Loretta Sanders, Complainant,v.Donald H. Rumsfeld, Secretary, Department of Defense, (Defense Commissary Agency), Agency.

Equal Employment Opportunity CommissionJul 19, 2006
01A41854 (E.E.O.C. Jul. 19, 2006)

01A41854

07-19-2006

Loretta Sanders, Complainant, v. Donald H. Rumsfeld, Secretary, Department of Defense, (Defense Commissary Agency), Agency.


Loretta Sanders,

Complainant,

v.

Donald H. Rumsfeld,

Secretary,

Department of Defense,

(Defense Commissary Agency),

Agency.

Appeal No. 01A41854

Agency Nos. 01DCM07C01 & 01DCM07C02

Hearing No. 310-2002-05221X

DECISION

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

appeal from the agency's December 29, 2003 final order in the above-

entitled matter. Complainant claimed that the agency discriminated against

her based on her race/color (African-American/black), disabilities

(physical and mental), and reprisal for prior protected EEO activity under

Title VII of the Civil Rights Act of 1964 and Section 501 of the

Rehabilitation Act of 1973, as applicable when (1) she received a lowered

performance appraisal rating (Excellent) because she reported a work

related injury during the rating period of July 7, 1999 through June 30,

2000, (2) she initially received a lower performance appraisal rating for

the rating period of July 1, 2000 through June 30, 2001, (3) management

allegedly violated her medical profile (duties outside her medical

limitations), and (4) she was not allowed to make food purchases in the

Commissary.

Pursuant to 29 C.F.R. � 1614.405(a), all post-hearing factual findings by

an EEOC Administrative Judge (AJ) will be upheld if supported by

substantial evidence in the record. Substantial evidence is defined as

"such relevant evidence as a reasonable mind might accept as adequate to

support a conclusion." Universal Camera Corp. v. National Labor Relations

Board, 340 U.S. 474, 477 (1951) (citation omitted). A finding regarding

whether or not discriminatory intent existed is a factual finding. See

Pullman-Standard Co. v. Swint, 456 U.S. 273, 293 (1982). An AJ's

conclusions of law are subject to a de novo standard of review, whether or

not a hearing was held.

The Commission notes that one witness in this case testified over the

telephone without the objection of the parties. The Commission has,

however, recently held that testimony may not be taken by telephone in the

absence of exigent circumstances, unless at the joint request of the

parties and provided that specified conditions have been met. See Louthen

v. USPS, EEOC Appeal No. 01A44521 (May 17, 2006).[1] Because the facts of

this case pre-date Louthen, the Commission will assess the propriety of

conducting the hearing by telephone, by considering the totality of the

circumstances. The witness in question was called to testify by the

agency. The witness testified at the September 2003 hearing that he

retired around January 2002 from the Civil Service. An example of an

exigent circumstance is a witness who is not a federal employee or who left

federal service that cannot be compelled to appear in person and may

nonetheless be willing to testify telephonically. Louthen. Such is the

case here.

After a review of the record in its entirety, including consideration of

all statements submitted on appeal, it is the decision of the Equal

Employment Opportunity Commission to affirm the final agency order because

the AJ's ultimate finding, that unlawful employment discrimination was not

proven by a preponderance of the evidence, is supported by the record.[2]

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

July 19, 2006

__________________

Date

-----------------------

[1] In Louthen, the Commission has promulgated its policy regarding the

taking of telephonic testimony in the future by setting forth explicit

standards and obligations on its Administrative Judges and the parties.

Louthen requires either a finding of exigent circumstances or a joint and

voluntary request by the parties with their informed consent. When

assessing prior instances of telephonic testimony, the Commission will

determine whether an abuse of discretion has occurred by considering the

totality of the circumstances. In particular, the Commission will consider

factors such as whether there were exigent circumstances, whether a party

objected to the taking of telephonic testimony, whether the credibility of

any witnesses testifying telephonically is at issue, and the importance of

the testimony given telephonically. Further, where telephonic testimony

was improperly taken, the Commission will scrutinize the evidence of record

to determine whether the error was harmless.

[2] For purposes of analysis only, we assume without finding that

complainant is an individual with a disability. See 29 C.F.R. �

1630.2(g)(1).