Wendy Alguard v. Department of Agriculture

CourtMerit Systems Protection Board
DecidedJuly 18, 2024
DocketSF-1221-20-0275-W-1
StatusUnpublished

This text of Wendy Alguard v. Department of Agriculture (Wendy Alguard 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
Wendy Alguard v. Department of Agriculture, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

WENDY ALGUARD, DOCKET NUMBER Appellant, SF-1221-20-0275-W-1

v.

DEPARTMENT OF AGRICULTURE, DATE: July 18, 2024 Agency.

THIS ORDER IS NONPRECEDENTIAL 1

Wendy Alguard , Yakima, Washington, pro se.

Lori A. Ittner , Washington, D.C., for the agency.

Sandy S. Francois , Kenner, Louisiana, for the agency.

BEFORE

Cathy A. Harris, Chairman Raymond A. Limon, Vice Chairman Henry J. Kerner, Member*

*Member Kerner did not participate in the adjudication of this appeal.

REMAND ORDER

The appellant has filed a petition for review of the initial decision, which dismissed her individual right of action (IRA) appeal for lack of jurisdiction. For the reasons discussed below, we GRANT the appellant’s petition for review,

1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future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

REVERSE the initial decision, and REMAND the case to the regional office for further adjudication in accordance with this Remand Order.

DISCUSSION OF ARGUMENTS ON REVIEW On February 21, 2020, the appellant filed three separate appeals with the Board, including the instant appeal. Initial Appeal File (IAF), Tab 1; Alguard v. Department of Agriculture, MSPB Docket No. SF-20-0752-0274-I-1, Initial Appeal File (0274 IAF), Tab 1; Alguard v. Department of Agriculture, MSPB Docket No. SF-20-1221-0270-W-1, Initial Appeal File (0270 IAF), Tab 1. 2 Here, the appellant alleged that, in 2016, the agency failed to select her for a position for which she had applied because she had filed a “complaint regarding reprocessing of moldy applesauce at a company where [she] was assigned.” IAF, Tab 9 at 5. With her initial appeal form, the appellant provided two letters from the Office of Special Counsel (OSC) dated December 19, 2019, and February 20, 2020. IAF, Tab 1 at 7-9. The letters indicated that, in 2016, the appellant had filed an OSC complaint involving, among other things, her disclosure of “potentially deadly (moldy) applesauce” and her 2016 nonselection. Id. at 7. OSC indicated that it was closing its investigation into her allegations, and it provided the appellant with her Board appeal rights. Id. at 8-9. To establish jurisdiction in a typical IRA appeal under the Whistleblower Protection Enhancement Act of 2012 (WPEA), 3 an appellant must show by 2 In her other Board appeals, the appellant (1) challenged her 2011 removal from the agency, 0274 IAF, Tab 1 at 3, 5, 7, Tab 7 at 5, and (2) alleged that the agency had retaliated against her for filing complaints with the agency’s Office of the Inspector General, 0270 IAF, Tab 1 at 3, 5. The former appeal was dismissed on the basis of res judicata, 0274 IAF, Tab 21, Initial Decision at 1-2, 4 (Apr. 13, 2020), and the latter appeal is currently pending in the Western Regional Office. 3 Pursuant to the WPEA, effective December 27, 2012, Congress expanded the grounds on which an appellant may file an IRA appeal with the Board. Rebstock Consolidation v. Department of Homeland Security, 122 M.S.P.R. 661, ¶ 5 (2015). Under the WPEA, the date of the purported retaliation, and not the disclosure, is dispositive in determining whether pre-WPEA or post-WPEA standards apply. See Hooker v. Department of Veterans Affairs, 120 M.S.P.R. 629, ¶¶ 13, 15 (2014). Here, because the alleged retaliation occurred in 2016, after the effective date of the WPEA, the WPEA 3

preponderant evidence 4 that she exhausted her remedies before OSC and make nonfrivolous allegations of the following: (1) she made a disclosure described under 5 U.S.C. § 2302(b)(8) or engaged in a protected activity described under 5 U.S.C. § 2302(b)(9)(A)(i), (B), (C), or (D); and (2) the disclosure or protected activity was a contributing factor in the agency’s decision to take or fail to take a personnel action as defined by 5 U.S.C. § 2302(a). Corthell v. Department of Homeland Security, 123 M.S.P.R. 417, ¶ 8 (2016), overruled on other grounds by Requena v. Department of Homeland Security , 2022 MSPB 39. A nonfrivolous allegation is an assertion that, if proven, could establish the matter at issue. 5 C.F.R. § 1201.4(s). The U.S. Court of Appeals for the Federal Circuit has found that, in the context of an IRA appeal, a nonfrivolous allegation is an allegation of “sufficient factual matter, accepted as true, to state a claim that is plausible on its face.” Hessami v. Merit Systems Protection Board, 979 F.3d 1362, 1364, 1367 (Fed. Cir. 2020). Any doubt or ambiguity as to whether the appellant made nonfrivolous jurisdictional allegations should be resolved in favor of affording the appellant a hearing. Drake v. Agency for International Development, 103 M.S.P.R. 524, ¶ 11 (2006). Here, in the initial decision, the administrative judge found that the appellant had made a nonfrivolous allegation that, in 2011, she made a protected disclosure described under 5 U.S.C. § 2302(b)(8)(A). IAF, Tab 16, Initial Decision (ID) at 5. She also found that the appellant had made a nonfrivolous allegation of a personnel action under 5 U.S.C. § 2302(a), i.e., that, in 2016, the agency had failed to select her for a position for which she had applied. ID at 5-6. The administrative judge also concluded that the appellant had exhausted her administrative remedies before OSC regarding these claims. Id. She found,

applies to this appeal. The relevant holdings of the pre-WPEA case law that we have cited herein have not been affected by the WPEA. 4 Preponderant evidence is the degree of relevant evidence that a reasonable person, considering the record as a whole, would accept as sufficient to find that a contested fact is more likely to be true than untrue. 5 C.F.R. § 1201.4(q). 4

however, that the appellant had failed to establish Board jurisdiction because she had failed to make a nonfrivolous allegation that her protected disclosure had contributed to her nonselection. ID at 5-7. In so finding, the administrative judge reasoned that, although the record showed that the selecting official was aware of the appellant’s protected disclosure, because the appellant’s nonselection had occurred 5 years after the same, the appellant had failed to satisfy the knowledge/timing test. ID at 6-7.

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Related

Hessami v. MSPB
979 F.3d 1362 (Federal Circuit, 2020)
Rommie Requena v. Department of Homeland Security
2022 MSPB 39 (Merit Systems Protection Board, 2022)

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Wendy Alguard v. Department of Agriculture, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wendy-alguard-v-department-of-agriculture-mspb-2024.