Noel Perez, Complainant,v.Anthony J. Principi, Secretary, Department of Veterans Affairs, Agency.

Equal Employment Opportunity CommissionJan 27, 2005
01a50723 (E.E.O.C. Jan. 27, 2005)

01a50723

01-27-2005

Noel Perez, Complainant, v. Anthony J. Principi, Secretary, Department of Veterans Affairs, Agency.


Noel Perez v. Department of Veterans Affairs

01A50723

January 27, 2005

.

Noel Perez,

Complainant,

v.

Anthony J. Principi,

Secretary,

Department of Veterans Affairs,

Agency.

Appeal No. 01A50723

Agency No. 200N-0654-2004100895

DECISION

Upon review, the Commission finds that complainant's complaint was

properly dismissed pursuant to 29 C.F.R. � 1614.107(a)(2).<1> In his

complaint, complainant alleged that he was subjected to discrimination

on the bases of race (Asian/Pacific Islander) and national origin

(Philippines) when:

he received a letter of counseling dated September 15, 2003, and a notice

of warning dated September 17, 2003; and,

was removed from his position on December 31, 2003.

The agency dismissed issue 1 for failing to timely contact an EEO

counselor and issue 2 for failing to file a formal complaint within 15

calendar days of receipt of the Notice of Final Interview.

The record reveals that complainant initially contacted an agency

EEO manager raising issues of discrimination on September 25, 2003.

Specifically, complainant stated that he was the victim of discrimination

and cited the letter of counseling and notice of warning among other

issues. The EEO counselor's report indicates that complainant initially

met with an EEO counselor regarding issue 1 on December 12, 2003.

On appeal, complainant's representative stated that she was often

incapable of timely responses due to exposure to environmental

contaminants.

EEOC regulations state that an aggrieved individual must contact an EEO

counselor within 45 days of the alleged discriminatory occurrence. 29

C.F.R. � 1614.105(a)(1). The Commission has adopted a "reasonable

suspicion" standard (as opposed to a "supportive facts" standard) to

determine when the forty-five (45) day limitation period is triggered. See

Howard v. Department of the Navy, EEOC Request No. 05970852 (February

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. This time limit may

be extended, however, if the individual was unaware of the time limits,

if he did not know or could not reasonably have known that discrimination

had occurred, if he was prevented from timely contacting a counselor by

circumstances beyond his control, or for any other reasons considered

sufficient by the Commission. 29 C.F.R. � 1614.105(a)(2). In addition,

the 45-day time limit is subject to waiver, estoppel, and equitable

tolling. 29 C.F.R. � 1614.604(c). If complainant fails to contact a

counselor within the 45-day time limit, and does not present arguments

or evidence that would support an extension of this time limit, then

the complaint may be dismissed pursuant to 29 C.F.R. � 1614.107(a)(2).

With respect to issue 1, we find that complainant had a reasonable

suspicion of discrimination on September 15 and 17, 2003, when he was

given a notice of counseling and notice of warning. We find further that,

although complainant contacted the EEO Manager by letter on September

25, 2003, and later spoke with the EEO Manager, an individual logically

connected to the EEO process, he did not exhibit an intent to pursue the

EEO complaint process at that time. The Commission has held that in order

to establish EEO Counselor contact, an individual must contact an agency

official logically connected to the EEO process and exhibit an intent

to begin the EEO process. See Allen v. United States Postal Service,

EEOC Request No. 05950933 (July 9, 1996). The Commission finds that

complainant did not contact the EEO Manager again and did not initiate

EEO counseling until December 12, 2003, which was beyond the requisite

time period. Complainant's representative failed to submit any medical

documentation showing that she was unable to contact the EEO counselor

between the time she contacted the EEO Manager on September 25, 2003,

and when she contacted the EEO Counselor on December 12, 2003. We find

that complainant and his representative have been unable to show that he

or his representative were prevented from timely contacting a counselor

by circumstances beyond their control.

The regulation set forth at 29 C.F.R. � 1614.107(a)(2) states, in

pertinent part, that an agency shall dismiss a complaint which fails to

comply with the applicable time limits contained in 29 C.F.R. � 1614.106,

which, in turn, requires the filing of a formal complaint within fifteen

(15) days of receiving a notice of the right to do so.

With respect to issue 2, complainant received his notice of right to

file on February 2, 2004, and his formal complaint was not filed until

February 26, 2004, which is beyond the fifteen (15) day limitation

period. On appeal, complainant has not offered adequate justification to

warrant an extension of the time limit for filing the complaint nor has he

shown that he or his representative were prevented from timely filing the

formal complaint by circumstances beyond their control. Accordingly, the

agency's final decision dismissing complainant's complaint is AFFIRMED.

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:

January 27, 2005

______________________________ __________________

Carlton M. Hadden, Director Date

Office of Federal Operations

1 The agency contends that complainant

did not timely file the instant appeal and stated that it attached two

U. S. Postal Service Track and Confirm sheets showing when complainant

received the FAD. However, the agency appeal brief does not contain

any such attachment. Because the agency failed to supply a copy of the

certified mail receipt or any other material capable of establishing

the date that complainant received the final decision, the Commission

presumes that the appeal was filed within thirty (30) calendar days of

the date of complainant's receipt of the final decision.