WILLIAM H. DUPREE v. DISTRICT OF COLUMBIA DEPARTMENT OF CORRECTIONS and DISTRICT OF COLUMBIA OFFICE OF EMPLOYEE APPEALS

132 A.3d 150, 2016 D.C. App. LEXIS 39, 2016 WL 683300
CourtDistrict of Columbia Court of Appeals
DecidedFebruary 18, 2016
Docket14-CV-860
StatusPublished
Cited by10 cases

This text of 132 A.3d 150 (WILLIAM H. DUPREE v. DISTRICT OF COLUMBIA DEPARTMENT OF CORRECTIONS and DISTRICT OF COLUMBIA OFFICE OF EMPLOYEE APPEALS) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
WILLIAM H. DUPREE v. DISTRICT OF COLUMBIA DEPARTMENT OF CORRECTIONS and DISTRICT OF COLUMBIA OFFICE OF EMPLOYEE APPEALS, 132 A.3d 150, 2016 D.C. App. LEXIS 39, 2016 WL 683300 (D.C. 2016).

Opinion

GLICKMAN, Associate Judge:

As part of a , mandated reduction-in-force (RIF), the District of Columbia Department of Corrections (the Department) released William H. Dupree from his employment as a criminal investigator in August 2001. Dupree’s first appeal of that decision eventually reached this court, and we remanded the casé to the Office of Employee Appeals (OEA) for its interpretation of the RIF regulations 1 and an evi-dentiary hearing on certain of Dupree’s *152 claims. 2

On remand, an OEA administrative judge took evidence and again upheld Du-pree’s separation in the RIF, and the Superior Court affirmed that decision. Du-pree appeals once more to this court. He argues that the OEA judge erred in interpreting and applying the RIF regulations. For the following reasons, we disagree and affirm the OEA decision.

I.

Appellant was released from his employment as a criminal investigator with the Department on August 3, 2001, in one of several RIFs connected with the closing of the District’s correctional facilities in Lor-ton, Virginia. The Department abolished several hundred positions in this RIF, including five of its ten criminal investigator positions.

Under the provisions of the Comprehensive Merit Personnel Act (CMPA) 3 pertaining to RIFs and the regulations in effect in 2001, government employees subject to a RIF had the right to a single round of lateral competition for remaining positions within the employee’s competitive level. 4 The competition was seniority-based: For each competitive level, the District of Columbia Office of Personnel (DCOP) determined “retention standings” by assigning each competing employee a “service computation date” (SCD) based on length of government service with credits for District of Columbia residency, pri- or military service, and outstanding performance. 5 The credit for outstanding performance is the only one at issue in this case. An employee who, at the time of a RIF, had received a “current performance rating” of “outstanding” was credited with four years of additional service. 6 The term “current performance rating” was defined to mean “the performance rating for the year which ended on the March 31 preceding the date of the reduction-in-force notice,” 7 and for the credit to be available, “the performance rating must have been officially acted upon with all the necessary approvals [and] received in the appropriate personnel office” no later than thirty days before the RIF notice is issued. 8 The regulations specified that a performance rating received after that date “shall not change the employee’s retention standing.” 9

The competing employees were ranked by their SCDs in a “retention register” used to identify the employees who would be released from service due to the abol-ishment of their positions. Employees selected for separation in the RIF were given thirty days’ written notice of the effective date of their release. 10 ' The notices also informed the released employees of their rights, which included the rights to inspect records pertaining to *153 their cases and to appeal. 11

The RIF in which appellant was released was authorized by the Mayor in May 2001. Appellant and nine other criminal investigators “competed” for the five remaining criminal investigator positions. That is to say, the DCOP generated a retention register, ranking the criminal investigators by their SCDs in order to identify the employees who would be released from service. The DCOP issued the criminal investigator retention register on June 27, 2001. Based on his SCD, appellant was ranked eighth out of ten and hence was slated for release. He received notice on' June 28 that the effective date of his separation would be August 3,2001.

He appealed. In Dupree I, we directed the OEA on remand to construe the regulations governing two of appellant’s contentions and provide him with an eviden-tiary hearing on them. Each contention was a challenge to appellants ranking in the retention register. .

First, appellant argued that the Department should have revised the June 27 register to reflect the voluntary retirements of three criminal investigators after the register was issued and before the RIF effective date. 12 The retiring investigators all were ranked ahead of appellant, and one of them was ranked in the top five, so if the Department had issued a new retention register excluding all three retirees, appellant would have ranked fifth instead of eighth and would not have been released in the RIF. Instead, by not revising the register, the Department effectively left one of the five retained criminal investigator positions unfilled even as it separated Dupree and two other investigators. In remanding for further consideration of appellant’s argument, we noted that the CMPA and the RIF regulations were “silent regarding the effect, if any, of retirements on the RIF procedures,” and that when confronted with such silence, we look “in the first instance” to the administrative agency charged with administering the law to interpret its requirements. 13

Second, appellant argued that' the Department violated the RIF regulations by using prior-year performance Ratings, instead of current-year ratings, to adjust the criminal investigators’ SCDs, while simultaneously denying him a service credit for his own-“outstanding” prior-year rating. The Department used the performance ratings for the prior year (i.e., for the year ending March 31, 2000) because the current-year ratings (for the year ending March 31, 2001) were not properly approved and received before the thirty-day deadline set by the regulations. • Appellant was not credited for his “outstanding” pri- or-year rating because he had been a criminal investigator for .only nine months that year. Because the RIF regulations were “silent as to what, happens, when the current yqar’s performance ratings have not been completed prior to the RIF,” we directed the OEA in Dupree Í to determine on remand whether the regulations permitted use of the prior year’s ratings in that situation. 14 We noted that appellant’s ranking iri the retention register would not change if the prior-year ratings were not *154 utilized. 15 But if it was proper to use the prior-year ratings', then, we held, appellant should have been given credit for his “outstanding” rating that year, which could improve his ranking by one position. 16

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Cite This Page — Counsel Stack

Bluebook (online)
132 A.3d 150, 2016 D.C. App. LEXIS 39, 2016 WL 683300, Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-h-dupree-v-district-of-columbia-department-of-corrections-and-dc-2016.