Richard L. Nolan, Complainant,v.Dirk Kempthorne, Secretary, Department of the Interior, Agency.

Equal Employment Opportunity CommissionSep 11, 2008
0120071379 (E.E.O.C. Sep. 11, 2008)

0120071379

09-11-2008

Richard L. Nolan, Complainant, v. Dirk Kempthorne, Secretary, Department of the Interior, Agency.


Richard L. Nolan,

Complainant,

v.

Dirk Kempthorne,

Secretary,

Department of the Interior,

Agency.

Appeal No. 0120071379

DECISION

Complainant filed a timely appeal with this Commission from a final

decision (FAD) by the agency dated December 21, 2006, finding that it

was in compliance with the terms of the February 11, 2000 settlement

agreement into which the parties entered. See 29 C.F.R. � 1614.402;

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

The February 2000 settlement agreement provided, in pertinent part, that

complainant would work 50% of the time for the Bureau of Land Management

(BLM) in Arizona, and 50% of the time for the Office of Civil Rights

(OCR) which was located in Washington, D.C. Complainant's official

duty station remained in Arizona, and he was apparently permitted to

work in OCR remotely from Arizona.

By letter to the agency dated August 4, 2006, complainant alleged that

the agency was in breach of the settlement agreement, and requested that

the agency specifically implement its terms. Complainant was not specific

in his breach allegations, but it appears he was concerned with the fact

that the agency was directing his full-time reassignment to OCR to the

position of Special Emphasis Program Manager, including a requirement

that his duty station be changed to Washington, D.C.1

In its December 21, 2006 FAD, the agency concluded that it had not

breached the agreement.

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 O 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).

The Commission has held that where an individual bargains for a position

without any specific terms as to the length of service, it would be

improper to interpret the reasonable intentions of the parties to include

employment in that exact position ad infinitum. See Holley v. Department

of Veterans Affairs, EEOC Request No. 05950842 (November 13, 1997);

Papac v. Department of Veterans Affairs, EEOC Request No. 05910808

(December 12, 1991); see also Parker v. Department of Defense, EEOC

Request No. 05910576 (August 30, 1991). In addition, the Commission

has held that there is no breach of a settlement agreement "where an

individual has been assigned to a position pursuant to a settlement

agreement, has held the position for a period of time, and then is

excised out of the position because of agency downsizing that was not

anticipated at the time of the agreement." Gish v. Department of the Army,

EEOC Appeal No. 01950923 (August 14, 1995). In the instant case, the

agreement was signed in 2000 and fully complied with for over six years.

Given the passage of time, the Commission finds there is no breach when

the agency sought to reassign complainant for asserted business reasons.

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 11, 2008

__________________

Date

1 Effective December 5, 2006, complainant was terminated because he

refused to accept the directed reassignment. He appealed the termination

decision to the Merit Systems Protection Board, which later affirmed the

agency's removal action. MSPB Appeal No. DE075207014213. Complainant

appealed the MSPB's decision to this Commission, which concurred with

the MSPB's decision. EEOC Petition No. 0320080052.

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0120071379

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Office of Federal Operations

P. O. Box 19848

Washington, D.C. 20036

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0120071379