Mary Kong, Complainant,v.John E. Potter, Postmaster General, United States Postal Service, Agency.

Equal Employment Opportunity CommissionJun 7, 2002
01A14005_r (E.E.O.C. Jun. 7, 2002)

01A14005_r

06-07-2002

Mary Kong, Complainant, v. John E. Potter, Postmaster General, United States Postal Service, Agency.


Mary Kong v. United States Postal Service

01A14005

June 7, 2002

.

Mary Kong,

Complainant,

v.

John E. Potter,

Postmaster General,

United States Postal Service,

Agency.

Appeal No. 01A14005

Agency No. 4A-110-0156-00

DECISION

Complainant filed a timely appeal with this Commission from a final

agency decision dated April 18, 2001, finding that it was in compliance

with the terms of a September 27, 2000 settlement agreement. See 29

C.F.R. � 1614.402; 29 C.F.R. � 1614.504(b); and 29 C.F.R. � 1614.405.

The settlement agreement provided, in pertinent part, that:

(1) Complainant will use her best efforts to fulfill her responsibility

as T6 on full duty;

(2) [Management Official A] agrees that upon request, he will consider

the duration of time Complainant spends at the window in any given day

and will use its best efforts to accommodate her within the bounds of

its authority and the demands of the postal station on that day;

Parties agree to enter into this agreement to cultivate an improved

working relationship; and

Parties agree that Complainant will be treated always as fairly and

equally as are all other employees at the station.

By letter to the agency dated March 31, 2001, complainant alleged that

the agency breached the settlement agreement, and requested that the

agency implement its terms. Specifically, complainant alleged that agency

breached the agreement when Management Official B failed to treat her in

a fair and equitable manner, in violation of provision 4 of the agreement.

In its April 18, 2001 final decision, the agency found no

breach. Specially, the agency found that the settlement agreement

binds only the signing parties, complainant and Management Official

A. Consequently, the agency concluded that complainant's allegations

regarding Management Official B are not within the purview of the

agreement and fail to constitute a breach of its provisions.

EEOC Regulation 29 C.F.R. � 1614.504(a) provides that any settlement

agreement knowingly and voluntarily agreed to by the parties, reached at

any stage of the complaint process, shall be binding on both parties.

The Commission has held that a settlement agreement constitutes a

contract between the employee and the agency, to which ordinary rules

of contract construction apply. See Herrington v. Department of Defense,

EEOC Request No. 05960032 (December 9, 1996). The Commission has further

held that it is the intent of the parties as expressed in the contract,

not some unexpressed intention, that controls the contract's construction.

Eggleston v. Department of Veterans Affairs, EEOC Request No. 05900795

(August 23, 1990). In ascertaining the intent of the parties with regard

to the terms of a settlement agreement, the Commission has generally

relied on the plain meaning rule. See Hyon v. United States Postal

Service, EEOC Request No. 05910787 (December 2, 1991). This rule states

that if the writing appears to be plain and unambiguous on its face,

its meaning must be determined from the four corners of the instrument

without resort to extrinsic evidence of any nature. See Montgomery

Elevator Co. v. Building Eng'g Servs. Co., 730 F.2d 377 (5th Cir. 1984).

Further, the adequacy or fairness of the consideration in a settlement

agreement generally is not at issue, as long as some legal detriment is

incurred as part of the bargain. However, when one of the contracting

parties incurs no legal detriment, the settlement agreement will be set

aside for lack of consideration. See MacNair v. U.S. Postal Service, EEOC

Appeal No. 01964653 (July 1, 1997); Juhola v. Department of the Army,

EEOC Appeal No. 01934032 (June 30, 1994) (citing Terracina v. Department

of Health and Human Services, EEOC Request No. 05910888 (March 11, 1992).

The Commission finds that the settlement agreement is void for lack of

consideration. We note that provision 1 merely obligates complainant to

do what she is already expected to do as an agency employee. Provision 4

merely recites the agency's preexisting obligations toward complainant

under applicable laws and regulations. Regarding provision 3, the

Commission determines that its promise �to cultivate an improved working

relationship� lacks consideration, and is too vague and subjective to

allow a determination as to whether or not the agency complied with such

a provision. See Bruns v. United States Postal Service, EEOC Appeal

No. 01965395 (June 24, 1997) (provision in settlement agreement that

complainant was to be treated fairly and with dignity and respect was

too vague to allow a determination as to whether the agency complied

with the provision). The Commission determines that provision 2 is also

too vague and subjective to allow a determination regarding compliance

(i.e., the agency will �consider� the duration of time that complainant

spends at the window; and use its �best efforts� to accommodate her).

The Commission determines that the settlement agreement fails to

provide complainant with anything that she was not already entitled to

receive as an agency employee, i.e., these provisions do not provide

any consideration in exchange for the withdrawal of the underlying EEO

complaint. We find that the settlement agreement is void for lack of

consideration and therefore order the reinstatement of complainant's

underlying complaint for further processing.

Accordingly, the agency's finding of no settlement breach is VACATED,

and the matter is REMANDED to the agency for further processing in

accordance with this decision and the ORDER set herein.

ORDER

The agency is ORDERED to resume processing of complainant's complaint from

the point processing ceased within thirty (30) calendar days of the date

this decision becomes final. The agency shall acknowledge to complainant

that it has reinstated and resumed processing of his complaint.

A copy of the agency letter of acknowledgment 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 (R0900)

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 action in an appropriate United

States District Court within ninety (90) calendar days from the date

that you receive this decision. 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 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 (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

June 7, 2002

__________________

Date