William Doyle v. Department of the Army

CourtMerit Systems Protection Board
DecidedApril 4, 2024
DocketDE-0752-21-0204-I-2
StatusUnpublished

This text of William Doyle v. Department of the Army (William Doyle v. Department of the Army) 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
William Doyle v. Department of the Army, (Miss. 2024).

Opinion

UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD

WILLIAM DOYLE, DOCKET NUMBER Appellant, DE-0752-21-0204-I-2

v.

DEPARTMENT OF THE ARMY, DATE: April 4, 2024 Agency.

THIS FINAL ORDER IS NONPRECEDENTIAL 1

Bobby R. Devadoss , Esquire, Claire Ocana , Esquire, and Morgan Valasquez , Esquire, Dallas, Texas, for the appellant.

Eric J. Teegarden , Esquire, Fort McCoy, Wisconsin, 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 affirmed his removal. 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interpretation of statute or regulation or the erroneous application of the law to the facts of the case; the 1 A nonprecedential order is one that the Board has determined does not add significantly to the body of MSPB case law. Parties may cite nonprecedential orders, but such orders have no precedential value; the Board and administrative judges are not required to follow or distinguish them in any future decisions.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

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 to address an additional due process claim, we AFFIRM the initial decision.

BACKGROUND The appellant was removed from his position as Alcohol & Drug Control Coordinator for the Army Reserve Command at Fort Douglas in Salt Lake City, Utah, for “sending an electronic mail (email) message to multiple recipients that included language of a threatening nature and for being on duty while under the influence of alcohol/drugs, to a degree which would interfere with proper performance of duty or would be prejudicial to the maintenance of discipline.” Doyle v. Department of the Army, MSPB Docket No. DE-0752-21-0204-I-1, Initial Appeal File (IAF), Tab 7 at 13. The agency specifically alleged that the appellant sent an email to approximately 7,500 employees and contractors within the 76th Operation Response Command in which he said “[y]ou are traitors to the US Constitution and God. You will die.” Id. The agency further alleged that on the same day, the appellant had telephone conversations both with his first-level supervisor and with local police in which he admitted sending the email and appeared to be intoxicated because he was slurring his words. Id. at 13, 96. As a result of the appellant’s email, “tenant organizations on Fort Douglas released their workforces early” and “Fort Douglas increased its security posture.” Id. at 14. 3

The appellant filed this appeal. IAF, Tab 1 at 4, 6. After holding a hearing, the administrative judge issued an initial decision affirming the removal. Doyle v. Department of the Army, MSPB Docket No. DE-0752-21-0204-I-2, Refiled Appeal File (RAF), Tab 7, Initial Decision (ID) at 1, 17. She found that the agency proved its narrative charge by preponderant evidence. ID at 5-7. She rejected the appellant’s implied arguments that the agency violated his due process rights. ID at 12-16; e.g., IAF, Tab 7 at 24-26. She concluded that the agency proved a nexus between the appellant’s misconduct and the efficiency of the service, that the deciding official properly considered the relevant Douglas factors, and that the penalty of removal was within the limits of reasonableness. 2 ID at 7-12. The appellant has filed a petition for review, and the agency has filed a response. Petition for Review (PFR) File, Tabs 1, 3. On review, the appellant challenges the administrative judge’s finding that the agency met its burden of proof concerning the charge and the reasonableness of the penalty. PFR File, Tab 1 at 6-9, 13-15. He argues that the administrative judge erred in crediting the testimony of both his first-level supervisor and the deciding official. Id. at 11-13. He also reasserts most of his due process claims and raises new ones. PFR File, Tab 1 at 9-11, 14-15.

DISCUSSION OF ARGUMENTS ON REVIEW The administrative judge properly sustained the charge. The agency proposed and ultimately removed the appellant based on a single, unlabeled narrative charge. IAF, Tab 7 at 11-15, 87-92. It generally described his misconduct as sending an email with “threatening language” and being under the influence of alcohol such that it could interfere with his work performance or the maintenance of discipline. Id. at 13, 87. The administrative judge found that the agency proved its charge, including that the appellant sent 2 In Douglas v. Veterans Administration, 5 M.S.P.R. 280, 305-06 (1981), the Board provided a nonexhaustive list of factors relevant to penalty determinations. 4

the email in question while working and was intoxicated when he did so. ID at 5-7. She also concluded that the appellant’s email caused the agency to take certain increased security measures and caused tenant organizations to release their full-time staff early on the day in question. ID at 3, 7; IAF, Tab 7 at 22. The parties do not dispute on review that the appellant sent the email while working. ID at 6; PFR File, Tab 1 at 7. However, the appellant appears to disagree that the agency’s increased security measures were sufficient to justify its description of his email as threatening. ID at 7; PFR File, Tab 1 at 14. He concedes that he had “one drink during lunch prior to sending his email” and that he was still under the influence of alcohol when he spoke to the police 1 hour after sending the email. Hearing Transcript (HT) at 13, 16 (testimony of the appellant); IAF, Tab 7 at 97; PFR File, Tab 1 at 7. However, he disagrees that, as charged by the agency, he was intoxicated such that he could not perform his job duties. PFR File, Tab 1 at 6-7. He also argues that the agency failed to prove that his email interfered with the maintenance of discipline. Id. at 8. We turn first to the appellant’s arguments that the agency’s security measures do not reflect that his email was threatening, and, relatedly, that the agency failed to prove his email was prejudicial to the maintenance of discipline. PFR File, Tab 1 at 6-7, 11. Although not framed by the appellant as such, we find that these arguments go to the interpretation of the agency’s charge. An agency is not required to affix a label to a charge but may simply describe actions that constitute misbehavior in narrative form in its charge letter. Otero v. U.S. Postal Service, 73 M.S.P.R. 198, 202-03 (1997). Hypertechnical common law pleading is not Board practice, and so an agency is not required to narrowly label its charge with magic words for it to be sustained by the Board. Id. at 203. Here, the administrative judge appropriately found that the gravamen of the agency’s charge was that the appellant sent the email at issue and was impaired by alcohol during the workday.

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

Related

Ward v. United States Postal Service
634 F.3d 1274 (Federal Circuit, 2011)
Jenkins v. Department of the Treasury
244 F. App'x 349 (Federal Circuit, 2007)
Phillips v. Department of the Interior
131 F. App'x 709 (Federal Circuit, 2005)
Stanley B. Parker v. United States Postal Service
819 F.2d 1113 (Federal Circuit, 1987)
Todd R. Haebe v. Department of Justice
288 F.3d 1288 (Federal Circuit, 2002)
Harding v. United States Naval Academy
567 F. App'x 920 (Federal Circuit, 2014)
Purifoy v. Department of Veterans Affairs
838 F.3d 1367 (Federal Circuit, 2016)
Perry v. Merit Systems Protection Bd.
582 U.S. 420 (Supreme Court, 2017)
Johnson v. Air Force
50 F.4th 110 (Federal Circuit, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
William Doyle v. Department of the Army, Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-doyle-v-department-of-the-army-mspb-2024.