Wally M. DeRose, Complainant,v.Colin L. Powell, Secretary, Department of State, Agency.

Equal Employment Opportunity CommissionMar 21, 2003
01A23472 (E.E.O.C. Mar. 21, 2003)

01A23472

03-21-2003

Wally M. DeRose, Complainant, v. Colin L. Powell, Secretary, Department of State, Agency.


Wally M. DeRose v. Department of State

01A23472

03-21-03

.

Wally M. DeRose,

Complainant,

v.

Colin L. Powell,

Secretary,

Department of State,

Agency.

Appeal No. 01A23472

Agency No. 98-20

DECISION

INTRODUCTION

Complainant filed an appeal with this Commission concerning his contention

that the agency has violated the terms of its January 30, 2001 final

decision, which was amended by the agency on May 22, 2001. Pursuant to

29 C.F.R. � 1614.405, the Commission accepts the complainant's appeal

in the above-entitled matter.

ISSUE PRESENTED

The issue on appeal is whether the agency properly decided that it had

complied with its January 30, 2001 final decision, as amended by its

supplemental decision on May 22, 2001.

BACKGROUND

In its January 30, 2001 final decision, the agency found that complainant

was discriminated against on the bases of age (59) and in reprisal for

engaging in prior EEO protected activity<1> when he was denied employment

(reappointment) as a Foreign Service Diplomatic Security Officer.

The following remedies where ordered:

The Department will expeditiously offer complainant reappointment to

a Foreign Service Diplomatic Security Agent FP-4 position, with back

pay from February 1992. Should the complainant decline that offer,

his entitlement to back pay and related benefits shall terminate as of

the date of his declination.

The Department will restore any compensatory and sick leave accrued

and credited to complainant as of the date of his resignation.

The Department will fully restore any retirement benefits that would

have accrued from 1992 to the date that complainant's reappointment

becomes effective.

The Department will expunge from complainant's personnel records

any references or documents related to the Stipulation of Settlement

Agreement executed on June 6, 1994.

The Department will allow the complainant to inspect his personnel file

and review all performance evaluations contained therein.

The Department will pay reasonable and documented Attorney's fees

encountered by complainant in this matter.

In a footnote, the agency indicated that:

It is theoretically possible that complainant might not now be eligible

for reappointment on security, suitability or fitness grounds. If the

Department makes any such determination, it shall be subject to the

strictest scrutiny. However, should the determination be meritorious,

complainant's entitlement to back pay and related benefits would be

terminated as of the date of such a determination.

On May 22, 2001, the agency issued a supplemental decision that withdrew

Remedial Measures (2) and (6). Remedial Measure (2) was withdrawn

because it was resolved pursuant to an earlier settlement agreement.

Remedial Measure (6) was withdrawn because attorney's fees are not

available for violations of the ADEA. Complainant did not file an appeal

on either of the agency's decisions.

On May 16, 2002, complainant, through his attorney, informed the

Commission that the agency had failed to comply with certain aspects of

its final decision. At the outset, he indicated that it was not until

May 1, 2002, that the agency made a �definitive offer to reappoint� him.

He also maintained that:

1) the agency refused to calculate as a component of his back pay award

a form of premium pay known as Administratively Uncontrollable Overtime

(AUO);

2) the agency's offer to reappoint him was conditioned upon his agreeing

to attend a basic training session at the Federal Law Enforcement Training

Center (FLETC) in Brunswick, Georgia, which was a unilaterally imposed

condition by the agency;

3) the agency failed to appoint complainant to a FP-3 position, a position

to which, but for the agency's delay in implementing the January 30,

2001 final decision, he would have been promoted;

4) the agency failed to include, as a factor in its back pay award,

the increased pay associated with a promotion to FP-3; and

5) the agency refused to acknowledge that complainant, upon accepting

reappointment pursuant to the final agency decision, will be eligible

to retire with a retirement calculation of 1.7% instead of 1.0% under

the Foreign Service retirement system.

The agency maintained that it had complied with its January 30, 2001 final

decision by providing the appropriate relief. Complainant, according

to the agency, is attempting to contest the remedies set forth in the

final decision even though he never filed an appeal.

ANALYSIS AND FINDINGS

The Commission's regulations provide that a complainant may appeal to this

Commission from an agency's failure to comply with its final decision.

29 C.F.R. � 1614.504(a).

At the outset, we note complainant's claim that the agency failed to

expeditiously reappoint him to his FP-4 position. The record contains

a March 29, 2001 internal memorandum that indicates, as early as

February 28, 2001, inquiries were made to, among other things, obtain

complainant's personnel records and to �prepare for his restoration

to the Department's employment rolls.� A June 1, 2001 e-mail message

indicates that complainant and the agency entered into settlement

discussions that would have included complainant's taking retirement in

lieu of reappointment. A June 7, 2001 memorandum discusses complainant's

application for reappointment and the need to update his security and

medical clearance forms. At some point, the efforts to reach a settlement

ended.<2> In a March 29, 2002 memorandum to complainant's attorney, the

agency indicated that it could not reschedule complainant's April 1-2,

2002 medical examination to the week of April 15, 2002. According to

the agency official, complainant was scheduled to attend a Diplomatic

Security class, which was to begin on April 8; therefore, he had to

have his medical examination completed prior to the start of the class.

Complainant was also informed that, if he failed to appear for the

examination, the agency would deem this as a declination of the offer.

Although complainant did not appear for his scheduled medical examination

on April 1-2, the agency rescheduled him for an examination on April

22, 2002, with a Diplomatic Security class starting on May 20, 2002.

On May 1, 2002, the agency sent complainant a letter providing him

with information concerning his upcoming class. He was also provided

a memorandum to the Board of Examiners, which required his signature.

By signing the memorandum, complainant would accept the agency's offer

of employment. On May 15, 2002, the agency sent a follow-up letter

requesting that complainant submit the signed memorandum by May 17th,

because the document was needed to process the paperwork that authorized

his travel for the May 20th class date. On June 6, 2002, the agency

informed complainant that, because he had not accepted its offer of

employment pursuant to the May 15, 2002 letter, it was terminating his

candidacy for reappointment. Complainant was also informed that his

back pay entitlement period would be February 1992 through May 17, 2002.

Based on the record before us, we do not find that there was an

unreasonable delay on the agency's part to reappoint complainant. There

were good faith efforts that complainant participated in, to resolve

this matter without complainant having to enter back on active duty.

We also note the agency's undisputed assertions that complainant's

actions contributed to the delay in processing this matter.

Claim (1)

Complainant maintained that, had he not been discriminated against, he

would have received AUO, which equals 25% of his base pay. According to

complainant, AUO is automatically paid to an employee for unscheduled,

unanticipated overtime and is guaranteed to all employees. The agency,

however, indicated that Special Agents in the Diplomatic Security Service

are not entitled to AUO. Instead, they are authorized to receive Law

Enforcement Eligibility Pay (LEAP). According to the agency, it notified

complainant that his back pay would include LEAP for the dates February

1992 through May 17, 2002. Complainant did not address the agency's

assertion. He also failed to present any evidence that would support

his claim for AOU.

We find that complainant failed to provide objective evidence that he

is entitled to AUO; therefore, we are unable to conclude that the agency

violated the January 30, 2001 final decision provision that complainant

would receive �back pay and related benefits.�

Claim (2)

Complainant argued that the agency �unjustifiably conditioned its

offer to re-employment� on his attending basic training as if he were a

new trainee. Complainant indicated that he already participated in the

training in 1986. Complainant also indicated that there was no dispute

that he was eligible for reappointment based on security, suitability

and fitness grounds. The agency maintained that it has the right to

set mandatory training requirements for its employees, and that all

employees who have been absent for 24 months or longer are required to

undergo FLETC basic training upon their return to duty.

We find that the agency's requirement that complainant attend a training

course, after he returns to duty, is not a violation of the January 30,

2001 final decision. The decision set forth the agency's obligation to

reappoint complainant. It did not preclude complainant being sent to

training after his reappointment. Nor do we find the agency's request

unreasonable, given its policy that all employees absent for 24 months

must undergo the training again.

Claims (3) and (4)

According to complainant, although the agency's final decision called for

his retroactive reinstatement to FP-4, he was entitled to a promotion

to FP-3 level because the agency did not �expeditiously� comply with

the January 30, 2001 decision. Although complainant maintained that

�employees of the agency, as of January 31, 2001, who are similarly

situated to him progressed to the FP-3 position as of the date of this

petition,� he presented no persuasive evidence that (a) he would have

been non-competitively promoted to FP-3 had the agency restored him to

his FP-4 position in January 2001, or shortly thereafter, pursuant to

its final decision, or (b) he would have been non-competitively promoted

to FP-3 had the agency never discriminated against him.

Claim (5)

Complainant maintained that he was entitled to a retroactive adjustment

to his retirement benefits. According to complainant, the agency used

the wrong formula to calculate the amount of his retirement benefits.

The agency, on the other hand, indicated that complainant was mistaken.

The agency argued that �complainant was not eligible to participate

under [the system he maintains should be applied] because his entry on

duty with the agency occurred in November 1985, following the change in

retirement systems for new hires . . . .� Complainant did not address

the agency's assertion. He also failed to present any evidence that

would support his claim for an adjustment in his retirement benefits.

We find that complainant failed to provide objective evidence that he

is entitled to an adjustment in his retirement benefits; therefore,

we are unable to conclude that the agency violated the January 30, 2001

final decision provision that complainant should receive �back pay and

related benefits.�

CONCLUSION

Based upon a review of the record and for the foregoing reasons, the

Commission finds that the complainant has not established that the agency

has not complied with its January 30, 2001 decision.

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

___03-21-03_______________

Date

1 Complainant's prior EEO activity raised a claim that the agency violated

the Age Discrimination in Employment Act.

2 In its brief, the agency maintains that between November - December

2001, complainant was advised that settlement did not seem possible, and

he should prepare himself for returning to the agency in January 2002.

The record does not contain documentation that supports this assertion

by the agency.