) Request No. 05960575

Equal Employment Opportunity CommissionJul 22, 1999
04990032 (E.E.O.C. Jul. 22, 1999)

04990032

07-22-1999

) Request No. 05960575


Barbara Flynt v. Department of Housing and Urban Development

04990032

July 22, 1999

Barbara Flynt, )

Petitioner, )

)

v. ) Petition No. 04990032

) Request No. 05960575

Andrew M. Cuomo, ) Appeal No. 01943653

Secretary, ) Agency No. AT-91-07

Department of Housing ) Hearing No. 140-94-8055X

and Urban Development )

Agency. )

___________________________________)

DECISION ON A PETITION FOR ENFORCEMENT

On March 26, 1999, the Equal Employment Opportunity Commission, docketed

a petition for enforcement to examine the implementation of its order

in Barbara Flynt v. Andrew M. Cuomo, Secretary, Department of Housing

and Urban Development, EEOC Request No. 05960575 (April 2, 1998). This

petition for enforcement is accepted by the Commission pursuant to 29

C.F.R. �1614.503.

In Request No. 05960575, the Commission ordered the agency, inter alia,

to offer petitioner reinstatement to the position of secretary, GS-4, at

its facility in Greensboro, North Carolina, or a comparable position in

the Greensboro area, retroactive to July 20, 1990.<1> In her petition for

enforcement, petitioner indicates that she accepted the agency's offer

to reinstate her as an office automation clerk. She argues, however,

that the position is not comparable with the secretarial position from

which she was terminated. She indicated that there were secretarial

positions in the Greensboro facility, and emphasized that she wanted her

title of "secretary" restored to her. Alternatively, she stated that she

wanted the opportunity to advance to the level of others in her group.

Regarding petitioner's reinstatement to a GS-4 secretarial position,

the compliance record includes a letter to the Commission from the

director of the agency's office of management, dated July 15, 1998.

The letter states that the agency had offered petitioner a position as

a GS-4 secretary in its Greensboro facility. A letter from that same

official to petitioner, dated July 21, 1998, however, indicates that the

agency offered petitioner a position as a GS-303-4 office automation

clerk, with promotion potential to GS-5. In a hand-written response

dated July 30, 1998, petitioner accepted the agency's offer. In a letter

to the Compliance Officer dated April 22, 1999, the agency stated that

the office automation clerk's position is the only comparable position

to the secretarial position in which she was previously employed, and

that petitioner had accepted that position on the advice of counsel.

The agency also noted that petitioner had been hired as a GS-4 and

promoted to GS-5. In addition to its letter, the agency submitted a

staffing chart that listed petitioner as a GS-5. In terms of salary at

least, it appears that petitioner was given the opportunity to advance

to the level of others in her group, since the office automation clerk

position promotion potential ends at GS-5.

In her petition, petitioner argues that the automation clerk position

is not comparable with the secretarial position. She maintains that

the clerk position is inferior because her only duties included typing,

filing, and answering the telephone. In support of its April 22, 1999

letter, the agency submitted position descriptions for the 1990 secretary

position and the 1998 office automation clerk position. These documents

indicate that the secretarial position had evolved into the office

automation clerk position, primarily because of advances in office

automation technology. For example, in 1990, the incumbent needed to

know how to use a typewriter. In 1998, the incumbent had to know how

to use an electric typewriter, a word processor, or a microcomputer

with word-processing and other advanced functions. After reviewing

the descriptions for the two positions, the Commission agrees with the

agency that the office automation clerk position is the closest position

to the secretarial position that petitioner held while employed in 1990.

Based upon its review of the record, the Commission finds that the

agency has fully complied with its order in Request No. 05960575,

requiring that petitioner be offered reinstatement to a GS-4 secretarial

position. Consequently, no further compliance action is necessary.

We therefore deny this petition for enforcement.

STATEMENT OF PETITIONER'S RIGHTS ON PETITION FOR ENFORCEMENT

RIGHT TO FILE A CIVIL ACTION (P0993)

This decision of the Commission is final, and there is no further right of

administrative appeal from the Commission's decision. You have the right

to file a civil action in an appropriate United States District Court.

It is the position of the Commission that 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.

You should be aware, however, that courts in some jurisdictions have

interpreted the Civil Rights Act of 1991 in a manner suggesting that

a civil action must be filed WITHIN THIRTY (30) CALENDAR DAYS from the

date that you receive this decision. To ensure that your civil action

is considered timely, you are advised to file it WITHIN THIRTY (30)

CALENDAR DAYS from the date that you receive this decision or to consult

an attorney concerning the applicable time period in the jurisdiction

in which your action would be filed. 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.

RIGHT TO REQUEST COUNSEL (Z1092)

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:

July 22, 1999

_______ _____________________

DATE Frances M. Hart

Executive Officer

Executive Secretariat

1The order in EEOC Request No. 05960575 includes other elements, none of

which petitioner raises herein. The Commission will therefore continue to

monitor compliance with respect to those elements.