Virgal A. Dixon, Complainant,v.F. Whitten Peters, Secretary, Department of the Air Force, Agency.

Equal Employment Opportunity CommissionJun 15, 2000
01975030 (E.E.O.C. Jun. 15, 2000)

01975030

06-15-2000

Virgal A. Dixon, Complainant, v. F. Whitten Peters, Secretary, Department of the Air Force, Agency.


Virgal A. Dixon v. Department of the Air Force

01975030

June 15, 2000

Virgal A. Dixon, )

Complainant, )

) Appeal No. 01975030

v. ) Agency No. 970265

)

F. Whitten Peters, )

Secretary, )

Department of the Air Force, )

Agency. )

)

DECISION

Virgal A. Dixon (complainant) timely initiated an appeal from a final

agency decision (FAD) concerning her complaint of unlawful employment

discrimination on the bases of race (Black) and reprisal (prior EEO

activity), in violation of Title VII of the Civil Rights Act of 1964,

as amended, 42 U.S.C. � 2000e et seq.<1> Complainant alleges she

was discriminated against when she was counseled regarding her work

performance on May 8, 1995.<2> The appeal is accepted in accordance

with 64 Fed. Reg. 37,644, 37,659 (1999) (to be codified at 29 C.F.R. �

1614.405).

BACKGROUND

The record reveals that during the relevant time, complainant was employed

as a Secretary to the Chief, Drug Testing Division, Armstrong Laboratory

at the agency's Brooks Air Force Base, San Antonio, Texas. Believing she

was a victim of discrimination, complainant sought EEO counseling and,

subsequently, filed a formal complaint on October 25, 1995.

The agency alleged that it sent complainant the investigative file

with the appropriate appeal rights attached on February 22, 1996 and

that complainant acknowledged receipt of the investigative documents

on February 23, 1996. The record does not contain a copy of attached

appeal rights or a copy of the return receipt indicating when complainant

received notification of her right to a hearing.

There is a dispute in the record concerning the issue of complainant's

hearing request. Complainant alleged that she first sent her request by

facsimile on March 20, 1996, followed by a mailed copy. Complainant also

alleged that she spoke with the Chief EEO Counselor on or about the last

week of March and was told that the request was received, but that when

complainant called back in early April to discuss a different case, she

was told her hearing request was never received. She therefore sent a

new request, which the agency acknowledged receiving on April 15, 1996.

The record contains a copy of a hearing request dated March 20, 1996,

attached to complainant's April 5, 1996 letter explaining the situation

described above, but no evidence of when the March 20, 1996 letter was

originally sent.

The agency alleged that complainant received her notification of appeal

rights on February 23, 1996, and that she therefore had until March 25,

1996, to timely request a hearing. The agency argued that it did not

receive a hearing request until April 15, 1996, and that no one in

the EEO office recalled receiving a faxed letter from complainant on

or around March 20, 1996. The agency therefore denied complainant's

hearing request for untimeliness.

The agency went on to find that complainant failed to establish by a

preponderance of the evidence that she was subjected to race or reprisal

discrimination. The agency concluded that a legitimate nondiscriminatory

reason for counseling complainant on May 8, 1995, had been provided.

Specifically, the agency noted that complainant was counseled due to

her work performance, after she was placed on a Performance Improvement

Plan. The agency then stated that complainant presented no evidence

of pretext beyond bare assertions of discrimination and, accordingly,

issued a finding of no discrimination.

CONTENTIONS ON APPEAL

Complainant makes no further contentions on appeal. The agency,

however, provides a more complete explanation of the hearing request

dispute. The agency alleges that on April 15, 1996, the EEO Office

received a certified letter from complainant requesting a hearing.

Included with this letter was "an original 20 March 1996 letter" with

an envelope attached. The envelope had both a March 22, 1996 postmark

and an April 12, 1996 postmark. The agency then informed complainant,

on May 13, 1996, that her request for a hearing was untimely and that

a final agency decision would be issued without a hearing.

ANALYSIS AND FINDINGS

Where, as here, there is an issue of timeliness, the Commission

has consistently held that the agency bears the burden of obtaining

sufficient information to support a reasoned determination. See Williams

v. Department of Defense, EEOC Request No. 05920506 (August 25, 1992);

Gens v. Department of Defense, EEOC Request No. 05910837 (January 31,

1992). After a thorough review of the record, we find that the agency

has not met this burden.

Although noting that complainant received the investigative file and

appeal rights on February 23, 1996, the agency provided no evidence to

establish this claim. Moreover, complainant contended that she faxed and

mailed a hearing request on or around March 20, 1996. While complainant

has no proof of this allegation, the agency notes on appeal that when

it received a hearing request on April 15, 1996, the mailing included

a request dated March 20, 1996 and an envelope with two postmarks, one

of which was March 22, 1996. The agency did not provide this envelope

to the Commission. The agency has therefore failed to provide three

key documents; namely, a copy of the notification of appeal rights,

a copy of the certified receipt indicating when complainant received

this notification, and a copy of the March 20, 1996 request with the

attached postmarked envelope to which the agency refers on appeal.

Accordingly, we find that the agency failed to meet its burden of

obtaining sufficient information to support a reasoned determination

as to timeliness. As such, it is the decision of this Commission to

VACATE the agency's final decision and REMAND this matter for further

processing in accordance with this decision and the ORDER set forth below.

We note that complainant's complaint lists color, sex, age, and

disability, in addition to race and reprisal, as bases for her allegations

of discrimination. Although complainant's affidavit makes clear that she

did not intend pursue a color-based discrimination claim, the record is

unclear as to whether complainant intended to pursue the other bases

for discrimination that she initially raised. We advise complainant

that she may, on remand, inform the EEOC administrative judge that she

wishes to include sex, age and/or disability as bases for her complaint.

See Dragos v. United States Postal Service, EEOC Request No. 05940563

(January 19, 1995).

Furthermore, it also appears from her complaint that complainant intended

to allege that she was denied a reasonable accommodation when the agency

placed her on a performance improvement plan, culminating in the May 8,

1995 counseling session, instead of transferring her to a less demanding

position. If this is the case, we advise complainant to inform the EEOC

administrative judge that she wishes to amend her complaint to include

this reasonable accommodation allegation. See 29 C.F.R. � 1614.106(d).

ORDER

The complaint is remanded to the Hearings Unit of the San Antonio

District Office for scheduling of a hearing in an expeditious manner.

The agency is directed to submit a copy of the complaint file to the

San Antonio District Office Hearings Unit within fifteen (15) calendar

days of the date this decision becomes final. The agency shall provide

written notification to the Compliance Officer at the address set forth

below that the complaint file has been transmitted to the Hearings

Unit. Thereafter, the Administrative Judge shall issue a decision on the

complaint in accordance with 29 C.F.R. � 1614.109 and the agency shall

issue a final action in accordance with 29 C.F.R. � 1614.110.

IMPLEMENTATION OF THE COMMISSION'S DECISION (K1199)

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 64

Fed. Reg. 37,644, 37,659-60 (1999) (to be codified and hereinafter

referred to as 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)(Supp. V 1993). If the complainant files a civil action, the

administrative processing of the complaint, including any petition for

enforcement, will be terminated. See 64 Fed. Reg. 37,644, 37,659 (1999)

(to be codified and hereinafter referred to as 29 C.F.R. � 1614.409).

STATEMENT OF RIGHTS - ON APPEAL

RECONSIDERATION (M0300)

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); 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 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).

COMPLAINANTS' RIGHT TO FILE A CIVIL ACTION (R0400)

This is a decision requiring the agency to continue its administrative

processing of your complaint. However, if you wish to file a civil

action, you have the right to file such action in an appropriate United

States District Court WITHIN NINETY (90) CALENDAR DAYS from the date

that you receive this decision. 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 filed your appeal with the

Commission. 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. 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:

June 15, 2000

Date Carlton M. Hadden, Acting Director

Office of Federal Operations

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.

2 While complainant appears to have also alleged that she was removed

from the agency due to discrimination, a review of Commission records

establishes that this allegation was the subject of Dixon v. Department

of the Air Force, EEOC Petition No. 03970073 (April 23, 1997).

In that case, the Commission denied consideration of complainant's

petition for review of the MSPB's determination that her removal was

not discriminatory. The termination allegation has therefore already

been decided and will not be addressed in the current decision. See 64

Fed. Reg. 37, 644, 37,656 (1999) (to be codified and hereinafter referred

to as 29 C.F.R. 1614.107(a)(1)).