Sandra S. Silvestri, Complainant,v.Glenn L. McCullough, Jr., Chairman, Tennessee Valley Authority, Agency.

Equal Employment Opportunity CommissionSep 29, 2004
01A22175 (E.E.O.C. Sep. 29, 2004)

01A22175

09-29-2004

Sandra S. Silvestri, Complainant, v. Glenn L. McCullough, Jr., Chairman, Tennessee Valley Authority, Agency.


Sandra S. Silvestri v. Tennessee Valley Authority

01A22175

September 29, 2004

.

Sandra S. Silvestri,

Complainant,

v.

Glenn L. McCullough, Jr.,

Chairman,

Tennessee Valley Authority,

Agency.

Appeal No. 01A22175

Agency No. 0619-98093

DECISION

Complainant timely initiated an appeal from a final agency decision

concerning her complaint of unlawful employment discrimination in

violation of Section 501 of the Rehabilitation Act of 1973 (Rehabilitation

Act), as amended, 29 U.S.C. � 791 et seq. The appeal is accepted

pursuant to 29 C.F.R. � 1614.405. For the reasons set forth below,

we affirm the agency's final decision.

BACKGROUND

Complainant, an agency employee since 1984, was employed as a Clerk-Word

Processor, SB-3 at the agency's Paradise Fossil Plant facility in

Drakesboro, Kentucky.<1> She began seeing a psychiatrist, Director of

Psychiatry, The Medical Center at Bowling Green, in April 1995 and was

diagnosed with severe depression in May 1995. In June 1995, complainant

required hospitalization for her depression for approximately two

weeks, and was out of work for approximately six weeks. She received

electroconvulsive therapy (ECT), and was prescribed a combination of

antidepressant drugs, all with poor response. In 1996, after witnessing

several episodes of hypomania, the psychiatrist revised this initial

diagnosis, and diagnosed complainant with severe bipolar II disorder

with rapid cycling.

Bipolar disorder is characterized by periods of mania alternating with

periods of depression.<2> People with bipolar disorder II, in contrast

to people with bipolar disorder I, experience primarily depression which

alternates with periods of hypomania, elevated mood and energy that

is not as extreme as the symptoms of mania. According to the letters

written by her psychiatrist, complainant has frequent short lasting

episodes of depression which are characterized by extreme hypersomnia,<3>

hyperphagia,<4> anergia,<5> and anhedonia.<6> Complainant also is

a rapid cycler, meaning her mood may change several times a day.

See U.S. National Library of Medicine and the National Institutes

of Health, MEDLINEplus, Health Information (visited October 16, 2003)

<http:// www.nlm.nih.gov/medlineplus>. In addition, complainant suffers

from morbid obesity that has worsened with her chronic depression, chronic

lumbosacral back sprain, that is worsened by her obesity, bronchial

asthma and upper respiratory allergies, as well as chronic recurring and

severe headaches. We note, however, that the only impairment listed in

complainant's complaint is depression/bipolar rapid cycling.

On multiple occasions between 1994 and 1998, complainant asked the

Production Manager and/or the Production Supervisor for a flexible

work schedule in which she could make up time that she missed if her

illness prevented her from coming to work.<7> All of her requests for

reasonable accommodation in the form of a flexible work schedule were

denied. On February 20, 1996, complainant contacted the Plant Manager

and requested Family and Medical Leave Act (FMLA) leave �intermittently

or consecutive as necessary.� Complainant supported her request with

a letter from her psychiatrist dated February 5, 1996, advising the

Plant Manager that complainant has been under his care for serious

depression since May 1995, that complainant would require �continued

treatment,� including medication, and at least one therapy session

per month. The agency granted complainant the FMLA leave. In July

1996, complainant began working directly under the Production Manager.

In his affidavit, the Production Manager admits that he became aware

of complainant's impairment around that time. On April 16, 1997,

complainant submitted a request to the Production Manager for more

FMLA leave to be taken �intermittently or consecutive as necessary�

over the next 12-month period. Complainant enclosed a letter from her

psychiatrist dated April 14, 1997, supporting her request for FMLA leave.

The FMLA leave was again granted, but complainant alleged that on May 5,

1997, the Production Manager told her that she had worked less than nine

weeks in the past two years, and instructed her to report for a Fitness

for Duty (FFD) examination, which was held on May 13, 1997. The clinical

psychologist who conducted the FFD examination concluded that complainant

met the standards for psychological approval for the ability to work

safely, �subject to the constraints of no hazardous duties and no duties

that affect plant or personnel safety.� In contrast, on May 9, 1997,

complainant's psychiatrist informed complainant that she was making

slow progress, that her medications were only moderately effective,

and that she needed continued therapy with sessions every two weeks.

During September or October 1997, following a reorganization,

complainant and all Clerk-Word Processors, were transferred from the

Plant's Operations section to the Business Office to work under the

Acting Business Manager. On October 22, 1997, at her psychiatrist's

suggestion, complainant asked the Acting Business Manager if she could

work two to three days per week. According to complainant, the Acting

Business Manager thought it was a good idea, but the Production Manager

denied this request. On December 12, 1997, the Production Manager again

requested a FFD examination for complainant. She was again conditionally

approved for duty, provided that she performed no hazardous duties and

no duties that affect safety. On January 28, 1998, complainant received

a Marginal/Improvement Needed rating on her Employee Service Report

(performance appraisal), for the period October 1, 1996, to September

30, 1997. The comments from the Production Manager were as follows:

[Complainant's] work performance during the rating period was

significantly impacted by her continued unavailability for work. During a

meeting with [complainant] on May 15, 1997, her continued unavailability

for work and the need to significantly improve was discussed.

A subsequent medical evaluation provided no explanation and therefore

no suggested resolution to the behavior exhibited. [Complainant's]

availability for work has not improved and continues to impact the

overall efficiency and effectiveness of the Unit Production organization

and other plant organizations.

Complainant was referred for a third FFD examination on July 1, 1998, and

received conditional approval, as long as she wore adequate corrective

eyewear. On October 28, 1998, under the Acting Business Manager,

complainant received a performance rating of Fully Adequate.

Complainant sought EEO counseling and subsequently filed a formal

complaint on June 19, 1998, alleging that she was discriminated against

on the basis of disability (alleged impairments of depression and bipolar

disorder), in violation of Section 501 of the Rehabilitation Act of 1973

(Rehabilitation Act), as amended, 29 U.S.C. � 791 et seq. when:

From 1994 through 1998, the agency denied complainant's requests for

a flexible work schedule;

On January 28, 1998, complainant received a Marginal/Improvement Needed

rating on her Employee Service Report;

In May 1997 complainant was denied the opportunity to be cross-trained;

and,

Beginning in February 1994 and continuing, complainant was subjected to a

hostile work environment when: (a) derogatory comments were made about

her in 1994 when she had to take off from work due to medical problems;

(b) between October 1995 and February 1996, the Production Supervisor

told employees throughout the plant that he was going to �run her off�

and refused to give her the support she needed to perform her job; (c)

she was not informed in February 1996 that her FMLA leave request was

approved; rather, she discovered that it had been approved later when

she requested sick leave; (d) the agency refused to renovate her office

and provide updated office equipment and computer software in 1996; and,

(e) on January 29, 1998, she was told that she would be terminated if

she returned to work with medical restrictions.<8>

At the conclusion of the investigation, complainant was informed of

her right to request a hearing before an EEOC Administrative Judge or

alternatively, to receive a final decision by the agency. Complainant

requested that the agency issue a final decision.

In its decision, the agency concluded that complainant did not raise a

claim of harassment; rather, she stated a claim of disparate treatment and

denial of reasonable accommodation. The agency found that complainant

did not establish a prima facie case of discrimination on the basis of

disability. The agency concluded that complainant was not an individual

with a disability, as she produced no evidence that her conditions

substantially impaired any major life activity. The agency further found,

even assuming that complainant was an individual with a disability, that

she was not a qualified individual with a disability because she needed

a flexible work schedule, not an alternate work schedule. Moreover,

the agency contended that complainant failed to show that consistent

attendance at work and performing her assignments in a timely manner

were not essential duties of her position. Following a fitness for duty

(FFD) examination, the agency's clinical psychologist concluded that

complainant's illness did not prevent her from working a full work week.

The agency argued that it did not discriminate against complainant when

it denied her reasonable accommodation request because complainant's

position required her to be present between 7:00 a.m. and 3:30 p.m.,

and a flexible work schedule would have required overtime payments.

Additionally, no one working under the Production Manager, complainant's

second-line supervisor, had a flexible work schedule. With regard to the

marginal performance appraisal for fiscal year 1997, the agency argued

that although her performance was satisfactory when she was at work, due

to her frequent absences, her performance was unsatisfactory. The agency

concluded that while it articulated legitimate, non-discriminatory reasons

for its actions, complainant did not show that the agency discriminated

against her by a preponderance of the evidence.

On appeal, complainant describes how she qualifies as an individual

with a disability. Additionally, complainant maintains that other

employees throughout the plant were allowed to have flexible schedules.

In response, the agency re-emphasizes that complainant is not an

individual with a disability, as she never identified any major life

activity in which she was significantly limited, there were no limitations

placed on her by her personal physician, and no significant limitations

placed on her following the agency's three FFD examinations. The agency

further argues, even assuming that complainant was an individual with

a disability, that she was not a qualified individual with a disability

because she was unavailable for work an a regular basis. Moreover, the

agency maintains that complainant failed to show that she was harassed

in any way. The agency requests that we affirm its decision.

ANALYSIS AND FINDINGS

Pursuant to 29 C.F.R. � 1614.405(a), the decision on an appeal from

an agency's final decision is based on a de novo standard of review.

We find that the denial of complainant's request for a flexible work

schedule is more appropriately characterized as a claim of denial of

reasonable accommodation, rather than as a claim of harassment, although

we do find that complainant raised a claim of harassment regarding

the other incidents described in claim 4. The denial of the requested

reasonable accommodation and the marginal performance appraisal that

complainant received are both tied to the issue of her attendance.

Claim 1: Reasonable Accommodation and Flexible Work Schedule

Under the Commission's regulations, an agency is required to make

reasonable accommodation to the known physical and mental limitations of

an otherwise qualified individual with a disability unless the agency

can show that accommodation would cause an undue hardship. See 29

C.F.R. � 1630.9. The employee must show a nexus between the disabling

condition and the requested accommodation. See Hampton v. United States

Postal Service, EEOC Appeal No. 01986308 (July 31, 2002).

In a case of disability discrimination under a failure to accommodate

theory, the complainant must first establish that she is an �individual

with a disability� within the meaning of the Rehabilitation Act.

An individual with a disability is one who: (1) has a physical or mental

impairment that substantially limits one or more major life activities;

(2) has a record of such impairment; or (3) is regarded as having such

an impairment. 29 C.F.R. � 1630.2(g).<9> Examples of emotional or mental

impairments include major depression, bipolar disorder, anxiety disorders,

schizophrenia, and personality disorders. EEOC Enforcement Guidance

on the Americans with Disabilities Act and Psychiatric Disabilities,

No. 915.002, at 2-3 (March 25, 1997). Major life activities include,

but are not limited to, caring for oneself, performing manual tasks,

walking, seeing, hearing, speaking, breathing, learning, and working.

29 C.F.R. � 1630.2(i). Sitting, standing, lifting and reaching are also

recognized as major life activities. See Appendix to Part 1630, Section

1630.2(i), Major Life Activities. The Commission has also identified

mental and emotional processes such as thinking, concentrating,

and interacting with others as examples of major life activities.

EEOC Compliance Manual, Vol. 2, Definition of the Term �Disability,�

Major Life Activities, Section 902.3 (March 14, 1995) (Compliance Manual).

An impairment is substantially limiting when it prevents an individual

from performing a major life activity or when it significantly

restricts the condition, manner or duration under which an individual

can perform a major life activity, compared to the average person

in the general population. 29 C.F.R. � 1630.2(j). The following

factors should be considered in determining whether an impairment is

substantially limiting: (1) the nature and severity of the impairment;

(2) the duration or expected duration of the impairment; and (3) the

permanent or long-term impact, or the expected permanent or long-term

impact of or resulting from the impairment. 29 C.F.R. � 1630.2(j)(2).

In addition, whether a person is substantially limited in a major life

activity must be determined with reference to any mitigating measures,

both positive and negative. See Sutton v. United Airlines, 527 U.S. 471,

482 (1999). �[S]ome chronic conditions may constitute substantially

limiting impairments. . . . [E]pisodic disorder, which remit and

then intensify . . . fall into this category.� Compliance Manual,

Substantially Limits, Section 902.4.

We will assume, arguendo, that complainant is an individual with

a disability. After establishing that she is an individual with a

disability, however, complainant must still show that she is a �qualified�

individual with a disability within the meaning of 29 C.F.R. � 1630.2(m).

A �qualified individual with a disability� is an individual with a

disability who satisfies the requisite skill, experience, education and

other job related requirements of the employment position such individual

holds or desires, and who, with or without reasonable accommodation, can

perform the essential functions of the position. 29 C.F.R. � 1630.2(m).

The agency must provide reasonable accommodations for known physical

or mental limitations of an otherwise qualified individual with a

disability, unless the accommodation would impose a undue hardship.

See 29 C.F.R. � 1630.9(a). In the context of providing an accommodation,

undue hardship means significant difficulty or expense incurred by

the agency. 29 C.F.R. � 1630.2(p)(1).

The agency denied complainant's request for a flexible work schedule.

The agency argues, even assuming that complainant is an individual with a

disability, she is not a qualified individual with a disability, because

regular attendance is an essential function of the job. According to the

Production Manager, between July 1996 through October 1997, the period

in which he directly supervised complainant, complainant was absent from

work approximately 20% of the time.

The Commission's regulations contemplate the creation of an accommodation

through �[m]odifications or adjustments to the work environment, or to

the manner or circumstances under which the position held or desired is

customarily performed, that [would] enable a qualified individual with

a disability to perform the essential functions of that position.� 29

C.F.R. � 1630.2(o)(1). A modified work schedule is a type of reasonable

accommodation contemplated by the Commission's regulations. 29 C.F.R. �

1630.2(o)(2). A modified work schedule may involve adjustment to arrival

or departure times, periodic breaks, altering when certain functions are

performed, or providing additional unpaid leave. See EEOC Enforcement

Guidance on Reasonable Accommodation and Undue Hardship Under the

Americans with Disabilities Act, EEOC No. 915.002 (Revised Oct. 17,

2002) at question 22 (�Reasonable Accommodation Guidance�).

We find that the agency did not violate the Rehabilitation Act when

it denied complainant's requests for a flexible work schedule between

1994 and 1998. First, a reasonable accommodation must be effective.

See U.S. Airways v. Barnett, 535 U.S. 391, 400 (2002) (cited in Wiley

v. United States Postal Service, EEOC Appeal No. 07A20105 (September

15, 2003), req. for reconsideration denied, EEOC Request No. 05A40147

(December 11, 2003)). It is unclear exactly what kind of flexible

schedule complainant sought, as complainant does not request any a

specific schedule, other than one that would allow her to work when she

was able, �intermittently or consecutive[ly] as necessary.� An attempt by

the Production Supervisor of the HED, who took over the Business Office,

shows that even if complainant's requests for that type of flexible work

schedule had been granted, her problems regarding attendance and keeping

up with her workload would not have been resolved. In his affidavit the

Production Supervisor explains that he �made her a slot to work at, at her

own pace, and time to where she wouldn't . . . be felt pressured down.�

He testifies that complainant �was coming in late and staying late, and

she did real well. She kept her eight hours real well, and that went on

a couple of weeks or so and then it sort of filtered off. She started

missing again.� Second, a reasonable accommodation must be reasonable

on its face, i.e., plausible or feasible. See id. at 401-02. The record

indicates that the only accommodation that would have been effective would

be one that would have allowed complainant to report to work whenever she

felt able; however, such an accommodation is not reasonable on its face.

See Wiley, EEOC Appeal No. 07A20105, req. for reconsideration denied, EEOC

Request No. 05A40147. The Production Manager stated in his affidavit that

a number of employees had to do complainant's work during her absence,

and �her unavailability for work severely impacted the efficiency of

the organization.� The Production Supervisor stated that complainant's

absences were �really interrupting the business.� The Acting Business

Manager stated that due to complainant's frequent absences, complainant

had to be given work without deadlines, and that she could never be given

work assignments with the expectation that they would be completed on any

particular date. As stated in Wiley, �It is not �plausible' or �feasible'

for an employer to excuse chronic erratic absenteeism and tardiness

by an employee who cannot provide timely notice sufficient to enable

the employer to ensure adequate staffing.� EEOC Appeal No. 07A20105,

req. for reconsideration denied, EEOC Request No. 05A40147. Therefore,

the Commission concludes that complainant is not a qualified individual

with a disability, and that she did not establish that the agency failed

to provide a reasonable accommodation for her alleged disability.

Claim 2: Disparate Treatment and Employee Service Report

As referenced above, complainant also claims that the agency discriminated

against her when she received a Marginal/Improvement Needed rating on

her Employee Service Report for the period October 1, 1996, to September

30, 1997. The Production Manager testifies in his affidavit, and states

on the performance appraisal, that he gave complainant a marginal rating

because of her �unavailability for work,� although he states that she

performed satisfactorily when she was at work. The agency takes the

position that complainant's absences were not related to any disability.

A claim of disparate treatment based on indirect evidence is examined

under the three-part analysis first enunciated in McDonnell Douglas

Corp. v. Green, 411 U.S. 792 (1973). For complainant to prevail, she

must first establish a prima facie case of discrimination by presenting

facts that, if unexplained, reasonably give rise to an inference of

discrimination, i.e., that a prohibited consideration was a factor in the

adverse employment action. Id. at 802; Furnco Constr. Corp. v. Waters,

438 U.S. 567 (1978); Heyman v. Queens Village Comm. for Mental Health

for Jamaica Community Adolescent Program, 198 F.3d 68 (2d Cir. 1999)

(analyzing a disparate treatment claim under the Rehabilitation Act).

The burden then shifts to the agency to articulate a legitimate,

nondiscriminatory reason for its actions. Texas Dep't of Community

Affairs v. Burdine, 450 U.S. 248, 253 (1981). Once the agency has

articulated such a reason, the question becomes whether the proffered

explanation was the true reason for the agency's action, or merely

a pretext for discrimination. St. Mary's Honor Center v. Hicks, 509

U.S. 502, 511 (1993). The burden of persuasion, by a preponderance of the

evidence, remains at all times on complainant. Burdine, 450 U.S. at 256.

To establish a prima facie case of discrimination on the basis of

disability under a disparate treatment analysis, complainant must

demonstrate that: (1) she is a qualified individual with a disability;

(2) she was subjected to an adverse employment action; and (3) the

circumstances surrounding the adverse action give rise to an inference

of discrimination. Lawson v. CSX Transp., Inc., 245 F.3d 916 (7th

Cir. 2001).

As described above, complainant failed to show that she is a qualified

individual with a disability, and therefore cannot establish a prima

facie case. Even assuming, however, that complainant established a

prima facie case, we find that the agency articulated a legitimate,

nondiscriminatory reason for giving complainant a Marginal/Improvement

Needed rating on her Employee Service Report for the period October 1,

1996, to September 30, 1997; namely, her excessive, unplanned absences

affected her ability to complete her work, and her performance evaluation

reflected that fact. The Commission finds that complainant failed to

rebut the agency's explanation, and failed to establish discrimination on

the basis of disability by a preponderance of the evidence with respect

to the marginal performance evaluation.

Claim 3: Disparate Treatment and Cross-Training

Complainant also claims that in May 1997 she was discriminated against

on the basis of disability when she was denied the opportunity to be

cross-trained in order to gain varied work experiences that were provided

to other employees. Again, complainant failed to show that she is a

qualified individual with a disability. She has also not demonstrated

that denial of training gives rise to an inference of discrimination.

Complainant has provided no connection between being denied this training

and her alleged disability. Since complainant has not met her burden to

establish a prima facie case, we need not reach the issues of whether

the agency established a legitimate, nondiscriminatory reason for its

actions or whether complainant was able to establish discrimination on

this issue by a preponderance of the evidence.

Claim 4: Harassment

Complainant also claims that she was subjected to harassment on the

basis of disability when: (a) derogatory comments were made about her

in 1994 when she had to take off from work due to medical problems;

(b) between October 1995 and February 1996, the Production Supervisor

told employees throughout the plant that he was going to �run her off�

and refused to give her the support she needed to perform her job; (c)

she was not informed in February 1996 that her FMLA leave request was

approved; rather, she discovered that it had been approved later when

she requested sick leave; (d) the agency refused to renovate her office

and provide updated office equipment and computer software in 1996; and,

(e) on January 29, 1998, she was told that she would be terminated if

she returned to work with medical restrictions.

In order to establish a claim of hostile environment harassment, a

complainant must show: (1) she is a member of a statutorily protected

class; (2) she was subjected to harassment in the form of unwelcome verbal

or physical conduct; (3) the harassment complained of was based on the

statutorily protected class; and (4) the harassment affected a term or

condition of employment and/or had the purpose or effect of unreasonably

interfering with the work environment and/or creating an intimidating,

hostile, or offensive work environment. See Soto v. U.S. Postal Service,

EEOC Appeal No. 01994396 (March 14, 2002).

To determine whether complainant has set forth an actionable claim of

harassment, the conduct at issue must be viewed in the context of the

totality of the circumstances, considering the nature and frequency

of offensive encounters and the span of time over which the encounters

occurred. See Cobb v. Department of the Treasury, Request No. 05970077

(March 13, 1997). The Supreme Court emphasized in Faragher v. City

of Boca Raton, that ��simple teasing,' offhand comments, and isolated

incidents (unless extremely serious) will not amount to discriminatory

changes in the 'terms and conditions of employment.'" 524 U.S. 775, 788

(1998). The Court noted that such conduct must be both objectively and

subjectively offensive, such that a reasonable person would find it to

be hostile or abusive, and that the victim perceived the environment

to be hostile and abusive. Id. at 787. We find that the record does

not support that the alleged incidents of harassment actually occurred

or that the conduct complained of herein was sufficiently severe or

pervasive to have altered complainant's employment and created an abusive

working environment.

CONCLUSION

After a careful review of the record, including arguments and evidence

not specifically discussed in this decision, the Commission affirms the

agency's final 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

September 29, 2004

__________________

Date

1The record is unclear as to whether

complainant is currently employed by the agency. In her affidavit,

dated September 24, 1998, complainant indicates that her psychiatrist

was �holding [her] off permanent.�

2Mania is characterized by an exaggerated feeling of well-being,

stimulation, and grandiosity in which a person can lose touch with

reality. Depression is characterized by overwhelming feelings of sadness,

anxiety, and low self-worth, which can include suicidal thoughts and

suicide attempts.

3Hypersomnia is characterized by recurrent episodes of excessive daytime

sleepiness or prolonged nighttime sleep. Persons with hypersomnia are

compelled to nap repeatedly during the day, often at inappropriate times

such as at work, during a meal, or in conversation.

4Hyperphagia is characterized by excessive ingestion of food beyond

that needed for basic energy requirements; eating may be obligatory and

disrupt normal activity.

5Anergia is lack of energy or inactivity.

6Anhedonia is reduced or complete inability to feel pleasure from

activities that usually produce happiness.

7The Production Manager was selected to that position in December

1997. From July 1996 until that time, he served as the Operations

Superintendent. For the sake of clarity, we will refer to this management

official as the Production Manager throughout the decision. Additionally,

the record does not contain the exact dates for some of complainant's

requests for a flexible work schedule.

8Complainant's additional claim that she was denied reclassification from

Clerk-Word Processor, SB-3, to Clerk-Word Processor, SB-4, was dismissed

by the agency for untimely EEO Counselor contact, and affirmed by the

Commission's Office of Federal Operations, pursuant to 29 C.F.R. �

1614.107(a)(2). See Silvestri v. Tennessee Valley Authority, EEOC

Appeal No 01986086 (July 21, 1999), req. for reconsideration denied, EEOC

Request No. 05990990 (November 5, 1999). In that decision the Commission

also found that complainant's harassment claim must be considered in its

entirety, from 1994 and beyond, rather than from 1996, because complainant

may be entitled to remedies other than backpay. See id. We note that in

response to complainant's appeal, the agency states that the Commission

upheld the agency's acceptance of the harassment issue only from 1996.

That statement is erroneous. Complainant's claim of harassment will be

considered from 1994 onward.

9An individual �has a record� of an impairment if he or she has a

history of, or has been misclassified as having, a mental or physical

impairment that substantially limits one or more major life activities.

See 29 C.F.R. � 1630.2(k). An individual is �regarded as having� an

impairment if he or she (1) has a physical or mental impairment that

does not substantially limit major life activities but is treated by an

agency as constituting such a limitation; (2) has a physical or mental

impairment that substantially limits major life activities only as a

result of the attitudes of others toward such impairment; or (3) does

not have a physical or mental impairment, but is treated by an agency

as having a substantially limiting impairment. See 29 C.F.R. � 1630.2(l).