George L. Austin, Complainant,v.John E. Potter, Postmaster General, United States Postal Service, Agency.

Equal Employment Opportunity CommissionOct 8, 2004
01a44069 (E.E.O.C. Oct. 8, 2004)

01a44069

10-08-2004

George L. Austin, Complainant, v. John E. Potter, Postmaster General, United States Postal Service, Agency.


George L. Austin v. United States Postal Service

01A44069

October 8, 2004

.

George L. Austin,

Complainant,

v.

John E. Potter,

Postmaster General,

United States Postal Service,

Agency.

Appeal No. 01A44069

DECISION

According to the record, complainant applied for a position with

"Manpower, Inc.,"(herein referred to as �Manpower�) to work as a contract

EEO investigator at the agency. When Manpower rejected his application

during a preliminary screening process on November 7, 2003, complainant

initiated EEO counseling on December 22, 2003. Complainant claimed that

he was the victim of unlawful employment discrimination on the bases of

age and in reprisal for prior EEO activity.

By notice dated April 26, 2004, the agency acknowledged complainant's

request for EEO counseling; however, the agency advised complainant that

it could not be processed by the agency due to a lack of jurisdiction.

Specifically, the agency notified complainant that his complaint was

against Manpower, an independent contractor, and must be filed as a

Charge of Discrimination with the local Commission office.

On May 29, 2004, complainant filed the instant appeal, arguing that

he has standing to file an EEO complaint against the agency regarding

his non-selection.

The EEO complaint process covers only aggrieved �employees� and applicants

for employment. See 29 C.F.R. � 1614.103. The test for determining

whether an individual is an employee for purposes of protection under

the discrimination statutes is set forth in Spirides v. Reinhardt,

613 F.2d 826 (D.C. Cir. 1979). In that case, the court stated that the

determination of whether an individual is an employee or an independent

contractor for purposes of Title VII involves an analysis of the economic

realities of the work relationship. The court further stated that the

most important factor to consider is the employers right to control the

means and the manner of the worker's performance. Id at 831.

As an initial matter, we find that the agency should have processed

this matter by completing EEO counseling, and by issuing complainant a

Notice of Right to File a Formal Complaint. Nonetheless, we determine

that complainant has no standing to pursue a federal sector EEO complaint.

Upon review, based on the terms of the contracts between the agency

and Manpower, we find that Manpower is a �staffing firm,� engaged by

the agency to process applications for contract EEO investigators, and

to provide the agency with their services, as �contingent workers.� See

Enforcement Guidance: Application of EEO Laws To Contingent Workers Placed

by Temporary Employment Agencies and Other Staffing Firms, EEOC 915.002,

December 3, 1997 (Guidance). The record further reflects that complainant

submitted an application for employment as a contingent worker with

Manpower, and not with the agency. Under these circumstances, we find

that complainant is not an aggrieved employee or applicant for employment

pursuant to 29 C.F.R. � 1614.103, concerning the non-selection at issue,

and has no standing in this matter.

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

October 8, 2004

__________________

Date