Wade Cox v. Department of the Navy

CourtMerit Systems Protection Board
DecidedAugust 23, 2023
DocketSF-0752-22-0180-I-1
StatusUnpublished

This text of Wade Cox v. Department of the Navy (Wade Cox v. Department of the Navy) 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
Wade Cox v. Department of the Navy, (Miss. 2023).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

WADE T. COX, DOCKET NUMBER Appellant, SF-0752-22-0180-I-1

v.

DEPARTMENT OF THE NAVY, DATE: August 23, 2023 Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Jeff Letts, Esquire, Ruther Glen, Virginia, for the appellant.

Mona C. Williams, Esquire, Silverdale, Washington, 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 sustained his removal. For the reasons discussed below, we GRANT the appellant’s petition for review and REVERSE the initial decision. We 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1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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 most recently held the position of Supervisory Logistics Management Specialist, a GS-13 position in Silverdale, Washington. Initial Appeal File (IAF), Tab 6 at 15, 71. The appellant’s supervisor proposed his removal based on one charge of conduct unbecoming of a supervisor concerning a verbal altercation in October 2021, during which he raised his voice and cursed at his colleague—another supervisor. Id. at 29-31. In explaining the reasons for her recommended penalty, the proposing official referenced the appellant’s history of similar disrespectful outbursts for which he was not formally disciplined and attached what she labeled as “Historical Emails and statements documenting like or similar behavior.” Id. at 29-32, 44-65. The appellant replied to the proposal notice and provided written statements from witnesses to the alleged October 2021 misconduct. Id. at 18-28. The deciding official issued a decision letter removing the appellant from his position in January 2022. Id. at 15-17. ¶3 The appellant filed this appeal arguing that the charge was untrue, he was denied due process, and the penalty was unreasonable. IAF, Tab 1 at 4, Tab 11 at 1-11. Following a hearing, the administrative judge issued an initial decision sustaining the removal. IAF, Tab 17, Initial Decision (ID). ¶4 The appellant has filed a timely petition for review, Petition for Review (PFR) File, Tab 1, and the agency has responded in opposition, PFR File Tab 3. The appellant replied to the agency’s response. PFR File, Tab 4.

DISCUSSION OF ARGUMENTS ON REVIEW ¶5 In his petition for review, the appellant challenges the administrative judge’s findings that the agency proved its charge and that the penalty of removal was reasonable. PFR File, Tab 1 at 4-13, 18-22. He also reasserts that the agency committed a due process violation. Id. at 13-17; IAF, Tab 11 at 8. As discussed below, we find that the agency violated the appellant’s due process 3

rights. Because we reverse his removal on due process grounds, we decline to address his arguments concerning the charge and penalty. ¶6 The essential requirements of procedural due process are prior notice of the charges against the employee and a meaningful opportunity to respond to those charges. Cleveland Board of Education v. Loudermill, 470 U.S. 532, 546 (1985); see 5 U.S.C. § 7513(b). The appellant’s main point on review is that the agency did not provide him adequate notice of past instances of similar misconduct relied upon by the deciding official in his decision on the penalty. PFR File, Tab 1 at 13-17. He presents two distinct allegations that he was denied due process . Id. ¶7 The appellant’s first allegation pertains to the past instances of misconduct considered by the deciding official that were documented in emails attached to the proposed removal. PFR File, Tab 1 at 14; IAF, Tab 6 at 44-65. The appellant argues that these emails did not provide him with a legitimate opportunity to contest the accuracy of the allegations contained in the emails and that due process requires the specific allegations of the past misconduct to be in the body of the notice of proposed removal. PFR File, Tab 1 at 14. We disagree. In Alvarado v. Department of the Air Force, 97 M.S.P.R. 389, ¶ 15 (2004), we explained that a notice of proposed adverse action need not be a self -contained document; the notice requirement is satisfied when the proposal and any attachments to it, taken together, provide the employee with specific notice of the charges against him so that he can make an informed and meaningful reply. Here, the proposed removal referred to a history of similar disrespectful outbursts and that the appellant had been “engaging in this type of misconduct for years .” IAF, Tab 6 at 32. The proposed removal specifically cited “Historical Emails and statements documenting like or similar behavior” as materials relied upon and attached those emails. Id. at 29, 44-65. Thus, the appellant had notice and an opportunity to respond to the allegations of past misconduct that were contained in the proposal packet. 4

¶8 The appellant’s second allegation is that the deciding official erred by considering two other past instances of misconduct that were not specified anywhere in the proposal packet, and the administrative judge erred in finding otherwise. PFR File, Tab 1 at 13-17; ID at 16. We agree. The deciding official described the appellant’s past work record as including eight examples of unprofessional and disrespectful conduct. IAF, Tab 10 at 6, Tab 12 at 16. At the hearing, he testified that two out of the eight were based on his own experience with the appellant and were not included in the proposal notice or otherwise provided to the appellant during the removal process. 2 Hearing Transcript (HT) at 118-20, 147-49 (testimony of the deciding official). ¶9 Pursuant to the decisions of the U.S. Court of Appeals for the Federal Circuit in Ward v. U.S. Postal Service, 634 F.3d 1274, 1279-80 (Fed. Cir. 2011), and Stone v. Federal Deposit Insurance Corporation, 179 F.3d 1368, 1376-77 (Fed. Cir. 1999), a deciding official violates an employee’s due process rights when he relies upon new and material ex parte information as a basis for his decision on the merits of a proposed charge or the penalty to be imposed.

2 The two examples appear to be the following: Unprofessional behavior toward me during a meeting to deliver my decision on your administrative grievance regarding you[r] Letter of Reprimand on 2/14/19. During this meeting I counseled you very specifically on how your behavior was unacceptable and my expectations that you improve. I provided this to you in writing. Unprofessional behavior toward me during a conversation about the Extended Refit Period 2 Technical Foundation Paper on 5/14/20. The conversation devolved into an incoherent rant from you about unrelated topics including hiring practices, your disagreement with organizational changes, alleged favoritism, and your feelings of persecution.

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Wade Cox v. Department of the Navy, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wade-cox-v-department-of-the-navy-mspb-2023.