Mary L. McCray-Ivey, Complainant,v.Thomas J. Ridge, Secretary, Department of Homeland Security Agency.

Equal Employment Opportunity CommissionSep 17, 2004
01A43523_r (E.E.O.C. Sep. 17, 2004)

01A43523_r

09-17-2004

Mary L. McCray-Ivey, Complainant, v. Thomas J. Ridge, Secretary, Department of Homeland Security Agency.


Mary L. McCray-Ivey v. Department of Homeland Security

01A43523

September 17, 2004

.

Mary L. McCray-Ivey,

Complainant,

v.

Thomas J. Ridge,

Secretary,

Department of Homeland Security

Agency.

Appeal No. 01A43523

Agency No. CIS-04-E033

DECISION

Complainant filed an appeal with this Commission from a March 18,

2004 agency decision, dismissing her complaint pursuant to 29 C.F.R. �

1614.107(a)(2) for failure to contact an EEO Counselor in a timely manner.

In her complaint, complainant alleged that she was subjected to

discrimination on the bases of national origin (Virgin Islands) and

color (dark black) when on January 13, 2003, she was not selected for

the position of District Adjudications Officer, as advertised under

vacancy announcement ER OC 02-281(WAS), Washington District Office,

Arlington, Virginia.<1>

In its decision dismissing the complaint, the agency stated that

complainant did not initiate EEO Counselor contact until November 28,

2003, which was beyond the 45-day time limitation period. The agency

stated that complainant should have had a reasonable suspicion of

discrimination when she learned of her nonselection on January 13, 2003,

and should have initiated contact 45 days therefrom. The agency also

indicated that complainant had filed a Freedom of Information Act (FOIA)

request on January 27, 2003, and in the request, complainant stated that

the agency had discriminated against her.

On appeal, complainant states that on January 16, 2003, she was

informed by the selectee of the selection. Complainant states that on

January 31, 2003, she called the agency's EEO office at headquarters

in Washington, D.C. The first call got disconnected after she asked

the person who answered to speak to Person A. On her second call, the

same person answered and told complainant that she could not help her.

Complainant stated that on February 26, 2003, she filed a FOIA request

and on November 6, 2003, received a response regarding her request.

The record reveals that the alleged discriminatory nonselection occurred

on January 13, 2003. The record contains a January 27, 2003 FOIA request

wherein complainant stated that she had applied for several District

Adjudication Officer positions previously, that her current application

was rejected, and that the agency was discriminating. The Counselor's

Report and a Request for Information Form reflect that complainant

contacted an EEO Counselor on November 28, 2003.

EEOC Regulation 29 C.F.R. � 1614.105(a)(1) requires that complaints of

discrimination should be brought to the attention of the EEO Counselor

within forty-five (45) days of the date of the matter alleged to be

discriminatory or, in the case of a personnel action, within forty-five

(45) days of the effective date of the action. The Commission has

adopted a "reasonable suspicion" standard (as opposed to a "supportive

facts" standard) to determine when the forty-five (45) day limitation

period is triggered. See Ball v. United States Postal Service, EEOC

Request No. 05880247 (July 6, 1988). Thus, the limitations period is

not triggered until a complainant reasonably suspects discrimination,

but before all the facts that support a charge of discrimination have

become apparent. When a complainant has some reason to support the belief

that prohibited discrimination has occurred, contact with a Counselor must

occur. Waiting until one has proof of discrimination before initiating

a complaint can result in untimely contact. See Bracken v. United States

Postal Service, EEOC Request No. 05900065 (March 29, 1990).

EEOC Regulation 29 C.F.R. � 1614.105(a)(2) provides that the agency or

the Commission shall extend the time limits when an individual shows that

he or she was not notified of the time limits and was otherwise unaware

of them, that he or she did not know and reasonably should not have

known that the discriminatory matter or personnel action occurred, that

despite due diligence he or she was prevented by circumstances beyond his

or her control from contacting the counselor within the time limits, or

for other reasons considered sufficient by the agency or the Commission.

Upon review, the Commission finds that complainant had a reasonable

suspicion that she was being discriminated against in January 2003, when

she learned of her nonselection. Although it appears that complainant

may have contacted the EEO office on January 31, 2003, there is no

persuasive evidence that complainant intended to pursue the EEO process.

Complainant did not contact the EEO office again until November 28,

2003, almost 10 months later. A complainant commences the EEO process

by contacting an EEO Counselor and exhibiting an intent to pursue the

EEO complaint process. See Allen v. United States Postal Service, EEOC

Request No. 05950933 (July 9, 1996). The Commission is not persuaded

that complainant was told that she could not receive any help from

the EEO office in January 2003. The agency's decision dismissing the

complaint is AFFIRMED.

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

September 17, 2004

__________________

Date

1Although in her complaint, complainant

typed in as the bases of discrimination �dark black� for race/color and

�U.S. Virgin Islands� as her national origin, the Commission notes that

in a continuation to the complaint form, complainant also stated that

she was discriminated against because she is an African American born

in the United States.