Sheila D. Wade, Complainant,v.William J. Henderson, Postmaster General, United States Postal Service, Agency.

Equal Employment Opportunity CommissionDec 27, 1999
01992790 (E.E.O.C. Dec. 27, 1999)

01992790

12-27-1999

Sheila D. Wade, Complainant, v. William J. Henderson, Postmaster General, United States Postal Service, Agency.


Sheila D. Wade v. United States Postal Service

01992790

December 27, 1999

Sheila D. Wade, )

Complainant, )

)

v. ) Appeal No. 01992790

) Agency No. 4-J-606-0265-98

William J. Henderson, )

Postmaster General, )

United States Postal Service, )

Agency. )

______________________________)

DECISION

On February 20, 1999, the complainant filed a timely appeal with this

Commission from a final agency decision (FAD) dated January 21, 1999,

pertaining to her complaint of unlawful employment discrimination in

violation of Title VII of the Civil Rights Act of 1964, as amended, 42

U.S.C. � 2000e et seq. and � 501 of the Rehabilitation Act of 1973,

as amended, 29 U.S.C. � 791 et seq.<1> In her complaint, complainant

alleged that she was subjected to discrimination on the bases of race

(black), sex (female) and disability (physical) when effective July 18,

1997, she was removed from the U. S. Postal Service.

The record shows that the complainant initially contacted an EEO counselor

on May 12, 1998. The record further shows that the complainant filed

a grievance on her removal which an arbitrator denied on April 6, 1998.

The agency dismissed the complaint pursuant to 64 Fed. Reg. 37,644,

37,656 (1999) (to be codified and hereinafter referred to as 29 C.F.R. �

1614.107(a)(2)) , for failure to seek EEO counseling within the applicable

time limit.

In support of her appeal the complainant asserts that grievances are

totally controlled by the union not by her and that she was not aware of

EEO procedures until after the arbitration, because neither the agency,

nor the union informed her of her rights. The agency timely responded.

EEOC Regulation 29 C.F.R. � 1614.105(a)(1) requires that complaints of

discrimination should be brought to the attention of the Equal Employment

Opportunity Counselor within forty-five (45) days of the date of the

matter alleged to be discriminatory or, in the case of a personnel

action, within forty-five (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 (45)

day limitation period is triggered. See Ball v. U.S. Postal Service,

EEOC Request No. 05880247 (July 6, 1988). Thus, the limitations period

is not triggered until a complainant reasonably suspects discrimination,

but before all the facts that support a charge of discrimination have

become apparent.

29 C.F.R. � 1614.105(a)(2) further provides that the agency or the

Commission shall extend the time limits when the individual shows that

she was not notified of the time limits and was not otherwise aware of

them, that she did not know and reasonably should not have known that

the discriminatory matter or personnel action occurred, that despite due

diligence she was prevented by circumstances beyond her control from

contacting the Counselor within the time limits, or for other reasons

considered sufficient by the agency or the Commission.

It is well settled that constructive knowledge of the time limit

for contacting an EEO counselor will be imputed to a complainant

where the agency has fulfilled its statutory duty of posting notices

informing employees of their rights and obligations under Title VII.

See Thompson v. Department of the Army, EEOC Request No. 0510474

(September 12, 1991). In order to impute constructive knowledge to the

complainant, the agency may not rely on a generalized affirmation that

it posted EEO information; it must submit specific evidence that the

poster contained notice of the applicable time limits. See Pride v.

U.S. Postal Service, EEOC Request No. 05930134 (August 19, 1993).

In the instant case, the agency submitted a sworn affidavit by the Senior

EEO Complaint Processing Specialist, stating that a notice was posted at

the complainant's work site. The agency submitted a copy of the posted

notice which includes the name, telephone number and address of the EEO

counselor and the specific time limits and the necessity for contacting

an EEO counselor before filing a formal complaint. The agency record

also shows that the complainant has filed two previous EEO complaints,

one in 1995 and one in May 1998.

Given the circumstances of this case, we find that the complainant knew of

the 45-day limit for contacting an EEO counselor and yet she waited until

after her grievance was denied through arbitration to seek counseling.

Accordingly, we AFFIRM the agency's dismissal of the complainant's

complaint pursuant to 29 C.F.R. � 1614.107(a)(2) for failure to comply

with the applicable time limits.

STATEMENT OF RIGHTS - ON APPEAL

RECONSIDERATION (M1199)

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

64 Fed. Reg. 37,644, 37,659 (1999) (to be codified and hereinafter

referred to as 29 C.F.R. � 1614.405). 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 64 Fed. Reg. 37,644, 37,661 (1999)

(to be codified and hereinafter referred to as 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 (S1199)

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:

Dec. 27, 1999

____________________________

DATE Carlton M. Hadden, Acting Director

Office of Federal Operations

CERTIFICATE OF MAILING

For timeliness purposes, the Commission will presume that this decision

was received within five (5) calendar days of mailing. I certify that

the decision was mailed to complainant, complainant's representative

(if applicable), and the agency on:

_________________________ __________________________

1 On November 9, 1999, revised regulations governing the EEOC's federal

sector complaint process went into effect. These regulations apply to all

Federal sector EEO complaints pending at any stage in the administrative

process. Consequently, the Commission will apply the revised regulations

found at 64 Fed. Reg. 37,644 (1999), where applicable, in deciding the

present appeal. The regulations, as amended, may also be found at the

Commission's website at WWW.EEOC.GOV.