Tyler Stewart v. Department of Health and Human Services

CourtMerit Systems Protection Board
DecidedApril 18, 2024
DocketDC-1221-20-0666-W-3
StatusUnpublished

This text of Tyler Stewart v. Department of Health and Human Services (Tyler Stewart v. Department of Health and Human Services) 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
Tyler Stewart v. Department of Health and Human Services, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

TYLER JAMES STEWART, DOCKET NUMBER Appellant, DC-1221-20-0666-W-3

v.

DEPARTMENT OF HEALTH AND DATE: April 18, 2024 HUMAN SERVICES, Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Tyler James Stewart , Derwood, Maryland, pro se.

Sariana Garcia-Ocasio , 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 the initial decision, which dismissed his individual right of action (IRA) appeal for lack of jurisdiction. 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findings of material fact; the initial decision is based on an erroneous interpretation of statute or regulation 1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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

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 and AFFIRM the initial decision, which is now the Board’s final decision. 5 C.F.R. § 1201.113(b). Under 5 U.S.C. § 1221(a), the right to file an IRA appeal is limited to employees, former employees, and applicants for employment in the civil service. See, e.g., Glover v. Department of the Army, 94 M.S.P.R. 534, ¶ 9 (2003) (finding that a widow or widower of a deceased Federal employee may not file an IRA appeal after the Federal employee’s death). To qualify as an employee or former employee for purposes of 5 U.S.C. § 1221(a), an individual must meet (or have met) the definition of an employee under 5 U.S.C. § 2105(a), i.e., “an officer and individual who is appointed in the civil service” by certain individuals specified by statute. The civil service in turn comprises “all appointive positions in the executive, judicial, and legislative branches of the Government of the United States, except positions in the uniformed services.” See 5 U.S.C. § 2101(1). As the administrative judge found below, the appellant has not provided evidence that he was appointed to a civil service position with the agency, such that he could be considered an employee, former employee, or applicant for employment with standing to file an IRA appeal. The record of the appellant’s traineeship does not bear the indicia of such an appointment, such as evidence of an oath of office, a Standard Form 50 or similar formal paperwork, or salary and benefits provided through the civil service system. See Horner v. Acosta, 3

803 F.2d 687, 693-94 (Fed. Cir. 1986) (identifying elements indicative of an appointment under 5 U.S.C. § 2105). To the contrary, the appellant’s correspondence with the agency, which he resubmits on review, indicates that he received a stipend rather than a salary and was responsible for obtaining private health insurance. We have considered the appellant’s argument that he did not receive notice of his burden to establish that he was an employee with standing to file an IRA appeal. While the administrative judge did not specifically address the issue of standing in his jurisdictional order, the Board has held that an administrative judge’s failure to provide notice of jurisdictional requirements is not prejudicial if the agency’s motion to dismiss places the appellant on notice of what he has to allege to establish jurisdiction. Yost v. Department of Health and Human Services, 85 M.S.P.R. 273, 277 (2000) aff’d, 4 F. App’x 900 (Fed. Cir. 2001). Here, we find that the appellant received adequate notice of the standing issue through the agency’s motion to dismiss. Stewart v. Department of Health and Human Services, MSPB Docket No. DC-1221-20-0666-W-2, Appeal File, Tab 6. Finally, we find no merit to the appellant’s assertion that he is entitled to a hearing in order to reintroduce evidence and argument concerning his standing to file an IRA appeal. See Graves v. Department of Veterans Affairs, 123 M.S.P.R. 434, ¶ 22 (2016) (explaining that in an IRA appeal, the appellant is entitled to a hearing only after jurisdiction is established, and that hearing is on the merits).

NOTICE OF APPEAL RIGHTS 2 You may obtain review of this final decision. 5 U.S.C. § 7703(a)(1). By statute, the nature of your claims determines the time limit for seeking such review and the appropriate forum with which to file. 5 U.S.C. § 7703(b). Although we offer the following summary of available appeal rights, the Merit

2 Since the issuance of the initial decision in this matter, the Board may have updated the notice of review rights included in final decisions. As indicated in the notice, the Board cannot advise which option is most appropriate in any matter. 4

Systems Protection Board does not provide legal advice on which option is most appropriate for your situation and the rights described below do not represent a statement of how courts will rule regarding which cases fall within their jurisdiction. If you wish to seek review of this final decision, you should immediately review the law applicable to your claims and carefully follow all filing time limits and requirements. Failure to file within the applicable time limit may result in the dismissal of your case by your chosen forum. Please read carefully each of the three main possible choices of review below to decide which one applies to your particular case. If you have questions about whether a particular forum is the appropriate one to review your case, you should contact that forum for more information.

(1) Judicial review in general . As a general rule, an appellant seeking judicial review of a final Board order must file a petition for review with the U.S.

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Tyler Stewart v. Department of Health and Human Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tyler-stewart-v-department-of-health-and-human-services-mspb-2024.