Constantine Economou, Appellant,v.Louis Caldera, Secretary, Department of the Army, Agency.

Equal Employment Opportunity CommissionAug 5, 1999
01983435 (E.E.O.C. Aug. 5, 1999)

01983435

08-05-1999

Constantine Economou, Appellant, v. Louis Caldera, Secretary, Department of the Army, Agency.


Constantine Economou, )

Appellant, )

)

v. ) Appeal No. 01983435

) Agency Nos. AUFS9506F0120,

Louis Caldera, ) AUFS9506F0130,

Secretary, ) AUFS9506F0140

Department of the Army, ) Hearing Nos. 160-96-8300X,

Agency. ) 160-96-8301X,

______________________________) 160-96-8302X

DECISION

On March 30, 1998, Constantine Economou (appellant), by and through

his attorney, timely appealed the final decision of the Department of

the Army (agency), dated February 25, 1998, concluding he had not been

discriminated against in violation of the Civil Rights Act of 1964, as

amended, 42 U.S.C. �2000e et seq., and the Rehabilitation Act of 1973,

as amended, 29 U.S.C. �791 et seq. This appeal is accepted in accordance

with the provisions of EEOC Order No. 960.001.

The record establishes that on August 16, 1993, January 4, 1994, and

September 24, 1994, respectively, appellant filed a series of three

equal employment opportunity (EEO) complaints against the agency.

After many procedural disputes between the parties, including an

appeal to this Commission from the dismissal of some of the issues

raised in appellant's complaints, the agency accepted the complaints

for investigation. At the conclusion of the investigation, appellant

requested an administrative hearing before an Equal Employment Opportunity

Commission (EEOC) administrative judge (AJ). The three complaints were

consolidated for hearing.

During the initial phase of the hearing, the AJ, with the agreement of

the parties, consolidated and redefined the multiple issues raised in the

three complaints. According to the AJ, the issues to be addressed at the

hearing were whether the agency's New York District Commander unlawfully

retaliated against appellant for his prior EEO activity and, with respect

to appellant's second and third complaints, also discriminated against

him on the bases of his national origin (Greek) and/or disabilities, when:

(1) in April and May 1993, the District Commander used secret committees

to reorganize appellant's division without his knowledge, input or

concurrence, which resulted in sections of the Construction Division

being removed and reestablished in other divisions;

(2) the District Commander allowed appellant's leave records to be left

in plain view of visitors in the District's legal office;

(3) appellant received a lower rating ("fully successful") on his

June 30, 1993 performance evaluation than he believed his performance

warranted, and the District Commander refused to discuss it with

appellant or consider upgrading it;

(4) the District Commander interfered with appellant's supervisory

authority by lowering the performance rating of one of appellant's

employees without his knowledge or consent;

(5) the District Commander interfered with the timely payment of

appellant's workers' compensation claim for injuries sustained at work

on May 25, 1993;

(6) the District Commander rated appellant on the supervision of four

area offices which were not under his supervision at the time;

(7) the District Commander blamed appellant for unsubstantiated

deficiencies in conducting various briefings, and mischaracterized

appellant as uncommunicative, uncooperative and overly sensitive to

criticism;

(8) in May 1994, after his return to work following a prolonged absence

due to a work-related injury, the District Commander allegedly threatened

and disparaged appellant, confined him in a separate office in the

executive suite, directed him to undergo a series of psychiatric

examinations, and embarrassed him by providing false information

about him;

(9) on June 9, 1994, the District Commander shouted in appellant's face,

triggering another period of sick leave and a workers' compensation

claim;

(10) the District Commander refused to allow appellant to resume his

duties as chief of the Transportation Division when he returned to

work; and

(11) the District Commander ignored appellant's requests to restore

his annual leave which had been forfeited because appellant had to use

sick leave.

On December 22, 1997, following a hearing at which nine witnesses

testified, the AJ issued a decision concluding appellant had failed to

establish unlawful national origin or disability discrimination with

respect to any of his allegations. The AJ also found that appellant

had failed to establish unlawful retaliation with regard to allegations

nos. 1, 2, 4 and 5. On appeal appellant does not challenge these

conclusions, and they shall, therefore, be affirmed by the Commission

without further discussion. However, the AJ went on to conclude that

the weight of the evidence established that appellant was the victim

of unlawful retaliation for his prior EEO activity with respect to

allegations nos. 3 and 6-11. To remedy appellant for its retaliatory

conduct, the AJ recommended: (1) that appellant's 1993 performance

appraisal rating be raised to an "exceptional" and he receive the

appropriate monetary award for that rating, as well as the retroactive

step increase, with backpay, which he would have allegedly received for an

"exceptional" rating; (2) that appellant be reimbursed for 292 hours of

leave without pay (LWOP) and have the sick leave restored which he was

forced to take as a result of the agency's unlawful actions;<1> (3) that

appellant be reimbursed for any unpaid medical expenses (approximately

$2,000) which he incurred as a result of the agency's unlawful actions;

and that appellant be awarded the amount of $300,000 in compensatory

damages for the "emotional distress and humiliation" he suffered as a

result of the agency's retaliatory actions.

On February 25, 1998, the agency issued its final decision accepting

the AJ's conclusion that no discrimination or retaliation occurred with

regard to issues nos. 1, 2, 4 and 5, but rejecting the AJ's finding of

unlawful retaliation with respect to appellant's remaining allegations.

It is from this decision that appellant now appeals.

The record establishes that, at the time the matters at issue arose,

appellant was employed by the agency as Chief of the Construction

Division, GM-15, New York District, U.S. Army Corps of Engineers.<2>

An employee of the agency since 1972, he assumed the Chief position on

November 1, 1992, as a direct result of the successful prosecution of an

earlier EEO complaint.<3> In June 1992, a new Commander assumed control

of the New York District. It was this individual's predecessor who was

found to have unlawfully retaliated against appellant in the case which

resulted in his retroactive promotion to the Construction Chief position.

However, the task of implementing the relief awarded appellant as a

result of that prior EEO complaint (retroactive promotion) fell on the

new District Commander, who appellant asserted was responsible for the

unlawful retaliation in the instant matters. It is undisputed that the

new District Commander was fully aware of appellant's prior EEO activity.

Appellant alleged that the new District Commander let him know from

the beginning that he thought, "EEO complaints are for GS-5's not for

Chiefs," and that he allegedly said, "I don't want to see anymore

EEO complaints from you and that I'm going to really lean on you."

The District Commander denied making these statements and testified

that he harbored no retaliatory animus towards appellant. However,

at the hearing, the District Commander admitted to being the author

of a handwritten note, made on or about June 9, 1994, in which he made

the following statement about appellant: "I believe he attempts to use

every system at his disposal to avoid work--EEO complaints, disability."

Complainant's Hearing Exhibit 10.

On June 30, 1993, appellant received his first performance appraisal

from the new District Commander, encompassing the period of June 1992

to June 1993. In this appraisal, appellant received an overall rating

of "fully successful." Appellant asserted he should have received an

"exceptional" rating, noting that, prior to the tenure of new District

Commander, he had always received an "exceptional" rating. In the

justification section of the performance appraisal, appellant pointed

to the fact that he was criticized for his supervision of the work of

four area offices. However, these offices were not under appellant's

supervision during the majority of the rating period as a result of the

reorganization which had been effectuated by the District Commander.

Appellant also noted that he was criticized for the fact that the

"Westhampton Beach project" was not started as scheduled. However,

appellant produced evidence that he was not involved with this project

and was out on extended leave during the construction of the project.

The record establishes that on May 25, 1993, appellant fell at work,

resulting in a severe concussion, as well as significant back and neck

injuries. Due to these injuries, he was out of work for nearly a year,

returning on May 17, 1994. During his prolonged absence, appellant

provided the agency with medical documentation supporting his inability

to work, which included references to a recurrence of Post Traumatic

Stress Disorder (PTSD), which apparently originated from a 1991 motor

vehicle accident. Appellant's claim for workers' compensation benefits as

a result of this condition was approved. The record indicates that the

Office of Workers Compensation Programs (OWCP) arranged for appellant to

have four separate medical examinations, two conducted by board-certified

psychiatrists and the other two by neurologists. The medical findings

of all four physicians supported appellant's total disability.

Upon his return to work in May 1994, the District Commander did not allow

appellant to return to his duties as Chief of the Construction Division.

Appellant alleged that the District Commander told him that he would

have to be observed because, referring to appellant's PTSD, he might be a

danger to himself or others. Therefore, appellant was told to move into

the office adjoining the District Commander's office, rather than his

old office, so that he could be kept under observation. Appellant said

he was also told that there would be a 30-day transition period, where

he was not to interact with other members of the Construction Division.

The District Commander conceded that appellant was not immediately

returned to his former duties or office upon his return from sick leave.

Rather, the District Commander explained that he did not want appellant

to interrupt the flow of the work of the Construction Division, so he

imposed a 30-day transition period to bring appellant up-to-date on the

work of the division during his year-long absence.

During the transition period, the District Commander ordered appellant to

obtain a fitness-for-duty examination, including a psychiatric evaluation.

He testified that he did so in light of the fact that appellant's lengthy

absence was attributed in large part to his PTSD, and he thought that

"a second opinion was prudent" on appellant fitness to return to the

stressful responsibilities of the Construction Division Chief. On June

9, 1994, the District Commander entered appellant's office and angrily

berated him for not keeping a scheduled appointment for a psychiatric

evaluation. In fact, appellant had attempted to keep this appointment,

but due to a scheduling error on the part of the agency, was told that

he did not have an appointment on that day. Appellant alleged that the

District Commander would not let him explain, but continued to berate him

and angrily slam his newspaper on appellant's desk. Appellant alleged

he became physically ill as a result of this encounter, and felt he

might have a heart attack. He was accompanied to the infirmary by a

coworker, and later was picked up by his wife and seen by his doctor.

The District Commander admitted to an angry exchange with appellant, but

stated that it was over appellant's failure to comply with a directive to

meet with several other agency employees concerning the reorganization of

appellant's division. While the District Commander stated that they both

raised their voices, and acknowledged slamming a newspaper on appellant's

desk, he denied yelling at appellant in a menacing fashion.

As a result of this incident, appellant was medically unable to return

to work and filed a workers' compensation claim for a recurrence of

his PTSD. This workers' compensation claim was denied by OWCP because

of insufficient evidence of an injury. In July 1994. appellant said

he attempted to return, but was told by the District Commander not to

come back. The District Commander denied hearing from appellant about

returning to work until December 1994. Appellant asserted that he was

forced to take 1020 hours of leave,<4> because he was not permitted to

return to work.

On December 4, 1994, appellant received a memorandum from the District

Commander, proposing to remove him as Chief of the Construction Division.

The notice stated that upon learning appellant was ready to return to

work, his medical records, job description and performance appraisals were

sent for an evaluation by a psychiatrist, specializing in occupational

medicine, at the Walter Reed Army Hospital. The notice stated that the

psychiatrist offered the opinion that it was "unlikely" that appellant

would be able to return to his position as Chief of the Construction

Division in the "foreseeable future." The psychiatrist was quoted as

further indicating that he:

...would not recommend that [appellant] return to a position which

requires engineering judgement and management skills unless his

psychiatrist specifically stated that his insight, judgement, memory and

concentration have returned to pre-morbid levels (i.e., those expected

of an engineer with professional registration). Additionally, the

psychiatrist should state that [appellant] is not a threat to himself

or others due to his reported suicidal ideation.

In response, in early 1995, appellant met with the Brigadier General and

presented him with the findings of three independent psychiatrists who

all stated that appellant was fit to return to work. No psychiatric

impairment was discerned by any of the three psychiatrists, including

no indication of depression or suicidal ideation. The doctors noted

appellant was not taking any medication, although he had reported taking

Xanax, described as a "mild anti-anxiety medication," the year before.

In response, the Brigadier General offered appellant a psychiatric

fitness-for-duty examination, at agency expense, to determine his "ability

to perform [his] duties so as to protect [his] health and well being."

In June 1995, the psychiatrists at Walter Reed Army Medical Center,

who conducted the examination of appellant, advised the agency of

their conclusion that appellant was psychiatrically fit for duty.

No symptoms of depression, anxiety or psychosis were noted. As a result,

the Brigadier General returned appellant to his position as Chief of

the Construction Division, effective June 26, 1995. On that same day,

the District Commander transferred to another position and no longer

supervised appellant's work.

After a careful review of the record in its entirety, the Commission finds

that the AJ's recommended decision supporting his finding of unlawful

retaliation with regard to allegations nos. 3 and 6-10 sets forth the

relevant facts and properly analyzes the appropriate regulations, policies

and laws. Based on the evidence of record, the Commission discerns no

basis to disturb the AJ's conclusion that the agency's actions described

by these allegations were motivated, as least in part, by retaliatory

animus. The Commission notes that the AJ made specific credibility

findings in support of his conclusions in this case regarding the

testimony of appellant and key management witnesses. These credibility

determinations are entitled to deference due to the AJ's first-hand

knowledge, through personal observation, of the demeanor and conduct of

the witnesses at the hearing. Esquer v. United States Postal Service,

EEOC Request No. 05960096 (September 6, 1996); Willis v. Department of

the Treasury, EEOC Request No. 05900589 (July 26, 1990). The Commission,

after an independent review of the record, found no significant evidence

to contradict the AJ's credibility findings. Accordingly, it is the

decision of the Equal Employment Opportunity Commission to REVERSE that

portion of the agency's final decision which rejected the AJ's findings

of unlawful retaliation with respect to appellant's allegations nos. 3

and 6-10. With regard to allegation no. 11, the AJ's decision failed to

specifically address the evidence supporting his finding of retaliation

with regard to this issue. The Commission, upon its own review of the

record, finds that this matter, concerning the restoration/reimbursement

of appellant's leave, should not be addressed as a separate allegation

of retaliation, but rather as an element of the remedial action which

the agency will be ordered to undertake.

Finally, the Commission will address the AJ's recommended award of

non-pecuniary compensatory damages in the amount of $300,000 for the

emotional distress caused appellant by the agency's retaliatory actions.

In this regard, we note that the AJ found that appellant credibly

testified to the emotional injury he suffered, which was manifested by

feelings of stress, anxiety, humiliation and sleeplessness. Based on

this evidence, we concur with the finding that the retaliatory actions

of the agency were the proximate cause of some emotional distress for

appellant, for which he is entitled to be compensated.

The Civil Rights Act of 1991 authorizes awards of compensatory damages for

intentional discrimination in violation of Title VII. 42 U.S.C. �1981a.

The Supreme Court has held that compensatory damages are recoverable

in the administrative process. West, Secretary of Veterans Affairs

v. Gibson, No. 98-238, 1999 WL 380643 (U.S. June 14, 1999). See also,

Jackson v. United States Postal Service, EEOC Appeal No. 01923399

(November 12, 1992), request for reconsideration denied, EEOC Request

No. 05930306 (February 1, 1993); Turner v. Department of the Interior,

EEOC Appeal No. 01956390 (April 28, 1998); Carpenter v. Department of

Agriculture, EEOC Appeal No. 01945652 (July 17, 1995) (compensatory

damages in a settlement agreement). In addition to an award for past

pecuniary losses incurred because of discrimination, compensatory

damages are also available for future pecuniary losses, emotional

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

life, injury to character and reputation, loss of health, and other

non-pecuniary losses. See Enforcement Guidance: Compensatory and Punitive

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

EEOC Notice No. N915.002 (July 14, 1992) (hereinafter referred to as

"Enforcement Guidance: Compensatory and Punitive Damages"). For employers

of more than 500 employees, Section 1981a(b)(3) limits the total amount

of non-pecuniary and future pecuniary compensatory damages that may be

awarded to a complaining party to $300,000. 42 U.S.C. �1981a(b)(3)(D).

There are no precise formulas for determining the amount of damages for

non-pecuniary losses. An award of compensatory damages for non-pecuniary

losses, including emotional harm, should reflect, however, the extent

to which appellant has established that the agency's actions directly

or proximately caused the harm ("the nexus"), and/or the extent to which

other factors also may have caused the harm. In addition, non-pecuniary

damages must be limited to the sum necessary to compensate the injured

party for actual harm, even where the harm is intangible, and should

take into account the severity of the harm and the duration or expected

duration of the harm. Rivera v. Department of the Navy, EEOC Appeal

No. 01934157 (July 22, 1994), request for reconsideration denied, EEOC

Request No. 05940927 (December 11, 1995); Carpenter v. Department of

Agriculture, EEOC Appeal No. 01945652 (July 17, 1995). The Commission

notes that, for a proper award of non-pecuniary damages, the amount of

the award should not be "monstrously excessive" standing alone, should

not be the product of passion or prejudice, and should be consistent with

the amount awarded in similar cases. Wooten v. Department of Agriculture,

EEOC Appeal No. 01960727 (August 28, 1997).

In Carle v. Department of the Navy, EEOC Appeal No. 01922369 (January 5,

1993), the Commission described the type of objective evidence considered

relevant when assessing the merits of a complainant's request for

emotional distress damages:

[E]vidence should have taken the form of a statement by appellant

describing her emotional distress, and statements from witnesses, both

on and off the job, describing the distress. To properly explain the

emotional distress, such statements should include detailed information

on physical or behavioral manifestations of the distress, information on

the duration of the distress, and examples of how the distress affected

appellant day to day, both on and off the job. In addition, the agency

should have asked appellant to provide objective and other evidence

linking . . . the distress to the unlawful discrimination . . . .

Objective evidence may include statements from the complainant concerning

his/her 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. Statements from others, including

family members, friends, and health care providers 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. Objective evidence also may include documents

indicating a complainant's actual out-of-pocket expenses related to

medical treatment, counseling, and so forth, related to the injury

allegedly caused by discrimination. See Enforcement Guidance: Compensatory

and Punitive Damages, supra. In determining damages, the agency is only

responsible for those damages that are clearly shown to be caused by the

alleged discriminatory conduct, not for any and all damages in general.

See Rountree v. Department of Agriculture, EEOC Request No. 05950919

(February 15, 1996).

In this case, the sole evidence presented by appellant concerning

the emotional harm he suffered as a result of the agency's retaliatory

actions was his own testimony that he experienced significant and ongoing

feelings of humiliation, anxiety, depression, stress and sleeplessness.

In addition, while appellant presented no statements from his health

care providers in support of his claim for compensatory damages, the

record does contain some medical records which were submitted to the

agency during the events at issue. In this regard, the Commission

notes that evidence from a health care provider is not a mandatory

prerequisite for recovery of compensatory damages for emotional distress.

Bernard v. Department of Veterans Affairs, EEOC Appeal No. 01966861 (July

17, 1998). Appellant's own testimony, along with the circumstances of

a particular case, can suffice to sustain his burden. Nonetheless, the

Commission has held that the absence of supporting evidence may affect

the amount of damages deemed appropriate in specific cases. Id.

After careful consideration of all the evidence of record, as well as

the arguments of both parties on appeal, it is the decision of the

Commission that, given Commission awards in similar cases, the AJ's

award of $300,000 in non-pecuniary damages in this case was excessive.

For example, the evidence concerning the severity and duration of the

harm to appellant caused by the agency does not rise to the level of the

evidence of harm supporting the damage awards in Finlay v. United States

Postal Service, EEOC Appeal No. 01942985 (April 29, 1997) ($100,000

award in non-pecuniary damages for severe psychological injury over

four years which was expected to continue for an indeterminate period

of time. This included ongoing depression, frequent crying, concern for

physical safety, loss of charm, lethargy, social withdrawal, recurring

nightmares, a damaged marriage, stomach distress and headaches.); McCann

v. Department of the Air Force, EEOC Appeal No. 01971851 (October 23,

1998) ($75,000 award in non-pecuniary damages for psychological injuries,

including a recurrence of PTSD, which had resulted in the need for more

than three years of continuing therapy after the agency's discriminatory

actions. At the time of her hearing, complainant had been diagnosed with

"chronic" depression, and was taking a number of medications, including

Prozac, Haldol and Trazadone.); Carpenter v. Department of Agriculture,

EEOC Appeal No. 01945652 (July 17, 1995) ($75,000 award in non-pecuniary

damages for a deterioration in appellant's medical and emotional condition

resulting in his disability retirement. Aggravation of asthma, panic

attacks, insomnia, digestive problems, loss of spirit, social withdrawal,

feelings of hostility and irritability, and loss of libido.); and Wallis

v. United States Postal Service, EEOC Appeal No. 01950510 (November 13,

1995) ($50,000 award for pain, suffering and emotional distress where

appellant produced sufficient evidence, including supporting statements

from his psychiatrist, to establish that the agency's acts of reprisal

substantially contributed to the worsening of appellant's mental condition

to the point where he had to take anti-depressive medication, and the

effects were expected to last at least seven years).

Most significantly in the present case, appellant has provided no

evidence that he continued to suffer any residual effects of the agency's

retaliatory actions after his return to work in June 1995. At that time,

the District Commander found responsible for the agency's retaliatory

actions transferred to another position and no longer had any contact

with appellant. The psychological evaluations of appellant performed in

early 1995 revealed no evidence of mental or emotional impairment, with

findings that any prior symptoms of depression or recurrent anxiety had

been resolved. During his June 1995 psychiatric evaluation, appellant

described his own general mood as "great." The Commission also notes

that the record reveals that appellant's prior symptoms of depression

and anxiety can be ascribed, at least in part, to causes other than the

agency's retaliatory actions. Appellant's PTSD had its roots in a 1991

automobile accident which was non-work related. He had a recurrence

of the PTSD between May 1993 and May 1994, after falling off a chair

at work, resulting in a severe concussion and neck and back injuries.

The weight of the evidence indicates that any symptoms of depression,

anxiety or sleeplessness experienced by appellant prior to May 1994<5>

were the result of factors other than the agency's retaliatory actions.

In sum, the agency's actions appear to be the proximate cause of at

least some of the documented psychological problems (mild depression and

anxiety, for which appellant was prescribed Xanax) for a period starting

in May 1994 and ending in early 1995, when appellant submitted psychiatric

opinions that he no longer experienced any symptoms of PTSD or any other

emotional or mental impairment.<6> Therefore, unlike the complainants

in McCann and Wallis, who similarly experienced a recurrence of a prior

mental/emotional illness as a result of their employer's actions,

appellant's symptoms were less severe and much shorter in duration.

Based on the more limited duration and extent of the emotional harm

experienced appellant, but also recognizing that appellant testified

to the additional harm caused by the ongoing humiliation he felt

as a result of the agency's actions and the damage to his reputation,

the Commission finds that he should be awarded the sum of $35,000 in

non-pecuniary compensatory damages. See, e.g., Feris v. Environmental

Protection Agency, EEOC Appeal No. 01983167 (September 18, 1998) ($35,000

for agency's failure to accommodate complainant's physical disability

over a period of time which resulted in tension, damage to self-esteem,

anxiety, anger and sleeplessness).

Accordingly, it is the decision of the Equal Employment Opportunity

Commission to REVERSE the agency's final decision which rejected the AJ's

finding of unlawful retaliation with respect to appellant's allegation

nos. 3 and 6-10. In order to remedy appellant for its retaliatory

actions, the agency shall, comply with the following Order.

ORDER

The agency is ORDERED to take the following remedial action:

(A) Within thirty (30) calendar days of the date this decision

becomes final, the agency is directed to rescind appellant's June 1993

performance appraisal with its summary rating of "fully successful"

performance appraisal at issue, and replace it with an appraisal

supporting a summary rating of "exceptional." Within the same time

period, the agency shall provide appellant with any award, bonus or

retroactive step increase which appellant would have been entitled to

if he had received the "exceptional" rating originally.

(B) The agency shall restore to appellant all sick and annual leave he

was forced to use between May 1994 and June 1995 as a result of the

agency's retaliatory actions. In addition, the agency shall provide

appellant with reimbursement for any medical expenses he may have

incurred during this period because of lapses in his medical insurance

coverage due to being placed on leave without pay.<7>

(C) Training shall be provided to the managers responsible for the

agency's actions in this matter focusing on their obligations and duties

imposed by Title VII.

(D) The agency shall post at the New York District of the U.S. Army

Corps of Engineers copies of the attached notice. Copies of the notice,

after being signed by the agency's duly authorized representative,

shall be posted by the agency within thirty (30) calendar days of the

date this decision becomes final, and shall remain posted for sixty

(60) consecutive days, in conspicuous places, including all places

where notices to employees are customarily posted. The agency shall

take reasonable steps to ensure that said notices are not altered,

defaced, or covered by any other material. The original signed notice

is to be submitted to the Compliance Officer at the address cited in

the paragraph entitled "Implementation of the Commission's Decision,"

within ten (10) calendar days of the expiration of the posting period.

(E) Within sixty (60) calendar days of the date this decision

becomes final, the agency shall award appellant the sum of $35,000

in non-pecuniary damages for the emotional distress he suffered as a

result of the agency's discriminatory actions.

(F) The agency is further directed to submit a report of compliance, as

provided in the statement entitled "Implementation of the Commission's

Decision." The report shall include supporting documentation of the

agency's calculation of backpay and other benefits due appellant,

including evidence that the corrective action has been implemented.

ATTORNEY'S FEES (H1092)

If appellant has been represented by an attorney (as defined by

29 C.F.R. �1614.501 (e)(1)(iii)), he/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 (K0595)

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 19848,

Washington, D.C. 20036. The agency's report must contain supporting

documentation, and the agency must send a copy of all submissions to

the appellant. If the agency does not comply with the Commission's

order, the appellant may petition the Commission for enforcement of

the order. 29 C.F.R. �1614.503 (a). The appellant 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. �� 1614.408, 1614.409, and 1614.503 (g). Alternatively,

the appellant 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. �� 1614.408 and 1614.409. 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) (Supp. V 1993). If the

appellant files a civil action, the administrative processing of the

complaint, including any petition for enforcement, will be terminated.

See 29 C.F.R. �1614.410.

STATEMENT OF RIGHTS - ON APPEAL

RECONSIDERATION (M0795)

The Commission may, in its discretion, reconsider the decision in this

case if the appellant or the agency submits a written request containing

arguments or evidence which tend to establish that:

1. New and material evidence is available that was not readily available

when the previous decision was issued; or

2. The previous decision involved an erroneous interpretation of law,

regulation or material fact, or misapplication of established policy; or

3. The decision is of such exceptional nature as to have substantial

precedential implications.

Requests to reconsider, with supporting arguments or evidence, MUST

BE FILED WITHIN THIRTY (30) CALENDAR DAYS of the date you receive this

decision, or WITHIN TWENTY (20) CALENDAR DAYS of the date you receive

a timely request to reconsider filed by another party. Any argument in

opposition to the request to reconsider or cross request to reconsider

MUST be submitted to the Commission and to the requesting party

WITHIN TWENTY (20) CALENDAR DAYS of the date you receive the request

to reconsider. See 29 C.F.R. � 1614.407. All requests and arguments

must bear proof of postmark and 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 filed on the date it is received

by the Commission.

Failure to file within the time period will result in dismissal of your

request for reconsideration as untimely. If extenuating circumstances

have prevented the timely filing of a request for reconsideration,

a written statement setting forth the circumstances which caused the

delay and 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. � l6l4.604(c).

RIGHT TO FILE A CIVIL ACTION (R0993)

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 an action in an appropriate

United States District Court. It is the position of the Commission

that 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. You should be aware, however, that

courts in some jurisdictions have interpreted the Civil Rights Act of

1991 in a manner suggesting that a civil action must be filed WITHIN

THIRTY (30) CALENDAR DAYS from the date that you receive this decision.

To ensure that your civil action is considered timely, you are advised to

file it WITHIN THIRTY (30) CALENDAR DAYS from the date that you receive

this decision or to consult an attorney concerning the applicable time

period in the jurisdiction in which your action would be filed. In the

alternative, you may file a civil action AFTER ONE HUNDRED EIGHTY (180)

CALENDARS 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 (Z1092)

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:

August 5, 1999

_________________ _______________________________

DATE Frances M. Hart

Executive Officer

Executive Secretariat

NOTICE TO EMPLOYEES

POSTED BY ORDER OF THE

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

An Agency of the United States Government

This Notice is posted pursuant to an Order by the United States Equal

Employment Opportunity Commission dated _____________ which found

that a violation of the Title VII of the Civil Rights Act 0f 1964,

as amended, 42 U.S.C. �2000e et seq., has occurred at this facility.

Federal law requires that there be no discrimination against any

employee or applicant for employment because of the person's RACE,

COLOR, RELIGION, SEX, NATIONAL ORIGIN, AGE, or PHYSICAL or MENTAL

DISABILITY with respect to hiring, firing, promotion, compensation,

or other terms, conditions or privileges of employment.

The U.S. Army Corps of Engineers, New York District, will comply with

such Federal law and will not take action against individuals because

they have exercised their rights under law.

The U.S. Army Corps of Engineers, New York District, has been found

to have unlawfully retaliated against the individual affected by the

Commission's finding because of his prior EEO activity. The Commission

has ordered that this individual be given a new performance appraisal

with any appropriate award, have leave restored, receive payment for

certain medical expenses, and be awarded monetary damages to compensate

him for the emotional harm caused by the agency's actions. The

U.S. Army Corps of Engineers, New York District, will ensure that

officials responsible for personnel decisions and terms and conditions

of employment will abide by the requirements of all Federal equal

employment opportunity laws and will not retaliate against employees

who file EEO complaints.

The U.S. Army Corps of Engineers, New York District, will not in any

manner restrain, interfere, coerce, or retaliate against any individual

who exercises his or her right to oppose practices made unlawful by,

or who participates in proceedings pursuant to, Federal equal employment

opportunity law.

____________________

Date Posted: _____________________

Posting Expires: _________________

29 C.F.R. Part 16141 See footnote 4 of this decision.

2 We note that the facts are presented in great detail in the agency's

final decision, the investigative report and the AJ's recommended

decision, and will only be repeated herein to the extent necessary to

resolve this appeal.

3 The record indicates that appellant had also filed at least three

other EEO complaints between 1987 and 1991.

4 In a hearing exhibit submitted by appellant, he indicated that 292

hours were taken as leave without pay (LWOP), 608 hours were taken

as sick leave, and 120 hours taken as annual leave. However, towards

the end of the hearing, appellant's attorney stipulated that the 292

hours of LWOP was later converted by the agency to sick leave and paid.

Hearing Transcript at 532. Appellant testified, however, that while on

LWOP his medical insurance was temporarily terminated and he incurred

uninsured medical expenses during this period.

5 The Commission also notes that, with the exception of allegation

no. 3, regarding appellant's "fully successful" performance appraisal,

all the other allegations which resulted in findings of retaliation by

the AJ occurred after May 1994.

6 Moreover, appellant testified that he was ready to go back to work

in July 1994 as his recurrence of PTSD had been resolved.

7 The Commission notes that the agency has already converted all of

appellant's leave without pay to sick leave for which he has been paid.