Carl W. Reed, Complainant,v.Ray Lahood, Secretary, Department of Transportation (Federal Aviation Administration), Agency.

Equal Employment Opportunity CommissionJan 21, 2011
0120080520 (E.E.O.C. Jan. 21, 2011)

0120080520

01-21-2011

Carl W. Reed, Complainant, v. Ray Lahood, Secretary, Department of Transportation (Federal Aviation Administration), Agency.


Carl W. Reed,

Complainant,

v.

Ray Lahood,

Secretary,

Department of Transportation

(Federal Aviation Administration),

Agency.

Appeal No. 0120080520

Agency No. 5-98-5077

DECISION

On November 9, 2007, Complainant filed this appeal from the Agency's

October 12, 2007 final decision concerning remedies due as a result

of the Agency's unlawful employment discrimination in violation of

Title VII of the Civil Rights Act of 1964 (Title VII), as amended,

42 U.S.C. � 2000e et seq. The Commission accepts the appeal pursuant

to 29 C.F.R. � 1614.405(a). For the following reasons, the Commission

MODIFIES the Agency's final decision.

ISSUE PRESENTED

The issue presented is whether the Agency erred in determining the

remedies to which Complainant is entitled pursuant to a finding of

discrimination issued by the Commission.

BACKGROUND

On March 10, 1998, Complainant, an Operations Supervisor, FG-2152-15,

at the Houston Air Route Traffic Control Center, in Houston, Texas,

filed a formal complaint in which he alleged discrimination on the

basis of reprisal when, on November 1, 1997, his first-line supervisor

(Supervisor) threatened to examine Complainant's assets as a preliminary

step to filing a civil action against him for testifying before a

congressional subcommittee about sexual harassment at the Agency.

The complaint ultimately reached the Commission, which found that the

supervisor's actions constituted retaliatory discrimination and ordered

the agency to take remedial action in the form of, among other things,

conducting a supplemental investigation on the issue of compensatory

damages. Reed v. Department of Transportation, EEOC Appeal No. 01A05085

(May 20, 2003) (Reed I).1

On June 17, 2004, the Agency issued a final decision on compensatory

damages and awarded Complainant $15,000 in non-pecuniary compensatory

damages. Believing he was entitled to more than $15,000 in non-pecuniary

damages as well as a determination on past and future pecuniary losses,

leave restoration, and back pay, Complainant appealed the Agency's

decision to the Commission. Upon request, the Agency provided the

Commission with a copy of the Report of Investigation (ROI) but failed

to include the information Complainant submitted to support his damages

request. Despite repeated requests from the Commission to provide this

information, the Agency did not do so and offered no justification as

to why. Therefore, the Commission vacated the June 17, 2004 decision and

ordered the Agency to issue new findings on Complainant's entitlement to

compensatory damages, including past and future pecuniary losses, and also

leave restoration and back pay. Reed v. Department of Transportation,

EEOC Appeal No. 0120044821 (May 17, 2007) (Reed II).

The Agency's supplemental investigation on remedies revealed that

Complainant alleged he is entitled to an estimated 750 hours of restored

leave, pecuniary compensatory damages for past expenses and future costs

exceeding $113,000, and non-pecuniary compensatory damages in the amount

of $300,000 for the harm caused by the Agency's discrimination.

According to Complainant, he used approximately 150 hours of annual and

sick leave every year for five years as a direct result of the Agency's

discrimination. Complainant alleged that the record clearly establishes

that he would not have taken this time from work but for the impact

the discrimination had on his physical and emotional well-being and

his inability to get the Agency to prevent its managers and other high

level personnel from engaging in discriminatory behavior. Complainant's

Supplemental Response to Decision Regarding Compensatory Damages at 10.

Complainant also alleged the Agency's actions cost him $17,624 in rent

payments and $5,300 in utilities and food for his wife, who relocated

from their home in Houston to an apartment she shared with her brother in

San Antonio because the depression and behavioral changes he underwent

as a result of the Agency's discrimination made her life intolerable.

Complainant's Initial Submission of Damages at 2-5.

Complainant also alleged that from March 1998 to July 1, 2002, he spent

$18,571 in travel expenses for the 53 trips his wife took from San

Antonio to Houston to care for him and an additional $7,818 in weekly

travel expenses from July 26, 2002, to August 18, 2003, for 45 trips he

took to visit his wife after he purchased her a home in San Antonio.

For medical costs, Complainant contended that he is entitled to $500

in past pecuniary damages. See Complainant's Supplemental Response to

Decision Regarding Compensatory Damages at 10. He further contended

he is owed $8,246 in future pecuniary damages because, as a result of

the Agency's discriminatory actions, he has to remain on blood pressure

medication for the rest of his life. Id. at Complainant's Attachment.

Lastly, Complainant alleged he is entitled to an additional $55,781.25 in

loss or diminution of earning capacity. Complainant derived this figure

by taking the 150 hours of annual and sick leave he allegedly used every

year for five years following the discrimination and multiplied it by his

hourly salary of $74.38 to deduce $11,156.25 per year. Complainant noted

that this was the best information available because the Agency refused

to surrender his leave and attendance records.

Pursuant to the Commission's order in Reed II, the Agency issued its

new findings on October 12, 2007, in which it again found Complainant

was entitled to $15,000 in non-pecuniary compensatory damages and

nothing else. The Agency also found that Complainant failed to show he

suffered any pecuniary losses as a result of the Supervisor's retaliatory

statements. According to the Agency, Complainant was not entitled to

leave restoration because he failed to offer evidence concerning the

amount and dates of leave taken or a nexus showing how such leave was

related to the Supervisor's behavior. The Agency noted it was unclear

why Complainant believes he is entitled to back pay because presumably he

was compensated through the leave program for any time spent from work.

In a footnote, the Agency stated that Complainant was not entitled to

attorney's fees because his attorney withdrew his initial attorney's

fee request after determining it to be premature and did not file a

subsequent request. Complainant thereafter filed this appeal.

CONTENTIONS ON APPEAL

In Complainant's Brief in Support of Appeal, Complainant asserts that

he is entitled to non-pecuniary compensatory damages above the $15,000

granted by the Agency and an award on past and future pecuniary losses.

He notes the evidence submitted by his physician, and the affidavits

provided from family members and co-workers, which he contends proves how

the Agency's discrimination directly impacted his physical and mental

health, from which he incurred medical expenses, became detached from

his family, and disengaged at work. He also challenges the Agency's

footnote on attorney's fees as inaccurate. The Agency submitted no

arguments on appeal.

STANDARD OF REVIEW

In determining the appropriate type and amount of relief due Complainant

because of the discrimination he suffered at the hands of the Agency,

we review the propriety of the remedies awarded pursuant to the relief

ordered de novo (or "anew"). See 29 C.F.R. � 1614.405(a). This means that

in deciding this case, we must "examine the record without regard to the

factual and legal determinations" of the Agency, "review the documents,

statements, and testimony of record, including any timely and relevant

submissions of the parties," and then issue our decision "based on the

Commission's own assessment of the record and ... interpretation of the

law." Equal Employment Opportunity Management Directive for 29 C.F.R. Part

1614 (EEO MD-110), at 9-15 (Nov. 9, 1999). Accordingly, we have carefully

reviewed the entire record before us in our attempt to discern whether

a preponderance of the evidence warrants a modification of the Agency's

remedy award. See 29 C.F.R. � 1614.405(a). Complainant's contentions

on appeal are addressed in one or more of the sections below.

ANALYSIS AND FINDINGS

I. EQUITABLE RELIEF

When discrimination is found, the agency must provide complainant with

full, make-whole relief to restore him as nearly as possible to the

position he would have occupied absent the discrimination. See, e.g.,

Franks v. Bowman Transportation Co., 424 U.S. 747, 764 (1976); Albemarle

Paper Co. v. Moody, 422 U.S. 405, 418-19 (1975); Wan v. US Postal Serv,

EEOC Appeal No. 01995204 (July 11, 2001). The Commission recognizes that

not all harms done are amenable to precise quantification; the burden

of limiting the remedy, however, rests with the employer. Smallwood

v. United Airlines, Inc., 728 F.2d 614, 616 n.5 (4th Cir.), cert. denied,

469 U.S. 832 (1984).

A. Back Pay

In Reed II, the Commission ordered the Agency to determine the appropriate

amount of back pay with interest due Complainant for the discriminatory

actions that occurred on November 1, 1997. Complainant alleged that

he is entitled to back pay because of the amount of leave he used as

a result of the discrimination. The Agency stated that it is unclear

why Complainant believes he is entitled to back pay because any leave

used would have been reimbursed in the form of leave. It appears

Complainant has conflated the issue of back pay with his request for

leave restoration, which we address below. There is no evidence that

an allowance for back wages would be an appropriate remedy in this case,

and therefore Complainant's request for back pay is denied.

B. Leave Restoration

The Commission previously ordered the Agency to determine the appropriate

amount of leave restoration to which Complainant was entitled as a result

of the discriminatory actions. Complainant alleged entitlement to an

estimated 750 hours of restored leave, which he referred to as lost wages,

presumably because he is now retired from the Agency. According to the

Agency, Complainant is not entitled to restored leave because he failed to

provide documentation showing the amount of leave used and how that leave

was related to the discriminatory act. Complainant stated that the Agency

refused upon request to provide his leave usage history. Complainant's

Supplemental Response to Decision Regarding Compensatory Damages at 11.

Complainant is entitled to restoration of leave which was taken for

purposes of avoiding or recovering from discriminatory conduct. In order

to be entitled to leave restoration, the employee must demonstrate a

causal nexus between the discrimination and need to take leave. Velez

v. U.S. Postal Serv., EEOC Appeal No. 01902746 (Nov. 16, 1990).

Several of Complainant's co-workers presented testimony indicating

that Complainant took an unusual amount of leave following the Agency's

actions. One co-worker stated, "It appeared [Complainant] took a lot

of leave and began volunteering to work mid-shifts to avoid being at

the facility when management was there." Another stated, "He has taken

quite a bit of leave and having known how conscientious he was prior

to these threats from management, it is obvious that [Complainant] is

avoiding coming to work due to the environment." Another one stated,

"[Complainant] has used a large amount of leave, both sick and annual.

I know [Complainant] well enough to say that his use of leave is

directly related to how he is treated at work." And another co-worker

stated, "[Complainant] has taken a lot of leave since these events."

One of his daughters stated that in the time after January 1998, she

noticed that her father's absences from work became "more often and more

excessive." Based on this evidence, we find that Complainant has shown

a causal nexus between the discriminatory act and the need to take leave

after November 1, 1997.

The remaining outstanding issue regarding this matter is the amount of

annual and sick leave taken by Complainant as a result of the Agency's

actions. At this time, we are unable to determine the amount of leave

owed to Complainant in accordance with our previous order. While the

Agency contends Complainant is not due any restoration of leave because

he failed to provide evidence showing the amount of leave taken, we

find that it is more likely than not that the Agency had access to

Complainant's leave records and yet chose not to supplement the record

with evidence showing the amount of leave Complainant used after he

was discriminated against. Therefore, we shall order the Agency to

determine Complainant's annual and sick leave usage from November 1,

1997, until the date of his retirement from the Agency, and reimburse

him for the entire amount.

II. COMPENSATORY DAMAGES

Compensatory damages do not include back pay, interest on back pay, or

any other type of equitable relief authorized by Title VII. To receive an

award of compensatory damages, a complainant must demonstrate that he has

been harmed as a result of the agency's discriminatory action; the extent,

nature and severity of the harm; and the duration or expected duration

of the harm. See Rivera v. Dep't of the Navy, EEOC Appeal No. 01934157

(July 22, 1994), request for recon. den., EEOC Request No. 05940927

(Dec 11, 1995); EEOC's Enforcement Guidance: Compensatory and Punitive

Damages Available Under Section 102 of the Civil Rights Act of 1991,

EEOC Notice No. 915.002 at 11-12, 14 (July 14, 1992). A complainant

is required to provide objective evidence that will allow an agency to

assess the merits of his request for damages. See Carle v. Dep't of the

Navy, EEOC Appeal No. 01922369 (Jan. 5, 1993).

A. Out-of-Pocket Losses/Expenses

Pecuniary losses are out-of-pocket expenses that are incurred as a

result of the employer's unlawful action. Typically, these damages

include reimbursement for medical expenses, job-hunting expenses, moving

expenses, and other quantifiable out-of-pocket expenses. EEOC Enforcement

Guidance: Compensatory and Punitive Damages, at 14. Past pecuniary losses

are losses incurred prior to the resolution of a complaint through a

finding of discrimination, the issuance of a full-relief offer, or a

voluntary settlement. Id. at 8-9. Future pecuniary losses are losses

that are likely to occur after resolution of a complaint. Id. at 9. For

claims seeking pecuniary damages, such objective evidence should include

documentation of out-of-pocket expenses for all actual costs and an

explanation of the expense, e.g., medical and psychological billings,

other costs associated with the injury caused by the agency's actions,

and an explanation for the expenditure. Id. at 9.

1. Past Pecuniary Losses

Complainant requests for past pecuniary damages include rent and travel

expenses he incurred as a result of his wife's move from Houston to

San Antonio, and past medical expenses for doctor's visits he alleged

were made necessary as a result of the Agency's discriminatory action.

However, he failed to provide specific evidence in the form of medical

receipts, bills, or other objective documentation tending to support

any of these claims, and therefore has not provided sufficient evidence

showing he is entitled to an award for past pecuniary damages.

2. Future Pecuniary Expenses

Complainant also claimed future pecuniary damages for blood-pressure

medication he will likely have to take for the rest of his life.

Complainant alleged that in April 1998, he underwent an Agency mandated

annual physical, the results of which showed his blood pressure to

be elevated. In a letter dated August 2003, Complainant's physician

(Physician) stated that Complainant had a significant history for

high blood pressure and likely must remain on blood medication for

the rest of his life. The Physician also stated that Complainant had

reported encountering undue stress at work since 1997. Complainant also

provided other medical documents, none of which indicate he was originally

diagnosed with high blood pressure in April 1998. Thus, he has failed to

establish a link between his medical condition and the Agency's action.

We therefore find he has not shown that he is entitled to future pecuniary

damages for anticipated medical costs.

Complainant also claimed future pecuniary damages for loss of or

diminution in earning capacity. Where an employee has shown that his

future earning power has been diminished as a result of the agency's

discrimination, the Commission has awarded future pecuniary damages for

the loss of future earning capacity. Brinkley v. U.S. Postal Serv., EEOC

Request No. 05980429 (August 12, 1999); Hernandez v. U.S. Postal Serv.,

EEOC Appeal No. 07A30005 (July 16, 2004). Proof of entitlement to loss of

future earning capacity involves evidence suggesting that the individual's

injuries have narrowed the range of economic opportunities available

to him. Carpenter v. Dep't of Agriculture, EEOC Appeal No. 01945652

(July 17, 1995). Generally, the party seeking compensation for loss

of earning capacity needs to provide evidence which demonstrates with

reasonable certainty or reasonable probability that the loss has been

sustained. Id. (citing Annotation, Evidence of Impaired Earnings Capacity,

18 A.L.R. 3d 88, 92 (1968)).

Complainant has alleged he is entitled to an award for loss of earning

capacity because the estimated amount of annual and sick leave he

used in each of the five years following the Agency's discrimination

affected his earnings and retirement. This contention appears related

to Complainant's argument for leave restoration but is insufficient to

show that his earning power was somehow impacted by the Agency's action.

Because the record is devoid of evidence which shows the Agency's action

narrowed the range of economic opportunities available to Complainant,

we deny this claim.

B. Non-Pecuniary Compensatory Damages

Non-pecuniary losses are losses that are not subject to precise

quantification, i.e., emotional pain, suffering, inconvenience, mental

anguish, loss of enjoyment of life, injury to professional standing,

injury to character and reputation, injury to credit standing, and

loss of health. See EEOC Notice No. 915.002 at 10 (July 14, 1992).

There is no precise formula for determining the amount of damages for

non-pecuniary losses except that the award should reflect the nature and

severity of the harm and the duration or expected duration of the harm.

See Loving v. Dep't of the Treasury, EEOC Appeal No. 01955789 (Aug. 29,

1997). We note that non-pecuniary compensatory damages are designed to

remedy the harm caused by the discriminatory event rather than punish

the Agency for the discriminatory action. Furthermore, compensatory

damages should not be motivated by passion or prejudice or "monstrously

excessive" standing alone but should be consistent with the amounts

awarded in similar cases. See Ward-Jenkins v. Dep't of the Interior,

EEOC Appeal No. 01961483 (Mar. 4, 1999).

Evidence from a health care provider or other expert is not a mandatory

prerequisite for recovery of compensatory damages for emotional harm. See

Lawrence v. U.S. Postal Serv., EEOC Appeal No. 01952288 (Apr 18, 1996)

(citing Carle v. Dep't of the Navy, EEOC Appeal No. 01922369 (Jan. 5,

1993)). Objective evidence of compensatory damages can include

statements from the Complainant concerning his emotional pain or

suffering, inconvenience, mental anguish, loss of enjoyment of life,

injury to professional standing, injury to character or reputation,

injury to credit standing, loss of health, and any other non-pecuniary

losses that are incurred as a result of the discriminatory conduct. Id.

Statements from others, including family members, friends, health

care providers, other counselors (including clergy) could address the

outward manifestations or physical consequences of emotional distress,

including sleeplessness, anxiety, stress, depression, marital strain,

humiliation, emotional distress, loss of self-esteem, excessive fatigue,

or a nervous breakdown. Id. Complainant's own testimony, along with the

circumstances of a particular case, can suffice to sustain his burden

in this regard. Id. The more inherently degrading or humiliating the

defendant's action is, the more reasonable it is to infer that a person

would suffer humiliation or distress from that action. Id. The absence of

supporting evidence, however, may affect the amount of damages appropriate

in specific cases. Id.

In the instant case, Complainant asserted that he has suffered emotional

and physical suffering since the Agency's discrimination. He asserted

that he has become detached from his family and disengaged at work.

Complainant provided affidavits from several family members and co-workers

to support his assertions.

Complainant's wife stated that in the aftermath of the Agency's

discrimination she has had a difficult time coping with his problems.

She stated that she has had to seek medical help because of the demand

of having to take care of the household and their daughters alone.

She stated that Complainant spent many hours on the telephone talking

to his co-workers about how was treated at work, which took a toll on

the family. Complainant's Wife Affidavit, at 1. Complainant's wife

stated that the tension created by Complainant's work situation made it

unbearable to live together as a family and caused her to move out from

their home in 1998 even though she still cared for and loved her husband.

Id. at 2.

Complainant's oldest daughter (Daughter 1) stated over the five years

following the Agency's discriminatory action, Complainant remained

in a constant state of tension, and that his body language and

lack of interaction with the family created a very tense atmosphere.

Daughter 1 Aff. at 1. She stated that her father, formerly outgoing and

family-oriented, was now isolated at home, which caused her mother to

move out of their bedroom and eventually out of their home. She stated

that her father missed her wedding because he did not have the emotional

state to deal with family events. Id. at 2.

Complainant's youngest daughter (Daughter 2) stated that Complainant's

job was a major part of his life before the discriminatory event but he

always found a way to spend time with his family. Daughter 2 Aff. at 1.

She stated that after her father was discriminated against, the look in

her father's eyes and his lack of enthusiasm for life deeply saddened her.

Id. at 3. She stated that her efforts to communicate with him in the

aftermath of what he experienced at the Agency were met with mean and

hurtful statements. Id. at 4. She stated that her father also missed

her wedding because of his mental state.

Complainant's brother, sister, and brother-in-law submitted affidavits

as well. All of these affidavits in one form or another indicated

that after Complainant was discriminated against, he became further

and further removed from the family, and that his attendance at family

events diminished. They also indicated that when they saw Complainant in

person, he was less talkative and withdrawn. Complainant's brother-in-law

referred to Complainant as "reclusive." His sister referred to his

condition as "a mood swing." His brother stated that Complainant "would

not return any phone calls."

Complainant provided affidavits from twelve former co-workers, several of

whom he supervised. One of his former employees stated that Complainant

was an effective supervisor but after he was discriminated against,

he loss his effectiveness. This employee stated that he and several of

his colleagues changed specialties because they could no longer work for

Complainant. Another employee confirmed that she and her colleagues knew

that whatever Complainant requested of them was reasonable and logical

because they watched how he worked but after he was discriminated against

he became very guarded in his actions and conversations.

Complainant's fellow supervisors stated that after Complainant was

discriminated against they often discussed Complainant's change in

personality among themselves. They indicated that he became preoccupied

and withdrawn and that the relationship he had with his co-workers changed

drastically. One colleague stated that Complainant became less engaged

in the operations of the organization, and described his behavior as

"constantly looking over his shoulder" and "approaching paranoia."

Another colleague stated Complainant was shunned at work and became

an outcast. Still another one stated that before the Agency's action,

Complainant was an attentive and resourceful colleague but afterwards

he became more distant, reserved and isolated.

Taking into account the evidence of non-pecuniary damages submitted by

Complainant, we find the Agency's award of non-pecuniary, compensatory

damages in the amount of $15,000 to be inadequate. As a result of the

Agency's action, Complainant experienced emotional mood swings, mental

anguish, and damage to his professional standing and reputation, which

included several of his staff members requesting a change in supervisors.

He also experienced marital and familial strain, a general loss of

self-esteem, and stopped enjoying life.

Based on the record, the Commission finds that Complainant is entitled

to an award of $50,000. This amount takes into account the nature

of the discriminatory actions and the severity of the harm suffered,

and is consistent with prior Commission precedent. Lindsay v. Dep't

of Veterans Affairs, EEOC Appeal No. 0720070016 (July 26, 2007),

request for recon. den., EEOC Request No. 0520070874 (Sept. 26, 2007)

($50,000 awarded where Complainant experienced stress and weight loss,

became withdrawn, lost energy, and interacted less with friends);

Claflin v. Dep't of Defense, EEOC Appeal No. 07A50069 (May 26, 2006)

($53,000 awarded where Complainant suffered emotional distress, believed

her reputation was ruined, became afraid to go outside, and became

cold and less affectionate toward her spouse); Scheels v. U.S. Postal

Serv., EEOC Appeal No. 07A50005 (July 28, 2005) ($50,000 awarded where

Complainant experienced emotional distress and marital problems, and

was described by her co-workers as unhappy, upset, and frustrated).

An award of $50,000 meets the goals of not being motivated by passion or

prejudice, not being "monstrously excessive" standing alone, and being

consistent with the amounts awarded in similar cases. See Cygnar, supra.

III. ATTORNEY'S FEES

A. Entitlement

On June 17, 2003, the Agency requested that Complainant provide

documentation showing his entitlement to remedies, including attorney's

fees. On July 11, 2003, Complainant's attorney submitted a petition for

attorney's fees requesting $13,212 in legal fees and costs. After being

notified that the petition included fees and costs related to an EEO

complaint where Complainant was not the prevailing party, Complainant's

attorney withdrew the request as premature.

On September 29, 2004, Complainant's attorney submitted an amended

petition requesting $9,136 in legal fees and associated costs.

The attorney noted that his request was no longer premature as the

Agency had just released its decision in Complainant's compensatory

damages claim on June 17, 2004. The Agency's February 9, 2005, response

informed Complainant's attorney that the June 17, 2004, decision concluded

that because he withdrew his initial request for attorney's fees and

no subsequent request had been submitted, Complainant would not be

awarded attorney's fees. The Agency noted that the decision notified

Complainant of his appeal rights, and since no appeal had been timely

filed the matter was now closed.

On May 17, 2007, the Commission vacated the Agency's June 17, 2004,

decision and ordered the Agency to issue new findings. Those findings,

issued on October 12, 2007, included a footnote stating that Complainant

had withdrawn his request for attorney's fees and that "[t]he file d[id]

not contain any subsequent submissions by the Complainant's attorney

regarding attorney's fees; therefore, no attorney's fees w[ould] be

awarded." On appeal, Complainant challenged the Agency's footnote on

attorney's fees as inaccurate.

The Agency's reliance on its June 17, 2004, decision as the reason to

deny Complainant's attorney's fee request was in error because that

decision was vacated in Reed II. And the notion that it could not award

attorney's fees in its October 12, 2007, decision because the file did not

contain a subsequent request for attorney's fees is a misrepresentation

of the facts; the file clearly contained Complainant's September 29,

2004 request for attorney's fees when the Agency rendered its decision on

October 12, 2007. In the instant appeal, Complainant timely challenged

all aspects of the Agency's October 12, 2007, decision, and that includes

the finding on attorney's fees. Thus Complainant's request for attorney's

fees is not a closed matter but an issue ripe for appellate review.

B. Attorney's Fees Calculation

Title VII and the Commission's regulations authorize the award of

reasonable attorney's fees and costs to a prevailing Complainant. 29

C.F.R. � 1614.501(e); see also Equal Employment Opportunity Management

Directive for 29 C.F.R. Part 1614 (EEO MD-110), at 11-1 (Nov. 9,

1999). Fee awards are typically calculated by multiplying the number of

hours reasonably expended times a reasonable hourly rate, an amount also

known as a lodestar. See 29 C.F.R. � 1614.50l(e)(ii)(B); Blum v. Stenson,

465 U.S. 886, 899 (1984); Hensley v. Eckerhart, 461 U.S. 424, 435 (1983).

All hours reasonably spent in processing the complaint are compensable,

but the number of hours should not include excessive, redundant or

otherwise unnecessary hours. Id. at 11-15. A reasonable hourly rate is

based on prevailing market rates in the relevant community for attorneys

of similar experience in similar cases. Id. at 11-6. An application for

attorney's fees must include a verified statement of attorney's fees

accompanied by an affidavit executed by the attorney of record itemizing

the attorney's charges for legal services. Id. at 11-9.

While the attorney is not required to record in great detail the manner

in which each minute of his time was expended, the attorney does have

the burden of identifying the subject matters on which he spent his time

by submitting sufficiently detailed and contemporaneous time records to

ensure that the time spent was accurately recorded. See Spencer v. Dep't

of the Treasury, EEOC Appeal No. 07A10035 (May 6, 2003). The attorney

requesting the fee award has the burden of proving, by specific evidence,

entitlement to the requested fees and costs. Koren v. U.S. Postal Serv.,

EEOC Request No. 05A20843 (Feb. 18, 2003).

Complainant claimed $8,844 in legal fees and $295 in associated costs

in the attorney's fees petition submitted on September 24, 2004 for

services rendered from October 23, 1997, to June 1, 2004. According to

the petition, Complainant's attorney spent approximately 42 1/2 hours

on Complainant's complaint at a cost of $200 per hour. We note that

the petition for attorney's fees claimed $198 in legal fees and $10 in

costs related to expenses incurred before November 1 1997, the date on

which Complainant was discriminated; the Agency is not obligated to pay

for those charges. Thus, we start with the premise that Complainant

is entitled to no more than $8,646 in legal fees and $285 in associated

costs.

Attorney's fees may not be recovered for work on unsuccessful

claims. Hensley, at 434. Courts have held that fee applicants

should exclude time expended on "truly fractionable" claims or

issues on which they did not prevail. See National Association of

Concerned Veterans v. Secretary of Defense, 675 F.2d 1319, 1327 n.13

(D.C. Cir. 1982). Claims are fractionable or unrelated when they involve

distinctly different claims for relief that are based on different facts

and legal theories. Hensley, 461 U.S. at 435. However, in cases where

a claim for relief involves "a common core of facts or will be based

on related legal theories" a fee award should not be reduced simply

because the plaintiff failed to prevail on every contention raised

in the lawsuit. Id. "The hours spent on unsuccessful claims should be

excluded in considering the amount of a reasonable fee only where the

unsuccessful claims are distinct in all respects from the successful

claims." See EEO MD-110, at 11-16 (citation omitted).

Complainant's initial complaint was a claim of retaliatory harassment

containing four incidents, all of which related to his testimony before

Congress. The Commission found that three of those four incidents

were legitimate, nondiscriminatory employment actions, and one, the

statement in which the Supervisor threatened to sue Complainant,

constituted retaliation. Even though Complainant did not prevail

on every contention he raised, we find that his complaint was based

on a common core of facts with the same legal theory. Therefore, we

decline to order a reduction in attorney's fees. We also find that the

number of hours expended and the attorney's rate of $200 per hour to be

reasonable considering the complexity of the case, and the experience

level of Complainant's attorney and the market in which he practiced.

We therefore grant Complainant $8,646 in attorney's fees and $285 in

costs.

CONCLUSION

Based on a thorough review of the record and the contentions on appeal,

including those not specifically addressed herein, we hereby MODIFY the

Agency's final decision and REMAND this case to the Agency for action

consistent with this decision and the Order below.

ORDER

The Agency shall take the following remedial actions within sixty (60)

calendar days from the date this decision becomes final:

1. Determine how much annual leave Complainant used from November 1,

1997, to the date of his retirement in connection with the Agency's

discriminatory actions, and pay him for the entire amount;

2. If Complainant retired under the Civil Service Retirement System

(CSRS), the Agency shall determine the amount of sick leave Complainant

used from November 1, 1997, to the date of his retirement in connection

with the Agency's discriminatory actions, and shall effect whatever

adjustments are necessary to credit Complainant's service time for such

sick leave;

3. Pay Complainant $50,000 in non-pecuniary damages;

4. Pay Complainant $8,646 in attorney's fees and $285 in costs; and

5. Submit a report of compliance, as provided in the statement entitled

"Implementation of the Commission's Decision." The report shall include

all supporting documentation of the Agency's calculation of Complainant's

reimbursement of annual and sick leave.

ATTORNEY'S FEES (H0610)

If Complainant has been represented by an attorney (as defined by 29

C.F.R. � 1614.501(e)(1)(iii)), she is entitled to an award of reasonable

attorney's fees incurred in the processing of the complaint. 29 C.F.R. �

1614.501(e). The award of attorney's fees shall be paid by the Agency. The

attorney shall submit a verified statement of fees to the Agency --

not to the Equal Employment Opportunity Commission, Office of Federal

Operations - within thirty (30) calendar days of this decision becoming

final. The Agency shall then process the claim for attorney's fees in

accordance with 29 C.F.R. � 1614.501.

IMPLEMENTATION OF THE COMMISSION'S DECISION (K0610)

Compliance with the Commission's corrective action is mandatory. The

Agency shall submit its compliance report within thirty (30) calendar

days of the completion of all ordered corrective action. The report shall

be submitted to the Compliance Officer, Office of Federal Operations,

Equal Employment Opportunity Commission, P.O. Box 77960, Washington,

DC 20013. The Agency's report must contain supporting documentation,

and the Agency must send a copy of all submissions to the Complainant. If

the Agency does not comply with the Commission's order, the Complainant

may petition the Commission for enforcement of the order. 29 C.F.R. �

1614.503(a). The Complainant also has the right to file a civil action

to enforce compliance with the Commission's order prior to or following

an administrative petition for enforcement. See 29 C.F.R. �� 1614.407,

1614.408, and 29 C.F.R. � 1614.503(g). Alternatively, the Complainant has

the right to file a civil action on the underlying complaint in accordance

with the paragraph below entitled "Right to File a Civil Action." 29

C.F.R. �� 1614.407 and 1614.408. A civil action for enforcement or a civil

action on the underlying complaint is subject to the deadline stated

in 42 U.S.C. 2000e-16(c) (1994 & Supp. IV 1999). If the Complainant

files a civil action, the administrative processing of the complaint,

including any petition for enforcement, will be terminated. See 29

C.F.R. � 1614.409.

STATEMENT OF RIGHTS - ON APPEAL

RECONSIDERATION (M0610)

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), at 9-18 (Nov. 9, 1999). All requests

and arguments must be submitted to the Director, Office of Federal

Operations, Equal Employment Opportunity Commission, P.O. Box 77960,

Washington, DC 20013. 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 (R0610)

This is a decision requiring the Agency to continue its administrative

processing of your complaint. However, if you wish to file a civil action,

you have the right to file such action in an appropriate United States

District Court within ninety (90) calendar days from the date that

you receive this decision. In the alternative, you may file a civil

action after one hundred and eighty (180) calendar days of the date

you filed your complaint with the Agency, or filed your appeal with the

Commission. 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. Filing a civil

action will terminate the administrative processing of your complaint.

RIGHT TO REQUEST COUNSEL (Z0610)

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 from the Court that

the Court appoint an attorney to represent you and that the Court also

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 with

the Court 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

January 21, 2011

Date

1 Complainant also alleged discrimination regarding three other actions

but the Commission found that he failed to prove those acts were

retaliatory in nature. Id.

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0120080366

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Office of Federal Operations

P.O. Box 77960

Washington, DC 20013

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0120080520