerite Pridgen v. Office of Management and Budget
2022 MSPB 31 (Merit Systems Protection Board, 2022)
Paul Bishop v. Department of Agriculture
2022 MSPB 28 (Merit Systems Protection Board, 2022)
John Edwards v. Department of Labor
2022 MSPB 9 (Merit Systems Protection Board, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
Steven McKinnis v. Department of the Interior, Counsel Stack Legal Research, https://law.counselstack.com/opinion/steven-mckinnis-v-department-of-the-interior-mspb-2023.