Alice Kay Zang, Complainant,v.Norman Y. Mineta, Secretary, Department of Transportation, Agency.

Equal Employment Opportunity CommissionDec 2, 2005
01a51837 (E.E.O.C. Dec. 2, 2005)

01a51837

12-02-2005

Alice Kay Zang, Complainant, v. Norman Y. Mineta, Secretary, Department of Transportation, Agency.


Alice Kay Zang v. Department of Transportation

01A51837

December 2, 2005

.

Alice Kay Zang,

Complainant,

v.

Norman Y. Mineta,

Secretary,

Department of Transportation,

Agency.

Appeal No. 01A51837

Agency No. 3-04-3056

DECISION

Complainant initiated contact with an EEO Counselor on April 20, 2004.

On June 9, 2004, complainant filed a formal EEO complaint in which she

claimed that the agency discriminated against her on the basis of her age

(dob 7/21/51) when:

1. Subsequent to the approval of her hardship transfer application on

December 9, 2002, the hardship transfer application was sent to only

one of the facilities that complainant requested.

2. After complainant's hardship transfer application was approved on

December 9, 2002, management overstaffed the Sarasota facility with

young people making it impossible for complainant to obtain a position.

The record reveals that complainant has been employed by the agency as

an Air Traffic Control Specialist, GS-2152-14, at the agency's Air Route

Traffic Control Center in Miami, Florida. On June 10, 2002, complainant

applied for a hardship transfer to the agency's facilities in Fort Myers,

Tampa, or Sarasota. The agency approved complainant's request for a

hardship transfer on December 9, 2002. The agency memorandum notifying

complainant that her request had been approved stated that her transfer

request was being forwarded to the Air Traffic Manager at the Sarasota

facility for consideration. The memorandum made no reference to either

the facility in Fort Myers or the facility in Tampa. The record reveals

that in e-mail correspondence dated December 2, 2002, to the agency,

the Union's Southern Region Vice President only supported sending

complainant's application to the Sarasota facility as he expressly

rejected both the Tampa and Fort Myers facilities. On June 3, 2004,

complainant requested and ultimately received an eighteen-month hardship

extension. Complaint stated that in addition to the aforementioned

agency facilities, she also wished to be considered for a position at

the Orlando facility.

The complaint was accepted for investigation. Subsequent to the

completion of the agency investigation, the agency notified complainant

of her right to request either a hearing and decision by an EEOC

Administrative Judge or an immediate final action by the agency.

Complainant requested a final action. The agency thereafter

issued a final action wherein it dismissed claim (1) pursuant to

29 C.F.R.�1614.107(a)(2) on the grounds that complainant failed to

initiate contact with an EEO Counselor in a timely manner. The agency

determined that complainant was aware on December 9, 2002, of management's

decision to forward her hardship transfer application only to the Sarasota

facility. The agency determined that complainant did not initiate contact

with an EEO Counselor until April 20, 2004, after the expiration of the

45-day limitation period for contacting an EEO Counselor. With regard

to claim (2), the agency determined that complainant failed to set forth

a prima facie case of age discrimination because complainant provided

no evidence that a younger employee was placed at the Sarasota facility

under a hardship transfer during the relevant time period. The agency

noted that even if complainant had established a prima facie case,

it articulated a legitimate, nondiscriminatory reason for its action.

According to the agency, the Sarasota facility was overstaffed and no

employees had been assigned there since June 2002. The agency determined

that complainant failed to show by a preponderance of the evidence that

but for her age, she would have received a hardship transfer to the

Sarasota facility.

On appeal, complainant contends that it was not until during the

investigation of the instant complaint, on or about August 20, 2004, that

she realized that her hardship transfer request had not been referred

to the Fort Myers, Tampa and Orlando facilities. Complainant states

that the agency's memorandum dated December 9, 2002, did not inform her

that her transfer request was not being sent to the Tampa and Fort Myers

facilities. According to complainant, she assumed that the Sarasota

facility was the only facility mentioned in the memorandum because she

indicated that Sarasota was her first choice.

The agency dismissed the first claim of the complaint on the grounds

that complainant failed to initiate contact with an EEO Counselor in a

timely manner. The agency determined that complainant's EEO contact on

April 20, 2004, was after the expiration of the 45-day time limit for

contacting an EEO Counselor. The Commission agrees with the agency.

Complainant's contact of an EEO Counselor on April 20, 2004, was more

than 45 days after she was informed by the agency memorandum dated

December 9, 2002, that her hardship transfer application was being

transferred for consideration to the Sarasota facility. In light of the

fact that this memorandum did not mention that the hardship transfer

application was being sent to the Tampa and Fort Myers facilities, we

find that complainant should have realized that the Tampa and Fort Myers

facilities would not receive her application. Therefore, Complainant

should have contacted an EEO Counselor within 45 days of her receipt of

this memorandum. We find that complainant has not submitted sufficient

argument or evidence to justify an extension of the 45-day limitation

period. Accordingly, the agency's decision dismissing the first claim of

complainant's complaint was proper pursuant to 29 C.F.R. � 1614.107(a)(2).

In the absence of direct evidence of discrimination, the allocation

of burdens and order of presentation of proof in a case claiming

discrimination is a three-step process as set forth in McDonnell Douglas

Corporation v. Green, 411 U.S. 792, 802-803 (1973), and its progeny.

See also Loeb v. Textron, 600 F.2d 1003 (1st Cir. 1979) (requiring a

showing that age was a determinative factor, in the sense that �but

for� age, complainant would not have been subject to the adverse action

at issue). For complainant to prevail, she 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 consideration was a factor in the adverse employment action.

McDonnell Douglas, 411 U.S. at 802; Furnco Construction Corp. v. Waters,

438 U.S. 567 (1978). The burden then shifts to the agency to articulate

a legitimate, nondiscriminatory reason for its actions. Texas Department

of Community Affairs v. Burdine, 450 U.S. 248, 253 (1981). To ultimately

prevail, complainant must prove, by a preponderance of the evidence, that

the agency's explanation is pretextual. Reeves v. Sanderson Plumbing

Products, Inc., 530 U.S. 133 (2000).

This order of analysis in discrimination cases, in which the first step

normally consists of determining the existence of a prima facie case,

need not be followed in all cases. Where the agency has articulated a

legitimate, nondiscriminatory reason for the personnel action at issue,

the factual inquiry can proceed directly to the third step of the

McDonnell Douglas analysis, the ultimate issue of whether complainant

has shown by a preponderance of the evidence that the agency's actions

were motivated by discrimination. United States Postal Service Board of

Governors v. Aikens, 460 U.S. 711, 713-714 (1983); Hernandez v. Department

of Transportation, EEOC Request No. 05900150 (June 28, 1990).

For purposes of analysis, we will assume, arguendo, that complainant has

established a prima facie case of discrimination on the basis of age. The

agency stated that complainant has not received a transfer to the Sarasota

facility because the facility is overstaffed. Further, the agency stated

that there have been no placements at the Sarasota facility since June

2002. We find that the agency articulated a legitimate, nondiscriminatory

reason for not transferring complainant to the Sarasota facility.

We find that complainant failed to refute the agency's stated reason for

not transferring her to the Sarasota facility. Complainant alleged that

the agency overstaffed the Sarasota facility with younger individuals

in order to prevent her from obtaining a position. Complaint claimed

that two individuals were assigned to the Sarasota facility shortly

before her transfer was approved. However, the record does not refute

the agency's position that there had been no placements at the Sarasota

facility since June 2002, approximately six months before complainant's

hardship transfer request was approved. We find that complainant has

not shown, by a preponderance of the evidence, that the agency's stated

reason for not transferring her to the Sarasota facility was pretext

intended to mask discriminatory intent. Therefore, we find that the

agency properly issued a decision finding no discrimination for claim (2).

The agency's final action 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

December 2, 2005

__________________

Date