Abeni Ogun, Complainant,v.Hector V. Barreto, Administrator, Small Business Administration, Agency.

Equal Employment Opportunity CommissionNov 29, 2005
01a44339 (E.E.O.C. Nov. 29, 2005)

01a44339

11-29-2005

Abeni Ogun, Complainant, v. Hector V. Barreto, Administrator, Small Business Administration, Agency.


Abeni Ogun v. Small Business Administration

01A44339

November 29, 2005

.

Abeni Ogun,

Complainant,

v.

Hector V. Barreto,

Administrator,

Small Business Administration,

Agency.

Appeal No. 01A44339

Agency No. 12-03-003

DECISION

Complainant timely initiated an appeal from a final agency decision

(FAD) concerning her complaint of unlawful employment discrimination

in violation of Title VII of the Civil Rights Act of 1964 (Title VII),

as amended, 42 U.S.C. � 2000e et seq. The appeal is accepted pursuant

to 29 C.F.R. � 1614.405. For the following reasons, the Commission

affirms the agency's final decision.

The record reveals that during the relevant time, complainant was

employed as an Accountant at the Denver Finance Center, located in

Denver, Colorado. Complainant sought EEO counseling and subsequently

filed a formal complaint on December 4, 2002, alleging that she was

discriminated against and subjected to a hostile work environment on the

bases of race (Black), national origin (Nigerian), and in reprisal for

prior EEO activity. Complainant sets forth several instances of alleged

harassment from January 2000 until she left the agency in December 2002.

Specifically, complainant alleged that her coworkers often called her

names and made racial comments<1>; and her coworkers were tampering

with her computer and disconnecting her telephone. Complainant also

alleged that she was discriminated against on the bases of race and

national origin when she was not selected for Accountant positions under

vacancy announcements 02-D-1127-DB and 02D-1132-DB; and when in 2002,

she received a lower performance rating than in previous years.

At the conclusion of the investigation, complainant was informed of

her right to request a hearing before an EEOC Administrative Judge

or alternatively, to receive a final decision by the agency. When

complainant failed to respond within the time period specified in 29

C.F.R. � 1614.108(f), the agency issued a final decision.

In its FAD, the agency concluded that complainant failed to establish

a prima facie case of harassment. Specifically, the agency found

that none of the alleged incidents of harassment, if they occurred as

described by complainant, were unduly severe, nor did they unreasonably

interfere with complainant's work performance. The agency also found

that management investigated complainant's allegations of harassment,

but the allegations were never substantiated. The agency found that

the investigation did not lead to any evidence that there were racial

conflicts, as much as personality conflicts. The agency further found

that management was aware that complainant was having difficulties with

her telephone, and they did replace her phone, but they could not prove

anyone was tampering with her phone.

The agency also concluded that management articulated legitimate,

non-discriminatory reasons for complainant's non-selections, that

complainant failed to rebut. The agency found that there were three

Certificates of Eligibles for the GS-9, 11 and 12 levels for the

seven Accountant positions advertised under the vacancy announcement

02-D-1127-DB. However, the agency noted that complainant only applied for

the Grade-12 certification list of eligibles. The record reveals that

on the Grade 12 Certificate of Eligibles, a veteran applicant appeared

on the list ahead of complainant. The agency found that the selecting

officials were unable to pass over a veteran to select a non-veteran

without getting permission from Office of Personal Management (OPM).

Therefore, the agency concluded that complainant could not be considered

for the remaining selections, on the Grade 9 and Grade 11 Certificate

of Eligibles, because she only applied at the Grade 12 level.<2>

The agency noted that complainant alleged that she was discriminated

against when she was not selected for one of four Accountant positions

listed under vacancy announcement 02D-1132-DB, and that she should be

eligible under the Outstanding Scholar program. The agency found that

complainant did apply for the position, but that, as a term employee,

complainant did not have competitive status, as was called for in the

vacancy announcement. Additionally, the agency found that complainant

had never been a permanent employee; therefore, complainant did not have

competitive status and she could not be referred under Merit Promotion

rules. Consequently, complainant could not apply as an Outstanding

scholar. Therefore, the agency concluded that management was unable

to consider complainant for the 02D-1132-DB job vacancy because she was

not eligible.

The agency also concluded that complainant failed to establish a claim

when she alleged that her performance appraisal was being lowered.

Specifically, the agency found that complainant's performance element for

communication and cooperation remained "Fully Successful" during 2000,

2001, and 2002. The agency also found that complainant's 2000 performance

appraisal had an overall rating of "Fully Successful"; while in both 2001

and 2002 complainant received an overall rating of "Exceeds Successful."

Therefore, the agency concluded that complainant's performance appraisals

did not go down and her overall rating increased over time.

On appeal, complainant contends, among other things, that she was

subjected to racially motivated comments and conduct on a repeated and

on-going basis and not simply in isolated instances, as the FAD states.

Specifically, complainant contends that beginning in approximately January

2000, three of her co-workers repeatedly told her (many times every week)

to "go back to Africa," called her a "slave from Africa," stated that

"Africans sleep on trees" and come to this country to "steal our men,"and

called her an "animal who slept in a tree." Complainant also contends

that her co-workers told her that they would "frustrate her out," meaning

that they would make her working environment so intolerable that she

would leave. Complainant further contends that she verbally complained

every week to her supervisor, who indicated that he "would look into

it," but he never did. Complainant contends that after her written

complaint, her co-workers continued to harass her and call her names.

Complainant also contends that her co-workers harassed her and made her

job nearly impossible to perform by turning off and/or tampering with

her telephone and computer system. Finally, complainant contends that

management manipulated the selection process to not select her for any

of the positions.

The agency requests that we affirm its FAD.

ANALYSIS AND FINDINGS

Harassment based on national origin

National origin harassment violates Title VII when it is so severe or

pervasive that the individual being harassed reasonably finds the work

environment to be hostile or abusive. Meritor Savings Bank v. Vinson,

477 U.S. 57 (1986). Harassment based on national origin can take on many

different forms, including ethnic slurs, workplace graffiti, or other

offensive conduct directed towards an individual's birthplace, ethnicity,

culture or foreign accent. A hostile work environment may be created by

the actions of supervisors, co-workers, or even non-employees, such as

customers or business partners. Relevant factors in evaluating whether

national origin harassment rises to the level of creating a hostile work

environment may include any of the following: (1) whether the conduct was

physically threatening or intimidating; (2) how frequently the conduct was

repeated; (3) whether the conduct was hostile and/or patently offensive;

(4) the context in which the harassment occurred; and (5) whether

management responded appropriately when it learned of the harassment.

See EEOC Compliance Manual on National Origin Discrimination, No. 925.003

(hereinafter, "Compliance Manual").

Employers and employees each play an essential role in preventing national

origin harassment. Failure by an employer to take appropriate steps to

prevent or correct harassment may contribute to employer liability for

unlawful harassment. Likewise, failure by an employee to take reasonable

steps to report harassment may preclude the employee from being able to

hold an employer responsible for the harassment. An employer is liable

for unlawful national origin harassment by co-workers or non-employees

if the employer knew or should have known about the harassment and failed

to take immediate and appropriate corrective action. The most important

step for an employer in preventing harassment is clearly communicating to

employees that harassment based on national origin will not be tolerated

and that employees who violate the prohibition against harassment will

be disciplined. In addition, an employer should have effective and

clearly communicated policies and procedures for addressing complaints of

national origin harassment and should train managers on how to identify

and respond effectively to harassment. See Compliance Manual, supra.

To prevail in a harassment claim, complainant must show that: (1)

she belongs to a statutorily protected class; (2) she was subjected

to unwelcome conduct; (3) the conduct complained of was based on

her protected status; (4) the conduct had the purpose or effect of

unreasonably interfering with her work performance and/or creating an

intimidating, hostile, or offensive work environment; and (5) there

is a basis for imputing liability to the employer. McCleod v. Social

Security Administration, EEOC Appeal No. 01963810 (August 5, 1999).

In the instant complaint, complainant alleged several incidents

of alleged harassment by coworkers based on her national origin.

Complainant alleged that in October 1999, a female coworker (TK)

invited her and another coworker (AH) to spend the weekend in her house.

At first complainant agreed, but the next day complainant declined the

invitation. Complainant alleged that from that day, TK started acting

very "strange." For example, sometimes she did not answer complainant's

"good morning." Complainant alleged that three weeks after the incident,

when she declined the invitation, another female coworker (M) told

her: "Why do you come here dressed up every day..." "We just want to

be sure that you are not trying to rival with us and take our men."

Complainant alleged that since the day she declined the invitation, she

"became the enemy" of her coworkers. Complainant stated that she said

"good morning" to all of her coworkers and some would answer and some

would not. Complainant also alleged that as a part of the harassment,

M told her "if you think you are too good for our group, you will be

frustrated out of here."

Complainant further alleged that her coworkers began disrupting her

telephone on a number of occasions. Specifically, she alleged that her

telephone was unplugged and switched off from the action main line. We

find, however, that the record did not support complainant's allegations.

The record reveals that the agency's telephone system is very old and

complainant seemed to have problems using the codes in the system.

The record further indicates that complainant received a couple of new

telephones in case there was a problem with her equipment. The record

shows that others in the office also had problems with their phones

on occasion. Regarding these allegations, we conclude that complainant

has failed to establish a prima facie case of hostile work environment

harassment in that she failed to demonstrate that the complained of

conduct was based on her protected status. Specifically, we find that

complainant admitted that these incidents occurred when she declined an

invitation for a overnight party. Nothing in the record shows that any of

these alleged incidents were related to complainant's national origin.

Complainant further alleged that on many occasions (weekly basis) she

was referred to as "slave from Africa," and "she and Africans slept in

trees," and she heard comments like "all of these foreigners think they

are so smart when they come over and take our jobs." For the purpose

of our further analysis, we will assume that these incidents occurred

as complainant alleged.

We find that complainant established that she belonged to a statutorily

protected class by virtue of her national origin; she was subjected

to unwelcome conduct related to her national origin; and the conduct

was sufficiently severe and pervasive to alter the condition of

complainant's employment. However, we find that the agency acted

promptly and appropriately to prevent further harassment once complainant

brought her complaints to management. Specifically, the record reveals

that once complainant complained about racial slurs and epithets,

management conducted an investigation which included an interview of

all complainant's coworkers mentioned by her as the perpetrators of the

harassment. The record further reveals that management interviewed and

obtained statements from complainant's coworkers and other coworkers

who may have been in a position to observe or overhear complainant's

allegations. The agency's investigative report reveals that the agency's

investigation did not support complainant's harassment allegations.

While complainant brought a witness in her harassment claim; her witness

admitted that she never "witnessed anything" regarding racial comments

concerning complainant, she also stated that her only information was just

"hearsay, nothing directly."<3> The record shows that after complainant's

allegations, management provided on a regular basis, diversity and

discrimination training, covering harassment issues, to all employees.

The record also shows an e-mail, dated December 13, 2000, from complainant

to the Director of the Denver Finance Center in which she stated: "Thanks

for trying your best to make this environment a comfortable place to

work for everyone. For me [complainant], the meeting was a reinforcement

that this office does not support unfair and discriminating practices."

Complainant's testimony also reveals that management periodically

monitored and asked her about the work environment. The record shows that

management offered complainant the option to move to another division,

and that complainant refused. Generally, in harassment claims, the

agency may not involuntarily transfer or reassign complainant, the agency

should transfer or reassign the alleged harasser; however, because in

the instant case complainant cited the entire office as responsible for

the harassment, we find that the agency's offer was appropriate.

Accordingly, based on the record before us, we conclude that the agency

took prompt remedial action, and complainant has not shown that there

is a basis for imputing liability to the agency.

Disparate Treatment Claim

As a general matter, in the absence of direct evidence of discrimination,

claims of discrimination alleging disparate treatment are examined

under the tripartite analysis first enunciated in McDonnell Douglas

Corp. v. Green, 411 U.S. 792 (1973). Under this analytical framework,

the complainant must first establish a prima facie case of discrimination

by presenting facts that, if unexplained, reasonably give rise to an

inference of discrimination, i.e., that a prohibited reason was a factor

in the adverse employment action. McDonnell Douglas, 411 U.S. at 802;

Furnco Constr. Corp. v. Waters, 438 U.S. 567 (1978). Next, the agency

must articulate a legitimate, nondiscriminatory reason for its action(s).

Texas Dep't of Community Affairs v. Burdine, 450 U.S. 248 (1981). After

the agency has articulated the reason for its action, the burden returns

to the complainant to demonstrate, by a preponderance of the evidence,

that the agency's reason was pretextual--that is, it was not the true

reason, or the action was influenced by legally impermissible criteria.

Burdine, 450 U.S. at 253. However, the ultimate burden of persuading

the trier of fact that the agency intentionally discriminated against

complainant remains at all times with complainant. Reeves v. Sanderson

Plumbing Prods., Inc., 530 U.S. 133, 143 (2000) (quoting Burdine, 450

U.S. at 253).

Even assuming arguendo that complainant established a prima facie case

of discrimination on the bases of race, national origin and retaliation,

we conclude that the agency articulated a legitimate, nondiscriminatory

reason for its action. The record reveals that complainant was not

selected for the Accountant positions listed under vacancy announcement

02D-1127-DB, because complainant was third on the Certificate of Eligibles

and there were two veterans ahead of her. The agency stated that veterans

cannot be bypassed for non-veterans. The record further reveals that

complainant was not selected for the Accountant positions listed under

vacancy announcement 02D-1132-DB, because complainant was not eligible.

Specifically, the record discloses that complainant, a term employee,

could not be considered for the position because it was announced as a

merit promotion action. The agency established that term employees are

not eligible for career status positions and are required to compete as

outside candidates.

The burden returns to complainant to establish that the agency's

explanation was a pretext for discrimination. Upon review, the Commission

finds that complainant failed to do so. In reaching this conclusion, we

note that complainant failed to rebut that the selectees were applicants

with veterans preference or demonstrate that term employees can apply

for a merit promotion action. We conclude that complainant did not show

that the agency's action was based upon discriminatory animus toward

complainant's protected classes.

Finally, the record shows that complainant's 2002 appraisal rating was

not lower than the previous year. The record shows that her summary

ratings were "satisfactory" for the first two years and the last two

years she was rated "fully successful."

Therefore, after a careful review of the record, including complainant's

contentions on appeal, the agency's response, and arguments and evidence

not specifically addressed in this decision, we affirm the FAD.

STATEMENT OF RIGHTS - ON APPEAL

RECONSIDERATION (M0701)

The Commission may, in its discretion, reconsider the decision in this

case if the complainant or the agency submits a written request containing

arguments or evidence which tend to establish that:

1. The appellate decision involved a clearly erroneous interpretation

of material fact or law; or

2. The appellate decision will have a substantial impact on the policies,

practices, or operations of the agency.

Requests to reconsider, with supporting statement or brief, must be filed

with the Office of Federal Operations (OFO) within thirty (30) calendar

days of receipt of this decision or within twenty (20) calendar days of

receipt of another party's timely request for reconsideration. See 29

C.F.R. � 1614.405; Equal Employment Opportunity Management Directive for

29 C.F.R. Part 1614 (EEO MD-110), 9-18 (November 9, 1999). All requests

and arguments must be submitted to the Director, Office of Federal

Operations, Equal Employment Opportunity Commission, P.O. Box 19848,

Washington, D.C. 20036. In the absence of a legible postmark, the

request to reconsider shall be deemed timely filed if it is received by

mail within five days of the expiration of the applicable filing period.

See 29 C.F.R. � 1614.604. The request or opposition must also include

proof of service on the other party.

Failure to file within the time period will result in dismissal of your

request for reconsideration as untimely, unless extenuating circumstances

prevented the timely filing of the request. Any supporting documentation

must be submitted with your request for reconsideration. The Commission

will consider requests for reconsideration filed after the deadline only

in very limited circumstances. See 29 C.F.R. � 1614.604(c).

COMPLAINANT'S RIGHT TO FILE A CIVIL ACTION (S0900)

You have the right to file a civil action in an appropriate United States

District Court within ninety (90) calendar days from the date that you

receive this decision. If you file a civil action, you must name as

the defendant in the complaint the person who is the official agency head

or department head, identifying that person by his or her full name and

official title. Failure to do so may result in the dismissal of your

case in court. "Agency" or "department" means the national organization,

and not the local office, facility or department in which you work. If you

file a request to reconsider and also file a civil action, filing a civil

action will terminate the administrative processing of your complaint.

RIGHT TO REQUEST COUNSEL (Z1199)

If you decide to file a civil action, and if you do not have or cannot

afford the services of an attorney, you may request that the Court appoint

an attorney to represent you and that the Court permit you to file the

action without payment of fees, costs, or other security. See Title VII

of the Civil Rights Act of 1964, as amended, 42 U.S.C. � 2000e et seq.;

the Rehabilitation Act of 1973, as amended, 29 U.S.C. �� 791, 794(c).

The grant or denial of the request is within the sole discretion of

the Court. Filing a request for an attorney does not extend your time

in which to file a civil action. Both the request and the civil action

must be filed within the time limits as stated in the paragraph above

("Right to File A Civil Action").

FOR THE COMMISSION:

______________________________

Carlton M. Hadden, Director

Office of Federal Operations

November 29, 2005

__________________

Date

1She testifies that her coworkers called her

�slave� and told her �go back to Africa and sleep on a tree.�

2Under vacancy announcement 02D-1127-DP: a male veteran, was selected

from the Grade 12 Certificate of Eligibles; one male veteran, and a male

non-veteran, were selected from the Grade 9 Certificate of Eligibles;

two females were selected from the Competitive Eligibles List; and two

females were selected from the Noncompetitive Eligibles List.

3Complainant's witness testified that she heard comments from some of

complainant's coworkers that other coworkers made derogatory comments

towards complainant.