Hilary E. Sadler, Complainant,v.Carlos M. Gutierrez, Secretary, Department of Commerce, Agency.

Equal Employment Opportunity CommissionSep 18, 2008
0120070663 (E.E.O.C. Sep. 18, 2008)

0120070663

09-18-2008

Hilary E. Sadler, Complainant, v. Carlos M. Gutierrez, Secretary, Department of Commerce, Agency.


Hilary E. Sadler,

Complainant,

v.

Carlos M. Gutierrez,

Secretary,

Department of Commerce,

Agency.

Appeal No. 0120070663

Agency No. 05-55-00051

DECISION

Complainant filed an appeal from the agency's September 28, 2006 final

decision concerning her equal employment opportunity (EEO) complaint

alleging 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.

For the following reasons, the Commission AFFIRMS the agency's final

decision.

BACKGROUND

At the time of events giving rise to this complaint, complainant worked

as a Senior Import Policy Analyst, GS-1101-13 and later, as a Senior

International Trade Compliance Specialist, a GS-1801-13, with the

International Trade Administration (ITA), Import Administration (IA),

Office of Operations, Office of China/Non-Market Economies (China/NME) at

the agency's facility in Washington, DC. On March 2, 2005, complainant

filed an EEO complaint alleging that she was discriminated against on

the bases of race (African-American) and in reprisal for prior protected

EEO activity under Title VII of the Civil Rights Act of 1964 when:

1. Office of Chief Counsel (OCC) Attorney A1 and subordinate

attorneys A2 and A3 disallowed complainant to use complainant's legal

title "Esquire," because she is not a Department of Commerce attorney;

2. A1 completely rewrites complainant's policy documents and refuses

to concur with complainant's decisions unless all of A1's revisions are

incorporated in the documents;

3. A1's and subordinate attorney's revisions have caused continuous

and unreasonable delay in concurrence and return of complainant's

documents, and office delay in issuing several decisions in non-compliance

with statutory deadlines;

4. Import Administration (IA) Attorneys A1, A4 and A2 show

contemptible attitudes toward complainant in the following ways:

a. A1 used enlarged and capital fonts in electronic mail

messages;

b. A1 made rude margin notes and sent rude handwritten

notes to complainant;

c. A1 degraded complainant's character in legal staff

meetings; and

d. A1 refused to work with complainant during the concurrence

process;

5. Complainant was transferred to the Office of China and Non-Market

Economies (China/NME) on August 8, 2004, but she had no knowledge of

the transfer until mid-January 2005. Complainant provides the following

information to support this claim:

a. Complainant was forced to transfer to this office when

all other employees applied for positions in the same office;

b. Complainant did not receive paperwork on transfer until

mid-January 2005, when Office of Human Resource Management

informed complainant. Management never informed complainant of

the personnel action completion;

c. IA office administration constantly requested

complainant's resume for one week to justify qualifications for

the realigned position; however, the other sunset analyst has

never been approached for her resume;

d. Complainant did not transfer her offices on June 23,

2005, while she was first notified of the transfer to her new

offices and job duties in March 2004;

e. Complainant's technical office status was under the

supervision of S7, not S3;

f. Complainant's job series changed from 1101 (general

business and industry) to 1801 (investigator);

g. Complainant received no pay increase for her new role as

sunset review "Team Leader" for the new analysts and supervisors

as they learn the statutory regulations and draft decisions

under sunset review;

h. Complainant was assigned to a sunset program manager

and office director who have no sunset review experience.

Complainant must train them in sunset review and they will

evaluate complainant's sunset review performance;

i. Complainant was assigned to operations and continued her

sunset policy duties. Only two to three analysts per office are

assigned to perform sunset review duties. Complainant was not

compensated for a duty that similarly situated employees do not

have to perform. Other analysts have the same rank without the

additional sunset review duty. Complainant is the only analyst

performing sunset duties in her cluster of two offices although

she receives the same pay as other similarly situated analysts

not performing sunset duties;

6. On December 23 and 30, 2004, complainant was harassed when

Senior Import Policy Analyst C1, who has no supervisory authority over

complainant, ordered complainant to submit information found on a current

weekly report while C1 was on vacation. The request was from S1, Policy

Communications, who never contacted complainant;

7. In October 2004, S1 placed interrogatory responses to

complainant's complaint on the network drive for at least 50 people,

if not the entire IA to see. Complainant's name was the file name;

8. IA Office of Policy Senior Management S2, M1, and S3 denied

her a continued Office of Policy position. Complainant provides the

following information pertaining to this claim:

a. The agency has had 25 Office of Policy vacancies since

November 2004;

b. The agency advertised a new vacancy announcement for

four Import Policy Analyst positions ending January 19, 2005;

c. Complainant was not offered an interview until she

mentioned that she had been on the certification list for a few

weeks;

d. M2 exhibited contempt toward complainant while setting

the interview time;

9. IA Office of Policy Supervisor S3 reduced complainant's training

when she was only given a free ticket to the two day, 2005 International

Trade Law Update Conference while others received a severely reduced

government rate, and had the opportunity to attend the full conference:

a. Complainant received no other relevant training outside

the office, except for the free International Trade Law Update

classes and two free International Trade Administration's (ITA)

Leadership Program. Other analysts under S3's direction are given

ample training opportunities, including training outside of job

duties;

10. In March 2004, although S3 told complainant that she would write a

new policy and procedures manual with the other half of the sunset team;

Senior Management Officials requested that OCC A1 and A5 write a manual

and train employees designated to take on Sunset Review duties;

11. Complainant has not received a Performance Plan. Office Director

S4 informed complainant that since May 2005, 100 percent of complainant's

duties would be considered "OTHER DUTIES AS ASSIGNED;"

12. Complainant has no real supervisory structure. Complainant

reports to a sunset coordinator, a program manager, and to an office

director, despite being at a professional level that requires independent

performance. Complainant must also perform tasks as directed by four

outside Sunset Coordinators, as well as S3;

13. After four requests, S5 and S4 took over two months to approve

complainant's request for 5 days annual leave from June to September

2005:

a. On June 24, 2005, S5 and S4 approved complainant's annual

leave requests for July 1, 2005. Complainant's original request

for this date was April 18, 2005;

b. In a previous meeting, S5 suggested that complainant

take a two-week vacation in August; however, when complainant

requested one week vacation, S5 did not respond for at least

a week, discussed the leave with S4 in front of complainant,

and asked complainant if she had any work due the following

week. Complainant has assignments due the third and fourth week of

each month and wonders if she will ever be authorized a two-week

vacation like other analysts. Complainant is concerned that she

will not be able to use complainant's "use-or-lose" leave when

she would like and not be approved to carry over any forfeited

leave if the opportunity arises;

14. S4 is attempting to force complainant to use compensatory time

earned for personal leave even though complainant has over two weeks of

projected use-or-lose annual leave in 2005;

15. In early May 2005, complainant requested two no cost ITA

Leadership School classes scheduled for June 2005. After several

requests, S4 and S5 approved only one class the day before the class

started;

16. S4 informed complainant that she, S7 and M3 decided that S6

should be Sunset Coordinator in complainant's office and the cluster of

two offices, even though no one in the office has any knowledge regarding

sunset review critical performance;

17. Until late June 2005, S4 directed complainant to report to S6,

who is on a temporary assignment in the office, and to report to S5 for

time and attendance and unrelated sunset matters. S5 has been included

in all sunset activities, has been included in all of S6's written

communications since June 20, 2005; on June 24, 2005, S4 directed

complainant to include S5 and complainant on all sunset emails, and

since then, S6 includes S5 in all email interaction between them;

18. In mid-June 2005, S6 informed complainant that she was not

performing any sunset duties except to task complainant and "review for

substance." S6 has no prior sunset experience. Complainant must train

S6 on sunset procedures, policies and correspondence. Although S6 is

frequently out of the office once or twice every week, complainant must

report to S6 with total inclusion of S4 and S5;

19. S6 sends complainant task lists every week and withholds

information from complainant until she is tasked. S6 however informs

S5 of all sunset activity because he reminds complainant of tasks S6

may or may not have told complainant about;

20. S6 subjects complainant to constant, daily harassment through

emails, while S5 advises complainant "to go easy on S6 because she is

sick;"

21. Complainant requested S6's guidance on June 27 and 28, 2005, but

received no response. When she called S6 on June 30, 2005, S6 informed

complainant that she had been in the office all week;

22. S4 harasses complainant at every opportunity:

a. S4 rolled her eyes twice to C2 in response to

complainant's question at her introductory meeting with outside

supervisors led by M4 in April 2005;

b. S4 harassed complainant surrounding complainant's office

move from room 2837 to room 4416 in May and June 2005. S4 first

forbade complainant to use the moving services, approved the use

of the moving services approximately two weeks later, then forbade

complainant to have direct contact with the moving service;

c. S4 raised her voice at complainant in a June 24, 2005

meeting, and continued to raise her voice after complainant's

request to refrain from such behavior;

d. On June 24, 2005, S4 and S5 called complainant into

S4's office to reprimand1 complainant for sending out an email

to outside parties and foreign governments without approval;

e. S4 directed complainant to write a training manual on

sunset review and train everyone in the office even though she

informed complainant that she has no authority to make decisions

on sunset procedures and review;

f. S4 denied complainant business cards due to lack of

funds even though complainant's duties entail meeting outside

parties and everyone else in the office has business cards;

23. On November 17, 2005, S4 came to complainant's office and

asked complainant if she was at the all hands meeting with a new agency

official. At that time, S4 said she wanted to make sure that the whole

office was there, and noted that she did not see complainant, and then

immediately left the office; and

24. The Office of Civil Rights did not complete her EEO Investigation

or issue an agency decision for a previous EEO complaint filed on July 5,

2002.2

By letter dated November 22, 2005, the agency dismissed claim (24)

pursuant to 29 C.F.R. � 1614.107(a)(8) on the grounds that this claim

alleged dissatisfaction with the processing of a prior complaint.

By letter dated April 17, 2006, the agency notified complainant of

the conclusion of the investigation of her complaint. Complainant was

provided with a copy of the report of investigation and notice of her

right to request a hearing before an EEOC Administrative Judge (AJ).

In accordance with complainant's request, the agency issued a final

decision, dated September 28, 2006, pursuant to 29 C.F.R. � 1614.110(b).

The agency found that complainant failed to prove that she was subjected

to discrimination as alleged.

In its final decision, the agency affirmed the dismissal of claim (24)

pursuant to the grounds cited in its letter of November 22, 2005.

The agency found that with respect to claims (1) through (4), that

complainant was asked by A1 and others not to use the term "Esquire" not

because A1 or any of the other attorneys sought to harass complainant,

but because they felt it was improper inasmuch as complainant did not

work as an attorney for the agency. A1 acknowledged that she made edits

to complainant's work and when complainant failed to make the changes

she requested, A1 grew frustrated and did indicate that frustration

with enlarged fonts and all capitalizations in electronic mail messages.

The agency noted that a reasonable person would not consider the actions

described in claim (1) through (4) to be anything other than the normal

review process for complainant's work. The agency found that complainant

was not harassed as alleged based on her race or prior EEO activity.

With respect to claim (5) through (23), the agency found that complainant

claimed to have been harassed in connection with Import Administration's

office reorganization and the events that occurred as the agency

realigned supervisory personnel, redistributed work assignments and

filled specific vacancies. The agency observed that complainant viewed

her reassignment to the operations group (together with all of the agency

actions incident to that reassignment) as discriminatory, but the agency

found that complainant's reassignment and job series change was simply

part of the reorganization of the agency's Policy and Operations groups.

Specifically, the agency found that legitimate, non-discriminatory reasons

were provided by management for the actions to which complainant objected

and that complainant was not treated any differently than other employees.

For example, complainant claimed the series to which her position was

converted (GS-1801-Investigator) was less desirable than the position

she previously held (GS-1101 - General business and industry). Agency

officials familiar with both job series denied that the investigator

series was less advantageous to complainant's career. S3 explained that

both complainant and her co-worker were initially assigned to write a

new policy and procedures manual. However, work load considerations

required that S3 reprioritize the tasks assigned to complainant and her

co-worker, so that S3 himself prepared most of the training materials,

while complainant and her co-worker continued with sunset case work.

Similarly, S3 stated that in his absence, C1, acting in S3's stead,

appropriately asked complainant for information to be submitted to S1,

as part of complainant's regular duties. The agency found nothing in

the record to contradict S3's account of the incident and concluded that

complainant was not harassed by C1 acting in S3's absence. The agency

further found that S1 admitted she placed her interrogatory answers

(from the investigation of complainant's prior EEO complaint) on the

shared network drive, but did so in error. The agency found no evidence

that S1 was motivated by complainant's race or reprisal when she made

the mistake and corrected it as soon as she realized her mistake.

With respect to claims (11) - (14) and (16) - (23), the agency found

that reasonable, non-discriminatory explanations were provided by the

agency officials involved in actions complainant believed were taken to

harass her. For example, agency officials stated that other employees

reassigned to the operations office did not have performance plans

when they were reassigned and that all of complainant's leave requests

were ultimately granted. The agency reasoned that if complainant's

leave requests were delayed, it was only because officials needed to

assess complainant's portfolio and examine any deadlines in connection

with complainant's requested time off. The agency acknowledges that

complainant was encouraged to use the compensatory time off that she

had accumulated because she had accrued the maximum allowed and the

agency did not pay overtime. Complainant did not, the agency found,

show that she was treated any differently than other employees, but

more importantly, that complainant did not show any nexus between the

agency's actions and her race or prior EEO activity.

The agency observed that S4, complainant's second line supervisor,

stated that she believed complainant felt harassed when complainant

did not like S4's tone of voice or what she had to say. However, S4

denies that she acted improperly. For example, S4 believed at first that

funds were not authorized for using movers and that S4 herself had moved

offices without movers. When S4 learned that movers were authorized,

she informed complainant, but complainant was not authorized to contact

the movers directly and S4 told complainant that S4's secretary would

make the arrangements. S4 further explained that the employees who have

business cards may have purchased their own and that S4 herself had done

exactly that. Again, the agency found that complainant did not establish

that she was treated differently than other employees and had not shown

that any of S4's actions were motivated by discrimination.

Regarding the reprimand issued by S4 to complainant, the agency observed

that S4's actions were prompted by an electronic mail message that

complainant sent to officials outside of the agency regarding the office's

reorganization. That message, S4 determined, was inappropriate and S4

admits she raised her voice in discussion with complainant about it.

Other agency officials confirmed the confusion that complainant's notice

had caused and S4 needed to impress upon complainant the problems she

had caused. The agency found that S4 was not motivated by complainant's

race or prior EEO activity, but prompted by complainant's own actions.

With respect to the selection of the Special Assistant to the Deputy

Assistant Secretary for Policy, the agency relies on the statement of the

selecting official, M1, who had no prior knowledge of complainant's EEO

activity. Complainant did apply for the position, was not selected and

a candidate, not in complainant's protected racial group was selected.

The agency found that M1 explained that complainant's interview was a

strange one, and that was the reason she was not selected. The agency

found that complainant did not show that her race was considered by M1

in his decision not to select her.

The agency also found that complainant's race played no role in the

agency's selection for the Import Policy Analyst position. Rather,

the agency noted that M2, the selecting official, indicated she was

looking for specific experience in antidumping/countervailing duty case

work that complainant did not have, but the selectees did. The agency

found that complainant did not establish that her qualifications were

superior to those of the selectees and that complainant did not show

that discrimination occurred as alleged with respect to either selection

process.

Regarding claims (9) and (15) the agency credited the statements of the

agency officials responsible for authorizing training for complainant.

Specifically, complainant's requests were granted to the extent the agency

had the funding to send employees for training and that complainant

was not denied any training because of her race or prior EEO activity.

S4 admits that one request that complainant submitted was lost, but a

second request was approved after work deadlines were reviewed.

The agency considered complainant's overall claim of harassment and found

that complainant did not show that the incidents she cites were shown to

be motivated by complainant's race or prior EEO activity. The agency

found that where complainant claimed to be harassed, she did not show

that harassment stemmed from her membership in a protected class.

ANALYSIS AND FINDINGS

As this is an appeal from a decision issued without a hearing, pursuant

to 29 C.F.R. � 1614.110(b), the agency's decision is subject to de novo

review by the Commission. 29 C.F.R. � 1614.405(a). See EEOC Management

Directive 110, Chapter 9, � VI.A. (November 9, 1999). (explaining that

the de novo standard of review "requires that the Commission examine

the record without regard to the factual and legal determinations of the

previous decision maker," and that EEOC "review the documents, statements,

and testimony of record, including any timely and relevant submissions

of the parties, and . . . issue its decision based on the Commission's

own assessment of the record and its interpretation of the law").

To prevail in a disparate treatment claim such as this, complainant must

satisfy the three-part evidentiary scheme fashioned by the Supreme Court

in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). Complainant

must initially establish a prima facie case by demonstrating that he or

she was subjected to an adverse employment action under circumstances

that would support an inference of discrimination. Furnco Construction

Co. v. Waters, 438 U.S. 567, 576 (1978). Proof of a prima facie case will

vary depending on the facts of the particular case. McDonnell Douglas,

411 U.S. at 804 n. 14. 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, 120 S.Ct. 2097 (2000); St. Mary's Honor

Center v. Hicks, 509 U.S. 502, 519 (1993).

Complainant can establish a prima facie case of reprisal discrimination

by presenting facts that, if unexplained, reasonably give rise to

an inference of discrimination. Shapiro v. Social Security Admin.,

EEOC Request No. 05960403 (Dec. 6, 1996) (citing McDonnell Douglas

Corp. v. Green, 411 U.S. 792, 802 (1973)). Specifically, in a reprisal

claim, and in accordance with the burdens set forth in McDonnell

Douglas, Hochstadt v. Worcester Foundation for Experimental Biology,

425 F. Supp. 318, 324 (D. Mass.), aff'd, 545 F.2d 222 (1st Cir. 1976),

and Coffman v. Department of Veteran Affairs, EEOC Request No. 05960473

(November 20, 1997), a complainant may establish a prima facie case of

reprisal by showing that: (1) he or she engaged in a protected activity;

(2) the agency was aware of the protected activity; (3) subsequently,

he or she was subjected to adverse treatment by the agency; and (4) a

nexus exists between the protected activity and the adverse treatment.

Whitmire v. Department of the Air Force, EEOC Appeal No. 01A00340

(September 25, 2000).

In Harris v. Forklift Systems, Inc., 510 U.S. 17, 21 (1993), the Supreme

Court reaffirmed the holding of Meritor Savings Bank v. Vinson, 477

U.S. 57, 67 (1986), that harassment is actionable if it is sufficiently

severe or pervasive to alter the conditions of the complainant's

employment. The Court explained that an "objectively hostile or abusive

work environment [is created when] a reasonable person would find [it]

hostile or abusive:" and the complainant subjectively perceives it

as such. Harris, supra at 21-22. Thus, not all claims of harassment

are actionable. Where a complaint does not challenge an agency action or

inaction regarding a specific term, condition or privilege of employment,

a claim of harassment is actionable only if, allegedly, the harassment

to which the complainant has been subjected was sufficiently severe or

pervasive to alter the conditions of the complainant's employment.

Claim (24)

We find the agency properly dismissed claim (24) pursuant to 29 C.F.R. �

1614.107(a)(8) for the reasons cited in the final decision. Further,

we note that the agency issued a final decision on September 28,

2006, regarding agency case number 02-55-00207 filed on July 5, 2002.

We therefore AFFIRM the agency's dismissal of claim (24).

Regarding the remainder of the complaint, we find that the agency's

final decision is adequately supported by the record and that the agency

properly concluded that the evidence does not show that complainant was

subjected to discrimination based on her race or retaliation for prior

protected activity.3

Claims (1) through (4)

We specifically note that claim (1) through (4) involve primarily the

actions of A1, an employee to whom complainant does not report, but whose

review of complainant's work products presumably impacts complainant's

performance. We find that while A1's manner of communicating her comments

regarding complainant's work could arguably be viewed as unpleasant

and even demeaning, we find nothing in the evidence suggests that A1's

arguably objectionable manner was motivated by complainant's race.

A1 was not among the agency officials named or involved in complainant's

prior complaints and accordingly, we find that the evidence does not

establish that A1 was motivated by reprisal.

Claim (5)

Complainant claims harassment with respect to the events that surrounded

her reassignment to the Office of China and Non-Market Economies. We find

the record confirms that complainant was not singled out for harassment

on any basis when the agency underwent reorganization and complainant's

position was moved to the office in question. As suggested in the

agency's final decision, the record confirms that timely communication

between the agency's personnel officials, employees and between employees

and supervisors appears to have been inadequate. We find complainant's

change of job series, supervisory structure, and requests for her resume

to be typical agency actions that generally accompany this type of

reorganization. We find nothing in the record to support complainant's

claim that the agency's reorganization was discriminatory.

Claim (6)

We find the agency properly concluded that the explanation provided by

S3, in whose stead C1 acted at the time of the incidents described in

this claim, is reasonable. We find that C1's request that complainant

provide information to S1 to be well within C1's authority to task

complainant under the circumstances. We do not find that C1 intended

to harass complainant because of her race or prior EEO activity, by

requesting that complainant undertake a task that would be ultimately

fruitless or frustrating given the absence of other employees from the

office and the time frame involved.

Claim (7)

In claim (7), we find the explanation provided by S1, that she placed

her interrogatory answers on a shared drive by mistake, to be reasonable

and non-discriminatory and complainant has not shown S1's reason to be

pretext.

Claim (8)

We find the agency properly analyzed and that the record supports the

agency's final decision with respect to the selections that occurred

for vacancies in the Office of Policy, for which complainant wished

to be considered and for which she applied. While the record shows

that complainant had extensive experience in policy analysis, we concur

that complainant has not shown that her qualifications for the various

positions were so superior to those of the selectees that discrimination

more likely than not, accompanied the agency's selection decisions.

We find complainant claim that she was misinformed by M14 regarding

openings uncorroborated in the record.

Claim (9)

We further concur with the agency that complainant has not shown that

other employees, similarly situated to complainant, were provided with

greater training opportunities, denied to complainant as alleged in

claim (9). We are not persuaded that S3's response (that the agency

was provided a limited number of tickets for employees and the tickets

were shared among the attending employees) was pretext. Again, we find

nothing suggesting that complainant's race or prior EEO activity motivated

S3 to provide complainant with any less training than any other employee

under his supervision.

Claim (10)

Claim (10) alleges that a task (writing an agency manual) was first

assigned to her (and another analyst) and later reassigned to other

employees instead. We find nothing unusual or discriminatory in the

assignment and subsequent reassignment of the sunset procedures manual

writing by S3. We find complainant does not successfully challenge

S3's explanation that he considered the priorities and workload of both

complainant and her co-worker (during the time the office was undergoing

reorganization) in determining that reassignment of the manual writing

task (in this case, to S3 himself) was appropriate. We find complainant

did not show that her race or prior EEO activity played any role in S3's

decision.

Claims (11), (12), and (17)

We note that the reorganization and change in the nature and composition

of complainant's work assignments appears to have been the agency action

that caused complainant to be assigned to work without a performance plan.

In its decision, the agency states that S4 admits that complainant's

allegations are accurate. We find no evidence to suggest that complainant

was left without a performance plan in order to harass her.

We find that at no time did complainant not have a supervisory structure.

That complainant continued to report to the supervisor with oversight

for complainant's sunset duties, while also reporting to S5, is

understandable, when viewed as accompanying the transition following

the reorganization of complainant's position to the operations group.

We find the record supports the agency's final decision and observe that

the complicated supervisory structure (and task coordination arrangement)

complainant experienced was more likely based on the unique circumstances

under which complainant worked at the time, than on discrimination.

Claims (13) - (15)

The Commission finds that delayed approval of annual leave and

training requests, complicated by poor communications (and possibly

miscommunication) between complainant and her supervisors would aggravate

any employee. However, we find, as did the agency, that complainant

did not show that the agency's reasons for the delay were pretext or

unworthy of belief. Complainant does not claim that she was denied leave

or that she lost either annual or compensatory time off as a result

of discrimination. More significantly, we find no evidence that the

agency delayed its approval of complainant's leave requests because of

her race or prior EEO activity.

Claims (16) - (21)

With respect to complainant's claim that no one in the office has any

knowledge regarding "sunset review" critical performance, we note that

complainant's allegations are admitted in part by S6, as well as other

agency officials. S6 agrees that she has never supervised sunset review

cases before, but she has "supervised a lot of cases with many of the

same procedures" and that "[t]he skills are the same, no matter what

the topic." We find it reasonable that S6's supervisory experience

in other cases motivated the agency to designate her as the sunset

review coordinator, and not complainant's race or prior EEO activity.

Complainant's remaining allegations regarding S6 stem from the manner in

which S6 supervised her work. We observe that complainant was clearly

unhappy reporting to S6 and resisted S6's efforts to supervise her.

We find nothing in complainant's allegations or S6's response to those

allegations suggests that S6 considered complainant's race or prior EEO

activity in relationship to her management of complainant's work.

Claims (22) and (23)

At the focus of claims (22) and (23) is complainant's working relationship

with S4. We find that complainant took exception to minor incidents

(subparts (a) and (b)) that by themselves, even if they occurred as

complainant stated, do not rise to the level of harassment. Subparts

(e) (S4 assigned complainant to write a training manual) and (f) (S4

denied complainant's request for business cards) as well as claim (23)

(S4 confirmed that complainant had been at a meeting), were actions

well within the scope of S4's position to take, and S4 provided valid,

business reasons to support her decisions. We find the record void of

any evidence that S4 considered complainant's race or prior EEO activity

in making what she considered to be prudent business-related decisions.

With respect to claim (22) subparts (c) (yelling at complainant) and (d)

(reprimand), we find that complainant has not shown that more likely than

not S4 raised her voice and issued discipline to complainant because of

her race or prior EEO activity. We find little disagreement between

complainant and S4 regarding the sequence of events that preceded the

issuance of the letter of reprimand. Clearly the two engaged in a heated

discussion regarding an electronic mail message that complainant authored

and sent to multiple recipients including outside parties. Assuming for

argument's sake that complainant's view is correct and that S4's reaction

to the message was totally inappropriate and further, that S4 was mistaken

or exaggerated any problems complainant's actions created, we find no

reason to infer that S4 would not have taken the same steps with any other

employee not in complainant's protected groups in similar circumstances.

We concur with the agency's final decision that complainant did not show

that she was harassed by S4 because of her race or prior EEO activity.

Based on a thorough review of the record, including complainant's

contentions on appeal, we AFFIRM the agency's final decision finding no

discrimination.

STATEMENT OF RIGHTS - ON APPEAL

RECONSIDERATION (M0408)

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 (S0408)

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 (Z0408)

If you decide to file a civil action, and if you do not have or cannot

afford the services of an attorney, you may request that the Court appoint

an attorney to represent you and that the Court permit you to file the

action without payment of fees, costs, or other security. See Title VII

of the Civil Rights Act of 1964, as amended, 42 U.S.C. � 2000e et seq.;

the Rehabilitation Act of 1973, as amended, 29 U.S.C. �� 791, 794(c).

The grant or denial of the request is within the sole discretion of the

Court. Filing a request for an attorney does not extend your time in

which to file a civil action. Both the request and the civil action

must be filed within the time limits as stated in the paragraph above

("Right to File A Civil Action").

FOR THE COMMISSION:

______________________________

Carlton M. Hadden, Director

Office of Federal Operations

September 18, 2008

__________________

Date

1 The record reveals that S4 issued a letter of reprimand to complainant

dated July 25, 2005, regarding the June 21, 2005 electronic mail message

and subsequent discussion. Complainant requested that her complaint be

amended to add the letter of reprimand by letter dated August 15, 2005.

We shall consider the letter of reprimand to be part of the complaint

in this claim.

2 Claim (24) was originally numbered claim (11) by the agency. We have

renumbered this claim to preserve the numbering of the accepted claims.

3 On appeal, complainant arguments refer to sex discrimination as well

as race and reprisal. We note that sex was not identified as a basis

of the instant complaint either initially or by amendment.

4 Complainant alleged that when she inquired, M1 told her there were no

vacant positions in the Policy Office, while complainant claims that an

Inspector General's report from March 2005, indicates there were some 17 -

25 vacant position in that office.

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0120070663

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Office of Federal Operations

P. O. Box 19848

Washington, D.C. 20036

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0120070663