Marvin E. Easiley, Complainant,v.John E. Potter, Postmaster General, United States Postal Service, (Pacific Area) Agency.

Equal Employment Opportunity CommissionJul 7, 2005
01a41327 (E.E.O.C. Jul. 7, 2005)

01a41327

07-07-2005

Marvin E. Easiley, Complainant, v. John E. Potter, Postmaster General, United States Postal Service, (Pacific Area) Agency.


Marvin E. Easiley v. United States Postal Service

01A41327

July 7, 2005

.

Marvin E. Easiley,

Complainant,

v.

John E. Potter,

Postmaster General,

United States Postal Service,

(Pacific Area)

Agency.

Appeal No. 01A41327

Agency No. 1F-942-0023-03

DECISION

Upon review, the Commission finds that complainant's complaint (alleging

Section 501 of the Rehabilitation Act of 1973 (Rehabilitation Act), as

amended, 29 U.S.C. � 791 et seq.) was properly dismissed pursuant to 29

C.F.R. � 1614.107(a)(2), for untimely EEO Counselor contact and failure

to state a claim. In his complaint, complainant alleged that he was

subjected to discrimination on the bases of disability and in reprisal

for prior EEO activity (arising under the Rehabilitation Act) when:

On February 27, 2002, he was issued a Notice of Proposed Removal -

Disability Separation;

On April 9, 2002, he was issued a Letter of Decision separating him from

the Postal Service, effective April 12, 2002, and

By letter dated May 20, 2003, the U.S. Office of Personnel Management

(OPM) notified him that his application for disability retirement had

been approved.

With regard to claims 1 and 2, we agree with the agency's final

determination. EEOC Regulation 29 C.F.R. � 1614.105(a)(1) requires

that an aggrieved person must initiate contact with a Counselor within

forty-five days of the date of matter alleged to be discriminatory or,

in the case of a personnel action, within 45 days of the effective date

of the action. The Commission has adopted a �reasonable suspicion�

standard (as opposed to a �supportive facts� standard) to determine

when the forty-five day limitation period is triggered. See Howard

v. Dep't of the Navy, EEOC Request No. 05970852 (Feb. 11, 1999). Thus,

the time limitation is not triggered until a complainant reasonably

suspects discrimination, but before all the facts that support a charge

of discrimination have become apparent.

EEOC Regulations provide that the agency or the Commission shall extend

the time limits when the individual shows that he was not notified of the

time limits and was not otherwise aware of them, that he did not know

and reasonably should not have known that the discriminatory matter or

personnel action occurred, that despite due diligence he was prevented

by circumstances beyond his control from contacting the Counselor within

the time limits, or for other reasons considered sufficient by the agency

or the Commission.

Complainant here maintains that the alleged discriminatory events

(claims 1 and 2) occurred on February, 27 and April 9, 2002, but he

did not initiate contact with an EEO Counselor until June 18, 2003,

which is beyond the forty-five (45) day limitation period. On appeal,

complainant argued that the delay was due to the APWU's attempts at

resolving the problem through the collective bargaining process. However,

the Commission has repeatedly held that �internal appeals, grievances,

or informal efforts to challenge an agency's adverse action do not toll

the running of the time to contact an EEO Counselor.� Foreman v. United

States Postal Serv., EEOC Appeal No. 01A44580, at 2 (Sept. 28, 2004).

Therefore, as complainant has presented no persuasive arguments or

evidence warranting an extension of the time limit for initiating EEO

Counselor contact, the agency's final decision dismissing claims 1 and

2 is affirmed.

The agency dismissed claim 3 for failure to state a claim because the

approval/denial of disability retirement is solely within the purview

of the Office of Personnel Management and not a decision which the

U.S. Postal Service has any authority or jurisdiction. We again agree

with this determination. EEOC's regulations authorize an agency to

dismiss an EEO complaint that fails to state a claim for which relief

can be granted. See 29 C.F.R. � 1614.107(a). The standard that must

be met to justify a dismissal on this ground is similar to that required

by the courts under Fed. R. Civ. P. 12(b)(6). See Cobb v. Dep't of the

Treasury, EEOC Request No. 0597007 (Mar. 13, 1997). Moreover, our case

law requires that the complainant be �aggrieved,� meaning, he must have

�suffered direct and personal deprivation at the hands of the employer.�

Gilyard v. Dep't of Energy, Appeal No. 01A01550 (June 9, 2003) (citing

Hobson v. Dep't of the Navy, EEOC Request No. 05891133 (Mar. 2, 1990)).

Under Section 107(a) the allegations in a complaint must be taken as true

and all reasonable inferences must be drawn in favor of the complainant.

See id. It is well settled that a complaint should not be dismissed

for failure to state a claim unless it appears beyond doubt that no

set of facts can be established that would entitle the complainant to

the relief sought in the complaint. See id. (citing Conley v. Gibson,

355 U.S. 40, 45-46 (1957)).

We do not find that the U.S. Postal Service made the decision to

grant complainant disability retirement. Furthermore, we do not

find evidence that the Postal Service has any authority to do so;

only OPM has this authority. As complainant challenges the approval

of disability retirement, complainant's claim is really with OPM and

not the Postal Service, and thus he raises an impermissible collateral

attack on a decision made by another agency. As such, we cannot find

that complainant has been �aggrieved� by the Postal Service's actions in

this regard, as the agency was not the one to cause a harm or loss with

respect to a term, condition, or privilege of his employment. See also

Diaz v. Dep't of the Air Force, EEOC Request No. 05931049 (Apr. 21, 1994).

Accordingly, we AFFIRM the final agency decision.

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

July 7, 2005

__________________

Date