Joseph S. Mahaley, Complainant,v.Spencer Abraham, Secretary, Department of Energy, Agency.

Equal Employment Opportunity CommissionApr 5, 2002
01A10170_r (E.E.O.C. Apr. 5, 2002)

01A10170_r

04-05-2002

Joseph S. Mahaley, Complainant, v. Spencer Abraham, Secretary, Department of Energy, Agency.


Joseph S. Mahaley v. Department of Energy

01A10170

April 5, 2002

.

Joseph S. Mahaley,

Complainant,

v.

Spencer Abraham,

Secretary,

Department of Energy,

Agency.

Appeal No. 01A10170

Agency No. 0074HQSO

DECISION

Complainant initiated contact with an EEO Counselor on May 15, 2000.

On July 6, 2000, complainant filed a formal EEO complaint wherein

he claimed that he was discriminated against on the bases of his race

(Caucasian), sex (male), age (48), national origin (non Asian-American),

and in reprisal for when he spoke out on January 7, 2000, against the

Department Secretary's plan to only consider Asian-Americans for the

proposed Ombudsman position. The alleged discriminatory incidents are

that on February 5, 2000, complainant's nomination for a Fiscal Year 2000

Meritorious Presidential Rank Award Nomination was disapproved and on

April 13, 2000, complainant's recommended promotion to pay level ES-6

was disapproved, with final approval delayed until after the instant

complaint was filed. The record indicates that complainant seeks

compensatory damages for damage to his reputation.

In its decision dated September 12, 2000, the agency addressed the

alleged discriminatory incidents as two separate claims. The agency

dismissed the claim concerning the disapproval of the award nomination,

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

failed to initiate contact with an EEO Counselor in a timely manner.

The agency determined that complainant's EEO contact of May 15, 2000,

was more than 45 days after the award nomination was disapproved.

The agency dismissed the claim concerning complainant's delayed promotion,

pursuant to 29 C.F.R. �1614.107(a)(5), on the grounds that the claim was

rendered moot when complainant was promoted on May 28, 2000. The agency

determined that complainant would not have received additional salary or

employment benefits had his promotion occurred in April 2000, because

the pay rate for senior executives in the federal government is frozen

at level III of the executive schedule. With regard to complainant's

request for compensatory damages, the agency

determined that an award of compensatory damages is not appropriate

because complainant's claim is speculative and lacking in objective

evidence.

On appeal, complainant claims that he did not realize that a retaliatory

campaign was being conducted against him until April 13, 2000, when his

promotion was denied.

With regard to the claim concerning complainant's disapproved award

nomination, we find that complainant should have reasonably suspected

discrimination when his nomination was disapproved in February 2000.

Therefore, we find that complainant's contact of an EEO Counselor on May

15, 2000, was not within the 45-day limitation period. Accordingly,

the agency's dismissal of this claim on the grounds of untimely EEO

contact was proper and is AFFIRMED.

EEOC Regulation 29 C.F.R. �1614.107(a)(5) provides that prior to a

request for a hearing, an agency shall dismiss an entire complaint when

the issues raised therein are moot. To determine whether the issues

raised in a complaint are moot, it must be ascertained (1) if it can be

said with assurance that there is no reasonable expectation that the

alleged violation will recur, and (2) if the interim relief or events

have completely and irrevocably eradicated the effects of the alleged

violation. See County of Los Angeles v. Davis, 440 U.S. 625 (1979).

When such circumstances exist, no relief is available and no need for

a determination of the rights of the parties is presented.

The agency determined that complainant's claim concerning his delayed

promotion is moot because he would not have received additional salary or

employment benefits had he been promoted in April 2000. The agency also

determined that complainant's request for compensatory was speculative

as complainant did not provide objective evidence to support his claim.

To establish a claim of compensatory damages, a complainant must provide

detailed evidence in support. Carle v. Department of the Navy, EEOC

Appeal No. 01922369 (January 5, 1993). In Carle, the Commission described

the type of objective evidence that may be considered when assessing the

merits of a request for damages bases on emotional distress, including,

e.g., (a) copies of receipts and/or bills for medical care medication, and

transportation to the doctor; (b) a statement by complainant describing

her emotional distress and statements from witnesses, both on and off

the job, describing the distress, including detailed information on

physical or behavioral manifestations of the distress, the intensity

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

distress affected complainant day to day, both on and off the job; (c)

objective and other evidence linking expenses, if any, and the distress

to the alleged unlawful discrimination; and (d) any other information

establishing the claim.

We observe that in a letter to complainant dated July 10, 2000, the agency

requested that complainant provide objective evidence linking the damages

to the alleged unlawful discrimination within thirty calendar days of

complainant's receipt of the letter. We find that the agency's request

for objective evidence in support of complainant's claim for compensatory

damages failed to provide complainant with sufficient information as to

the evidence necessary to prove damages and entitlement. The agency

should advise complainant that he should submit objective evidence such

as statements 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 have been incurred

as a result of the alleged discriminatory conduct. It further should

advise him that he may submit statements from others, including family

members, friends, health care providers, other counselors addressing,

for example, the outward manifestations or physical consequences of

emotional distress. Objective evidence may include documents indicating

complainant's actual out-of-pocket expenses, if any, related to medical

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

caused by discrimination. The agency should advise complainant that he

must establish a connection between the alleged discriminatory action and

the resulting injury. We further note that the agency also should inform

complainant that a request for compensatory damages related to emotional

pain and suffering may permit the agency to seek personal and sensitive

information from him in order to determine whether the injury is linked

solely, partially, or not at all to the alleged discriminatory conduct.

See Robert Broughton v. Department of the Navy, EEOC Appeal No. 01951999

(April 25, 1995). In light of complainant's claim for compensatory

damages, the effects of the alleged violation may not have been completely

eradicated. See Estafania v. Small Business Administration, EEOC Appeal

No. 01940838 (April 18, 1994). Accordingly, the agency's decision to

dismiss this claim on the grounds of mootness is REVERSED. This claim

is hereby REMANDED for further processing pursuant to the Order below.

ORDER (E0900)

The agency is ordered to process the remanded claim in accordance with

29 C.F.R. � 1614.108. The agency shall acknowledge to the complainant

that it has received the remanded claim within thirty (30) calendar

days of the date this decision becomes final. The agency shall issue

to complainant a copy of the investigative file and also shall notify

complainant of the appropriate rights within one hundred fifty (150)

calendar days of the date this decision becomes final, unless the matter

is otherwise resolved prior to that time. If the complainant requests a

final decision without a hearing, the agency shall issue a final decision

within sixty (60) days of receipt of complainant's request.

A copy of the agency's letter of acknowledgment to complainant and a

copy of the notice that transmits the investigative file and notice of

rights must be sent to the Compliance Officer as referenced below.

IMPLEMENTATION OF THE COMMISSION'S DECISION (K0501)

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 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 (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 (T0900)

This decision affirms the agency's final decision/action in part, but it

also requires the agency to continue its administrative processing of a

portion of your complaint. 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 on both that portion

of your complaint which the Commission has affirmed and that portion

of the complaint which has been remanded for continued administrative

processing. 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 your appeal with the Commission, until

such time as the agency issues its final decision on your complaint.

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

April 5, 2002

__________________

Date