Tina Lonnie Complainant,v.Gale A. Norton, Secretary, Department of the Interior, Agency.

Equal Employment Opportunity CommissionNov 22, 2005
01A31700 (E.E.O.C. Nov. 22, 2005)

01A31700

11-22-2005

Tina Lonnie Complainant, v. Gale A. Norton, Secretary, Department of the Interior, Agency.


Tina Lonnie

Complainant,

v.

Gale A. Norton,

Secretary,

Department of the Interior,

Agency.

Appeal No. 01A31700

Hearing Nos. 370-A1-X2419

370-A1-X2531

370-A2-X2003

Agency Nos. FNP-99-089R

FNP-2000-006

FNP-2000-107

DECISION

JURISDICTION

On January 14, 2003, complainant filed an appeal from the agency's December

16, 2002 final order concerning her equal employment opportunity (EEO)

complaint alleging employment discrimination in violation of Title VII of

the Civil Rights Act of 1964 (Title VII), as amended, 42 U.S.C. � 2000e et

seq. The appeal is deemed timely and is accepted pursuant to 29 C.F.R. �

1614.405(a).

BACKGROUND

At the time of events giving rise to this complaint, complainant worked as

a Laborer, WG-2, in the Buildings Custodial Department, at the agency's

National Park Service in Yosemite National Park. Complainant filed three

EEO complaints alleging discrimination on the bases of race (African-

American), sex (female), and reprisal for prior protected EEO activity

under Title VII of the Civil Rights Act of 1964. The first complaint was

filed on June 10, 1999, alleging discrimination when: (1) her requests for

training opportunities to enhance the development of her career were

denied; (2) she was not selected for a promotion to the position of

Maintenance Worker, WG-4749-05, advertised under vacancy announcement

number YOSE-97-99; and (3) she was subjected to harassment by her co-

workers (CW1 and CW2). In complaint #2, filed October 18, 1999,

complainant alleged that she was discriminated against on the bases of

race, sex, and reprisal when (4) she was not selected for a 120-day detail

in the Building and Grounds Department of Yosemite National Park. On

September 28, 2000, complainant filed her third formal complaint alleging

discrimination on the same bases when: (5) she was not selected for the

position of Laborer, WG-3502-03, advertised under vacancy announcement No.

98-62.

Each complaint was investigated separately. At the conclusion of the

investigations, complainant was provided with a copy of the reports of

investigation and notice of her right to request a hearing before an EEOC

Administrative Judge (AJ). Complainant timely requested a hearing on each

of the three complaints. The AJ consolidated the three complaints.

On April 5, 2002, the AJ issued his notice of intent to issue a decision

without a hearing. Complainant's attorney filed a response to the AJ's

notice on April 25, 2002. Complainant's response asserted that she made

out a prima facie case of harassment based on race. Therefore,

complainant's counsel argued, the matter is one where summary judgment is

not appropriate. After a review of the investigative files and

complainant's submissions, the AJ issued a decision without a hearing on

July 1, 2002.

AJ DECISION

The AJ found that there were no material facts in dispute and the evidence

of record failed to establish complainant was discriminated against as

alleged.

Specifically, as to claim (1), the AJ noted that complainant did not

request specific training. Further, the AJ found that the record included

several training opportunities complainant received including training on

the 4X4 Mule, forklift safety and operation, and basic electrical.

Therefore, the AJ determined that complainant was not denied training

opportunities.

In claim (2), the AJ found that the agency provided legitimate,

nondiscriminatory reasons for its actions. In claim (2), complainant

alleged discrimination when she was not selected for the WG-5 Maintenance

Worker position. The AJ noted that S1 chose Selectee1 (white male) because

he had an extensive background in repair and maintenance work while

complainant lacked such experience. S1 then also chose Selectee2 (white

male) for another Maintenance Worker position based on his maintenance

experience. The AJ then turned to complainant to establish that the

agency's reasons were pretext and found that complainant failed to show

that she had the similar job-related experience as Selectee1 and 2.

Therefore, the AJ concluded that complainant had not established that the

agency's reasons were pretext for discrimination.

As to claim (4), the AJ found that the agency provided legitimate,

nondiscriminatory reasons for the detail. Complainant's supervisor (S1)

averred that he had a temporary promotional detail available, and three

equally qualified employees for the detail--complainant and two of her co-

workers (CW3 and CW4, both white males). S1 thought it would be fair to

give all three of them part of the detail by splitting the detail into

three ways, so each employee would get an opportunity to fill two forty-day

temporary details, one in the Building and Grounds Department and the other

in the Campground Maintenance Department. S1 chose names out of a hat to

decide the order of the details. CW3 was the first name out of the hat for

the Building and Grounds detail. CW4 was second and assigned to the

Campground Maintenance detail. Complainant's name was third and she was to

rotate into the Campground Maintenance detail after the first forty-day

detail period. However, the AJ found that at some later point, the Chief

of Maintenance offered complainant the whole 120-day detail and she

declined the offer. Because complainant declined the offer, S1 was told to

take complainant's name out of rotation. Based on the record, the AJ found

that S1 selected complainant for a forty-day detail and she was even

offered the full 120-day detail. Therefore, the AJ concluded that

complainant was not denied the detail as alleged.

As to claim (5), the AJ noted that complainant and two co-workers were

referred on the certificate for the WG-3 Laborer position. The AJ found

that the agency decided not to hire for the WG-3 Laborer position due to

lack of funding. While the management official who made the decision not

to fill the decision was aware of complainant's prior EEO activity

(Complaints 1 and 2 previously described), he denied that, rather than

funding problems, was the reason for his decision. Complainant asserted

that the agency did not fill the position because it did not want

complainant to get the job. Further, complainant claimed that she was

coerced into a sexual relationship with one of her supervisors (S3), who

participated in the selection. She asserted that she was not selected

because she ended the relationship with the S3. The AJ, however, noted

that complainant acknowledged that the relationship was consensual and that

it continued until February 2000, well after the agency decided not to fill

the WG-3 Laborer position in 1998. Accordingly, the AJ determined that

complainant failed to show pretext as to the position at issue in claim

(5).

The AJ also determined that complainant failed to establish her claim of

unlawful harassment. In claim (3), complainant asserted that she was

subjected to discriminatory harassment by several white male coworkers and

that management failed to do anything about it. The AJ found that

complainant did not assert that any of the alleged acts by these coworkers

were directed at her and also did not allege that they made any racially

derogatory remarks about her. Therefore, the AJ concluded that complainant

failed to establish her claim of harassment.

FINAL AGENCY ACTION

The agency subsequently issued a final order adopting the AJ's finding that

complainant failed to prove that she was subjected to discrimination as

alleged. Complainant filed this appeal without comment. In response to

the appeal, the agency argued that the AJ correctly concluded that there

were no material facts in dispute and that complainant failed to establish

that she was discriminated against as alleged. As such, the agency

requested that the Commission affirm its final action.

STANDARD OF REVIEW

In rendering this appellate decision we must scrutinize the AJ's legal and

factual conclusions, and the agency's final order adopting them, de novo.

See 29 C.F.R. � 1614.405(a) (stating that a "decision on an appeal from an

agency's final action shall be based on a de novo review . . ."); see also

EEOC Management Directive 110, Chapter 9, � VI.B. (November 9, 1999)

(providing that an administrative judge's "decision to issue a decision

without a hearing pursuant to [29 C.F.R. � 1614.109(g)] will be reviewed de

novo"). This essentially means that we should look at this case with fresh

eyes. In other words, we are free to accept (if accurate) or reject (if

erroneous) the AJ's, and agency's, factual conclusions and legal analysis -

including on the ultimate fact of whether intentional discrimination

occurred, and on the legal issue of whether any federal employment

discrimination statute was violated. See id. at Chapter 9, � VI.A.

(explaining that the de novo standard of review "requires that the

Commission examine the record without regard to the factual and legal

determinations of the previous decision maker," and that EEOC "review the

documents, statements, and testimony of record, including any timely and

relevant submissions of the parties, and . . . issue its decision based on

the Commission's own assessment of the record and its interpretation of the

law").

ANALYSIS AND FINDINGS

We must first determine whether it was appropriate for the AJ to have

issued a decision without a hearing on this record. The Commission's

regulations allow an AJ to issue a decision without a hearing when he or

she finds that there is no genuine issue of material fact. 29 C.F.R. �

1614.109(g). This regulation is patterned after the summary judgment

procedure set forth in Rule 56 of the Federal Rules of Civil Procedure.

The U.S. Supreme Court has held that summary judgment is appropriate where

a court determines that, given the substantive legal and evidentiary

standards that apply to the case, there exists no genuine issue of material

fact. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986). In

ruling on a motion for summary judgment, a court's function is not to weigh

the evidence but rather to determine whether there are genuine issues for

trial. Id. at 249. The evidence of the non-moving party must be believed

at the summary judgment stage and all justifiable inferences must be drawn

in the non-moving party's favor. Id. at 255. An issue of fact is

"genuine" if the evidence is such that a reasonable fact finder could find

in favor of the non-moving party. Celotex v. Catrett, 477 U.S. 317, 322-23

(1986); Oliver v. Digital Equip. Corp., 846 F.2d 103, 105 (1st Cir. 1988).

A fact is "material" if it has the potential to affect the outcome of the

case.

If a case can only be resolved by weighing conflicting evidence, issuing a

decision without holding a hearing is not appropriate. In the context of

an administrative proceeding, an AJ may properly consider issuing a

decision without holding a hearing only upon a determination that the

record has been adequately developed for summary disposition. See Petty v.

Department of Defense, EEOC Appeal No. 01A24206 (July 11, 2003). Finally,

an AJ should not rule in favor of one party without holding a hearing

unless he or she ensures that the party opposing the ruling is given (1)

ample notice of the proposal to issue a decision without a hearing, (2) a

comprehensive statement of the allegedly undisputed material facts, (3) the

opportunity to respond to such a statement, and (4) the chance to engage in

discovery before responding, if necessary. According to the Supreme Court,

Rule 56 itself precludes summary judgment "where the [party opposing

summary judgment] has not had the opportunity to discover information that

is essential to his opposition." Anderson, 477 U.S. at 250. In the

hearing context, this means that the administrative judge must enable the

parties to engage in the amount of discovery necessary to properly respond

to any motion for a decision without a hearing. Cf. 29 C.F.R. �

1614.109(g)(2) (suggesting that an administrative judge could order

discovery, if necessary, after receiving an opposition to a motion for a

decision without a hearing).

Upon review, we find that the record was fully developed by thorough

investigations. In particular, we note that the investigators conducted

detailed depositions of complainant, management and other witnesses. We

note that the witnesses appear to essentially agree on the facts involved

in the complaints at hand. Additionally, complainant failed to identify

any material facts in dispute at the hearing or on appeal. Therefore, we

determine that there are no material facts in dispute. Accordingly, we

conclude that summary judgment was appropriate.

Disparate Treatment

A claim of disparate treatment based on indirect evidence is examined under

the three-part analysis first enunciated in McDonnell Douglas Corporation

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. McDonnell Douglas, 411 U.S. at 802; Furnco Construction Corp. v.

Waters, 438 U.S. 567 (1978). The burden then shifts to the agency to

articulate a legitimate, nondiscriminatory reason for its actions. Texas

Department of Community Affairs v. Burdine, 450 U.S. 248, 253 (1981). Once

the agency has met its burden, the complainant bears the ultimate

responsibility to persuade the fact finder by a preponderance of the

evidence that the agency acted on the basis of a prohibited reason. St.

Mary's Honor Center v. Hicks, 509 U.S. 502 (1993).

The elements of the prima facie case are determined by the individual

circumstances of each case and the bases of discrimination alleged; but

regardless of the specific action at issue, complainant may establish a

prima facie case by demonstrating: 1) that she is a member of a protected

group; 2) that she is similarly situated to employees outside of her

protected group; 3) and that she was treated differently than those

employees. Potter v. Goodwill Industries of Cleveland, Inc., 518 F.2d 864,

865 (6th Cir. 1975). In a reprisal claim, and in accordance with the

burdens set forth in McDonnell Douglas, Hochstadt v. Worcester Foundation

for Experimental Biology, 425 F. Supp. 318, 324 (D. Mass.), aff'd, 545 F.2d

222 (1st Cir. 1976), and Coffman v. Department of Veteran Affairs, EEOC

Request No. 05960473 (November 20, 1997), a complainant may establish a

prima facie case of reprisal by showing that: (1) she engaged in a

protected activity; (2) the agency was aware of the protected activity; (3)

subsequently, she was subjected to adverse treatment by the agency; and (4)

a nexus exists between the protected activity and the adverse treatment.

Whitmire v. Department of the Air Force, EEOC Appeal No. 01A00340

(September 25, 2000).

Claims (1), (2), and (5)

This established order of analysis in discrimination cases, in which the

first step normally consists of determining the existence of a prima facie

case, need not be followed in all cases. Where the agency has articulated

a legitimate, nondiscriminatory reason for the personnel action at issue,

the factual inquiry can proceed directly to the third step of the McDonnell

Douglas analysis, the ultimate issue of whether complainant has shown by a

preponderance of the evidence that the agency's actions were motivated by

discrimination. U.S. Postal Service Bd. of Governors v. Aikens, 460 U.S.

711, 713-714 (1983); Hernandez v. Department of Transportation, EEOC

Request No. 05900159 (June 28, 1990); Peterson v. Department of Health and

Human Services, EEOC Request No. 05900467 (June 8, 1990); Washington v.

Department of the Navy, EEOC Petition No. 03900056 (May 31, 1990).

Upon review, we find that the AJ correctly determined that complainant did

not show that she was discriminated against as alleged in claims (1). As

to claims (2) and (5), the AJ properly found that the agency articulated

legitimate, nondiscriminatory reasons and that complainant failed to

establish that those reasons were pretext.

Claim (4)

In claim (4), complainant is an African-American female who filed an EEO

complaint against S1. CW3 and CW4 (both white males who have not

participated in EEO activity) were selected by S1 for the details at issue.

Complainant was not provided with the detail. Therefore, we find that

complainant has established a prima facie case of discrimination based on

her race, sex and her prior EEO activity.

The burden shifts to the agency to articulate a legitimate,

nondiscriminatory reason for its action. S1 averred that he selected

complainant, CW3 and CW4 for two details. He asserted that he placed the

names in a hat and that CW3 and CW4 were selected first out of the hat to

serve on the forty-day details. Complainant's name was third and she was

to rotate into the Campground Maintenance detail after the first forty-day

detail period. However, the AJ found that at some later point, the Chief

of Maintenance offered complainant the whole 120-day detail and she

declined the offer. Because complainant declined the offer, S1 was told to

take complainant's name out of rotation and she never served in either

details to the Building and Grounds Department or to the Campground

Maintenance Department.

We note that, in concluding no discrimination occurred, the AJ credited as

legitimate the agency's rationale for taking complainant out of the

rotation for the promotional detail-that complainant was offered the full

120-day detail and that she rejected it. The AJ, however, appears not to

have recognized that this "offer" was made during settlement discussions

between complainant and agency regarding a prior EEO complaint. See Report

of Counseling, Complaint FNP-00-006. In exchange for withdrawing an EEO

complaint, the agency offered to provide complainant with the whole 120-day

detail. Complainant refused the offer in order to pursue her EEO

complaint. The evidence is clear that she was then removed from her turn

at the rotational details, that she had already been granted, because of

her refusal to accept the settlement offer. EEOC Management Directive (MD)-

110, Chapter 12, is clear that settlements of EEO disputes must be

voluntary in nature, with the complainant free to choose not to settle and

instead pursue processing of his or her EEO complaint. Moreover,

"[s]ettlement negotiations, including any statements or proposals, are to

be treated as confidential and privileged to facilitate a candid

interchange to settle disputes informally." Harris v. Department of the

Navy, EEOC Request No. 05941002 (March 23, 1995). For these reasons, we

find that the agency's decision to pull complainant out of the rotation for

the promotional details was unlawful retaliation for complainant's decision

to exercise her protected right in the EEO complaint process to pursue her

previously filed EEO complaints rather than settling with the agency.

Harassment

It is well-settled that harassment based on an individual's sex and race,

or in retaliation for engaging is protected EEO activity, is actionable.

See Meritor Savings Bank FSB v. Vinson, 477 U.S. 57 (1986). In order to

establish a claim of harassment under those bases, the complainant must

show that: (1) she belongs to the statutorily protected classes and/or

engaged in prior EEO activity; (2) she was subjected to unwelcome conduct

related to her membership in those classes and her prior EEO activity; (3)

the harassment complained of was based on sex, race and/or prior EEO

activity; (4) the harassment had the purpose or effect of unreasonably

interfering with her work performance and/or creating an intimidating,

hostile, or offensive work environment; and (5) there is a basis for

imputing liability to the employer. See Henson v. City of Dundee, 682 F.2d

897 (11th Cir. 1982). The harasser's conduct should be evaluated from the

objective viewpoint of a reasonable person in the victim's circumstances.

Enforcement Guidance on Harris v. Forklift Systems Inc., EEOC Notice No.

915.002 (March 8, 1994).

Claim (3)

In claim (3), complainant alleged that she was subjected to a hostile work

environment when she was harassed on the basis of her race, sex and her

participation in prior EEO activity. Complainant noted that she was one of

the few African Americans working at the park and the only one in her

division. The record also establishes that due to the geographic isolation

of the park, many employees lived in close proximity to their work and each

other, and encountered each other both at work and when not working with

some frequency. Complainant stated that most other African American

employees who have tried "to work here and live here and make this their

community.have all left.I'm the only one that has stuck it out."

Deposition of June 11, 2001, pg.12.

Complainant asserted in August 1997 she was placed in a permanent position

at the park, where previously she had held a temporary job. She said that

almost immediately one of her coworkers (CW1, a white male) told her that

"the only reason you got a permanent job. is because [you are] black" and

then spat at her feet. Id., pg. 17. She said CW1 later repeatedly made

similar statements and continued spitting at her feet on a number of

different occasions for a period of "months and months," which she found

very offensive. Id., pg. 19. Complainant said she finally reported

CW1's conduct to her supervisor, S1, who sent her to a "mediation meeting"

with CW1, held with the agency's EEO counselor. After the mediation

session, complainant stated that CW1 stopped making the offensive

statements, but gave her a lot of "dirty looks," as well as complaining

frequently to management about her work.

Complainant's supervisor, S1, confirmed that she was the only African

American employee he supervised. He also said that he was aware that

complainant and CW1 had a long-standing hostile relationship, but

characterized it as a personality conflict. He indicated that he decided

to set up the mediation session for the two of them with the facility's EEO

counselor. He noted that during the lunch break of the mediation session,

an anonymous report was received that complainant had been seen using an

illegal substance while driving her park-issued scooter. He said the park

police investigated immediately and determined that the allegation was

untrue. He indicated that this incident "kind of ruined" the mediation.

Complainant's second-level supervisor, S2, confirmed that he was also aware

of a bad relationship between complainant and CW1 and counseled them to put

their differences aside, but he denied knowing there was a racial element

to their disputes. However, the EEO Counselor's report indicated that S2

told the counselor that CW1 was told by management that "his behavior was

not appropriate and would not be tolerated."

With regard to CW2's conduct, complainant asserted that he said that if she

got promoted before he did he was going to make "a big stink about it."

Id., pg. 24. Complainant also said that one day in front of the shop, CW2

(white, male) said he was going to rape the wife of the second-level

supervisor, S2. Complainant reported this statement to management and an

investigation of the incident was started. Complainant was detailed out of

the park to Santa Barbara for about a month during the investigation. When

she returned, she learned that S2 had been permanently transferred to

another park, but she was returned to work with CW2. She noted that in

addition to encountering him at work, CW2 also lived about five houses away

from her. Complainant asserted she was fearful for her own safety working

with CW2 and had been told by some friends that they heard him say that he

hoped she was dead. Complainant said she told management she was afraid of

CW2, but they did nothing about it. Complainant asserted that S2 (who was

white) was protected by the agency from CW2, while she was not.

S1 confirmed that complainant was briefly detailed to Santa Barbara because

of concerns that CW2 would retaliate against her for reporting his alleged

threat against S2's wife. He said CW2 was suspended for 30 days following

the investigation of this incident and he was aware that complainant was

afraid of CW2, and said he tried to keep them separated and to counsel CW2

frequently. S2 confirmed that he and his family transferred to another

park shortly after this incident, in part to get away from CW2. He also

confirmed complainant's assertion that CW2 was very angry at her, and

described him as very "imposing." He said that park law enforcement

continued to monitor CW2's actions on a regular basis.

Upon review, we find that the AJ correctly concluded that complainant

failed to show that the alleged incidents of harassment were due to her sex

and/or prior EEO activity. However, based on a review of the record, the

Commission disagrees with the AJ's conclusion that complainant did not

assert that any of the alleged acts by her coworkers were directed at her

and also did not allege that they made any racially derogatory remarks

about her. We find that the evidence of record showed that CW1's actions

were based, at least in part, on complainant's race. CW1 regularly

commented, for a period of "months and months," that the reason complainant

was hired by the agency was her race and spat in complainant's direction.

We note that complainant was the only person of her race employed at the

facility. There is also evidence that he acted in a generally hostile

manner towards her over a long period of time. Management was fully aware

of the hostile relationship between them, and sent them to a mediation

session with an EEO counselor to learn to "get along." These efforts,

however, were established to be unsuccessful.

The agency is liable for harassment by a co-worker if it knew of the

harassment and failed to take appropriate corrective action. Policy

Guidance on Current Issues of Sexual Harassment, EEOC Notice No. N-915-050

(March 19, 1990); Owens v. Department of Transportation, EEOC Request No.

05940824 (September 5, 1996). Here, complainant informed her supervisors

of the harassment. Complainant stated and management officials confirmed

that she raised the issue of CW1 behavior. However, despite management

counseling of CW1 about his behavior, the hostility continued, a fact of

which the record indicates management was aware. Therefore, upon review, we

find that despite knowledge of the harassment, management did not take

prompt and appropriate corrective action. As such, we find that the agency

cannot make out an affirmative defense to complainant's claim of a

discriminatory hostile work environment. See Burlington Industries, Inc.,

v. Ellerth, 524 U.S. 742 , 118 S.Ct. 2257, 2270 (1998); Faragher v. City of

Boca Raton, 524 U.S. 775, 118 S.Ct. 2275, 2292-93 (1998); EEOC Enforcement

Guidance: Vicarious Liability for Unlawful Harassment by Supervisors, EEOC

Notice No. 915.002 (June 18, 1999) at 12. Accordingly, we determine that

complainant has shown that she was subjected to a hostile work environment

based on her race.

With regard to the actions of CW2, we find that while complainant was

undoubtedly subjected to hostility by his actions, and reasonably feared

CW2, there is insufficient evidence to establish that CW2's actions were

motivated by racial discrimination rather than his anger at complainant

because she reported his threats directed at S2's wife. However, the

record does establish that agency management treated S2, who was white, and

complainant, who was African American, differently with regard to CW2. The

record establishes that S2 was permanently transferred to another park, at

least in part, to protect him from potential danger from CW2. Complainant,

on the other hand, was briefly sent to another facility, but then returned

to Yosemite where she continued to have to work with CW2. Complainant

asserted she was fearful for her own safety working with CW2 and had been

told by some friends that they heard him say that hoped she was dead.

Complainant said she told management she was afraid of CW2, but they did

nothing about it. We find that complainant has established a prima facie

case of disparate treatment by agency management based on race in this

matter, which the agency has failed to rebut with an articulation of a

legitimate, nondiscriminatory reason for the different treatment.

Therefore, we further find complainant has established an inferential case

of race discrimination with regard to agency management's lack of

appropriate response to her legitimate fears about having to continue to

work with CW2.

CONCLUSION

After a review of the record in its entirety, it is the decision of the

Commission to affirm in part and reverse in part the agency's final order.

The agency is ordered to take the corrective action listed below.

ORDER (C0900)

The agency is ordered to take the following remedial action:

1. The agency shall provide complainant with forty-day detail opportunities

to both the Building and Grounds and the Campground Maintenance

Departments and provide her with back pay for any differences in salary

she would have incurred had she originally received these details.

2. The agency is directed to conduct training for the agency employees who

have been found to have created a hostile work environment as well as for

the management officials who failed to exercise reasonable care to

prevent the hostile work environment and who discriminated against

complainant. The agency shall address these employees' responsibilities

with respect to eliminating harassment in the workplace.

3. The agency shall consider taking disciplinary action against the

employees identified as being responsible for the discrimination and

unlawful harassment perpetrated against complainant. The agency shall

report its decision. If the agency decides to take disciplinary action,

it shall identify the action taken. If the agency decides not to take

disciplinary action, it shall set forth the reason(s) for its decision

not to impose discipline.

4. The agency shall ensure that CW1 and CW2 are separated from complainant.

5. Within fifteen (15) calendar days of the date this decision becomes

final, the agency shall give complainant a notice of her right to submit

objective evidence (pursuant to the guidance given in Carle v. Department

of the Navy, EEOC Appeal No. 01922369 (January 5, 1993)) in support of

her claim for compensatory damages within forty-five (45) calendar days

of the date complainant receives the agency's notice. The agency shall

complete the investigation on the claim for compensatory damages within

forty-five (45) calendar days of the date the agency receives

complainant's claim for compensatory damages. Thereafter, the agency

shall process the claim in accordance with 29 C.F.R. � 1614.110.

6. The agency is further directed to submit a report of compliance, as

provided in the statement entitled "Implementation of the Commission's

Decision." The report shall include supporting documentation verifying

that the corrective action has been implemented.

7. The agency shall complete all of the above actions within 120 calendar

days from the date on which the decision becomes final.

POSTING ORDER (G0900)

The agency is ordered to post at its facility in Yosemite National Park,

copies of the attached notice. Copies of the notice, after being signed by

the agency's duly authorized representative, shall be posted by the agency

within thirty (30) calendar days of the date this decision becomes final,

and shall remain posted for sixty (60) consecutive days, in conspicuous

places, including all places where notices to employees are customarily

posted. The agency shall take reasonable steps to ensure that said notices

are not altered, defaced, or covered by any other material. The original

signed notice is to be submitted to the Compliance Officer at the address

cited in the paragraph entitled "Implementation of the Commission's

Decision," within ten (10) calendar days of the expiration of the posting

period.

ATTORNEY'S FEES (H0900)

If complainant has been represented by an attorney (as defined by 29 C.F.R.

� 1614.501(e)(1)(iii)), he/she is entitled to an award of reasonable

attorney's fees incurred in the processing of the complaint. 29 C.F.R.

� 1614.501(e). The award of attorney's fees shall be paid by the agency.

The attorney shall submit a verified statement of fees to the agency -- not

to the Equal Employment Opportunity Commission, Office of Federal

Operations -- within thirty (30) calendar days of this decision becoming

final. The agency shall then process the claim for attorney's fees in

accordance with 29 C.F.R. � 1614.501.

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 (T0900)

This decision affirms the agency's final decision/action in part, but it

also requires the agency to continue its administrative processing of a

portion of your complaint. 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 on both that portion of your

complaint which the Commission has affirmed and that portion of the

complaint which has been remanded for continued administrative processing.

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 your appeal with the Commission, until such time as the agency

issues its final decision on your complaint. 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

November 22, 2005

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