EEOC Appeal 2020001096

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Office of Federal Operations
P.O. Box 77960
Washington, DC 20013
Garret W.,1
Complainant,
v.
Louis DeJoy,
Postmaster General,
United States Postal Service
(Southern Area),
Agency.
Appeal No. 2020001096
Hearing No. 450-2018-00143X
Agency No. 4G-752-0228-17
DECISION
On November 24, 2019, Complainant filed an appeal with the Equal Employment Opportunity
Commission (EEOC or Commission), pursuant to 29 C.F.R. § 1614.403(a), from the Agency’s
October 31, 2019, final order concerning his 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. For the following reasons, the Commission AFFIRMS
the Agency’s final order.
ISSUES PRESENTED
Whether the EEOC Administrative Judge (AJ) correctly found that the Agency did not
discriminate against Complainant or subject him to a retaliatory harassment/hostile work
environment (prior and current EEO activity) when Complainant was issued discipline, denied
route assistance, yelled at and spoken to in an unprofessional manner, and his start date was
changed.
1 This case has been randomly assigned a pseudonym which will replace Complainant’s name
when the decision is published to non-parties and the Commission’s website.

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BACKGROUND
At the time of events giving rise to this complaint, Complainant worked as a City Letter Carrier,
PS-01 at the Agency’s Prestonwood Station in Dallas, Texas. On August 18, 2017, Complainant
filed an EEO complaint alleging that the Agency discriminated against him on the basis of reprisal
for prior protected EEO activity under Title VII of the Civil Rights Act of 1964 when:2
1. 	on June 26, 2017, Complainant was given an Investigative Interview and subsequently, on
June 27, 2017, Complainant was issued a Letter of Warning (LOW) for Unacceptable
Conduct/Failure to be in Regular Attendance;
2. 	on August 5, 2017, and September 15, 2017, Complainant’s request for route assistance on
Postal Service (PS) Form 3996 was denied;
3. 	on September 13, 2017, Complainant was yelled at and spoken to in an unprofessional
manner; and
4. 	on September 16, 2017, Complainant’s start time was changed.
Complainant indicated that his protected EEO activity involved a 2016 complaint and the instant
filing. Complainant stated that the Supervisor, Customer Service (S1) was not named in his prior
EEO filing but became aware of it through the Station Manager (S2). S1 affirmed awareness of
Complainant’s prior EEO activity. He also affirmed that he became aware of the instant complaint
when he received an affidavit by email. S2 denied awareness of Complainant’s prior EEO activity.
She also affirmed that she became aware of the instant complaint when she was contacted by the
investigator.
At the conclusion of the investigation, the Agency provided Complainant with a copy of the report
of investigation and notice of his right to request a hearing before an AJ. 	Complainant timely
requested a hearing. When Complainant did not object, the AJ assigned to the case granted the
Agency’s September 6, 2019, motion for a decision without a hearing and issued a decision without
a hearing on October 16, 2019. The Agency subsequently issued a final order adopting the AJ’s
finding that Complainant failed to prove that the Agency subjected him to discrimination as
alleged.
Following are the undisputed facts:
Regarding Claim 1, Complainant alleged that S2 gave him a Pre-Disciplinary Investigative
Interview and issued him a LOW for Unacceptable Conduct/Failure to be Regular in Attendance.
2 The Agency noted that one of Complainant’s claims was dismissed during the investigation. We
note that the dismissed claim was not stated in the record. We also note that in this decision, the
accepted claims have been renumbered for clarity.

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Complainant stated that he explained to S2 that he had bouts of illness when she asked him to
explain his absences. Complainant stated that the Postal Service provides sick benefits which are
to be used for illnesses. Complainant however did not state whether he had requested leave for his
absences.
Complainant explained that the LOW was reduced to an Official Discussion. He contended that
his prior EEO activity was a factor because S2 went out of her way to conduct his Pre-Disciplinary
Interview and to issue him a LOW, a task which, Complainant asserted, should have been
delegated to the floor supervisors.
S2 affirmed Complainant’s allegations, explaining that Complainant was made aware of his poor
attendance through quarterly reviews and prior letters. S2 denied that Complainant's prior EEO
activity was a factor, indicating that her actions were consistent with applicable sections of the
Employee and Labor Relations Manual (ELM).
Included in the record is ELM § 511.42 which provides that employees are expected to maintain
their regular schedule and make every effort to avoid unscheduled absences. The ELM at § 511.43
also provides that an employee who fails to be regular in attendance may receive disciplinary
action.
Regarding Claim 2, Complainant alleged that S1 denied Complainant’s request for route assistance
on Complainant’s PS Form 3996. 	Complainant contended that the main reason for his route
assistance being denied was his involvement in prior EEO Activity. 	Complainant asserted his
belief that S2 instructed supervisors to deny any and all assistance in order to impose pressure and
stress; and to deprive Complainant of respect and dignity “within the scope of agency
management.”
Complainant stated that he learned through the Delivery Operations Information Systems (DOIS)
that mail volume did not warrant his request for assistance on August 5, 2017, or on September
15, 2017. Complainant stated that his prior EEO activity was a factor in the assistance denial at
issue, asserting that when S2 gave a decree to supervisors that all assistance requested by
Complainant 	be denied, 	it 	was 	because of 	Complainant’s 	involvement 	in 	EEO 	activity.
Complainant asserted that management is in violation of the Behavior and Personal Habits and
discrimination sections of the ELM.
Without 	explaining 	the 	link 	between 	Complainant’s 	requested 	assistance 	and 	overtime,
Complainant identified a coworker (C1) as a comparator who was on the overtime list but was not
provided overtime equally as other carriers. Complainant stated that he is unaware if C1 engaged
in EEO activity. Complainant also listed C2 as a comparator whose request for route assistance
on PS Form 3996 was not denied. Complainant stated that C2 is a City Carrier who works for S1.
Complainant asserted that he was not privy to C2’s EEO activity history.
S1 explained that it was management's decision to deny Complainant's request for route assistance
because the mail volume did not warrant the assistance on the dates at issue.

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S1 contended that Complainant was instructed to manage the mail within Complainant’s scheduled
time; and that Complainant confirmed that the request for route assistance did not warrant
overtime. S1 stated that employees are not guaranteed overtime or assistance to be given on their
route on any given day. S1 asserted that it is management's right to manage the mail volume.
S1 asserted that Complainant's prior EEO activity was not a factor in S1’s action which, S1
indicated, was consistent with applicable sections of the ELM and Employee Handbook. 	S1
asserted that C1 should not have any relevance to Complainant's claim and is not comparable to
Complainant. He stated that C1 was on the overtime desired list. S1 asserted that C1 is a Regular
City Carrier who has prior EEO activity and reports to S1.
S1 also stated that C2’s overtime has been denied on occasion. 	S1 asserted that he curtails the
mail on C2’s route depending on the mail volume. S1 stated that C2 is also a Regular City Carrier
who has prior EEO activity and reports to S1.
Regarding Claim 3, Complainant alleged that S1 yelled at him and spoke to him in an
unprofessional manner. Complainant stated that he gave S1 an incomplete PS Form 3971 which
was signed by Complainant. Complainant contended that within minutes of submitting the form,
he went to retrieve it from S1 to provide additional information, and that S1 refused to return the
form to Complainant. Complainant indicated that rather than return the form to him, S1 stated that
S1 would leave the form at Route Case #4818 for Complainant out of spite. Complainant stated
that after he attempted to state his case to S1 about the form he had handed to S1 minutes before,
S1 began yelling at Complainant. 	Complainant asserted that S1 stated, “You don't run nothing
here!” Complainant stated that a coworker (C3) witnessed S1 yelling and acting unprofessional
towards Complainant. Record evidence indicated that C3 is no longer employed at the Agency;
and that he neither responded nor returned the affidavit sent to him.
Complainant reiterated that his EEO activity was a factor because S1’s professional manners
changed when Complainant’s June 2017, EEO activity drew closer. Complainant asserted that the
retaliation began with the targeting from S2; then from S1, the floor supervisor, when S1 denied
Complainant’s request for assistance. Complainant stated that this retaliation was an attempt to
deprive him of respect and dignity due to engaging in prior EEO activity.
S1 asserted that he did not yell at or speak unprofessionally to Complainant as alleged, explaining
that he was providing instructions to Complainant. S1 stated that there were no witnesses to the
incident, and asserted that no one came forward to provide a statement. 	S1 contended that
Complainant's current and prior EEO activity were not factors. S1 indicated that no policies were
applicable in this claim because Complainant was not yelled at or spoken to in an unprofessional
manner.
Regarding Claim 4, Complainant alleged that S1 and S2 changed his start time. 	Complainant
stated that he was verbally notified by S1 that his start time for Route #4818 would change from
8:00 am to 8:30 am, effective September 16, 2017.

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Complainant asserted that S1 communicated to Complainant that Complainant’s start time was
changing because Complainant was not on the overtime list. Complainant stated that his current
and prior EEO activity was a factor because management's professional manners changed as the
resolution for his prior complaint drew to a close.
Complainant reiterated that his current and prior EEO activity was also a factor on September 16,
2017, because the conditions of employment and respect changed after the EEO Specialist called
him at the station. Complainant stated that he was met with abuse of authority by management
when they created a hostile work environment by repeatedly yelling at him and by changing his
start time because he was not on the overtime list. Complainant asserted that the alleged abuse
was followed by the adjustment of his route from an estimated 8 hours to 9-10 hours. Complainant
reiterated that the ELM sections cited in Claim 2 are applicable to his allegations.
S1, affirmed by S2, explained that he changed Complainant's start time because Complainant was
not on the overtime list. 	He stated that Complainant’s start time was moved later because
Complainant was waiting around for the mail, which then caused Complainant to need overtime.
S1 stated that Complainant's schedule was changed one week in advance, consistent with agency
policy. S1 asserted that management has a right to change an employee's schedule two hours up
or down within their official start time as long as employees are notified. S1 stated that there was
no need for Complainant to arrive at work early because the mail volume was not ready and it was
causing Complainant to go into overtime because Complainant had to wait for mail. S1 stated that
Complainant's current and prior EEO activity were not factors. 	Record evidence indicated that
another coworker (C3) also had his schedule changed.
Complainant alleged that he has been harassed and placed in a hostile work environment by S1
when S1 changed the condition of Complainant’s employment through abusive, hostile and
intimidating behavior. Complainant indicated that S1 is supposed to be held to a higher standard
of behavior. 	Complainant asserted that he informed his union steward, C3, of the behavior
exhibited by S1. 	Complainant also stated that he told S1 that S1’s actions must cease but the
yelling continued with Complainant and another city carrier.
Complainant stated that he was harassed and placed in a hostile work environment on September
16, 2017, when S1 changed the conditions of his employment by discriminating against him for
not being on the overtime list. 	Complainant did not indicate that he had expressed interest on
being on the overtime list or why not being on that list would be a basis for discrimination.
Complainant asserted that he notified C3 of the hostile work environment when his start time was
changed. 	Complainant asserted that he has received little training on harassment/hostile work
environment. 	Complainant stated that there have been stand-up discussions but all training is
limited by time and by management. Complainant asserted that he has not seen current postings
on harassment/hostile work environment that are immediately visible at the Prestonwood Station.

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S1 asserted that to the best of his recollection, he does not recall Complainant filing a grievance
on being harassed. 	S1 stated that when Complainant notified the chief union steward about
Complainant’s schedule being changed, Complainant was told that management has a right to
change an employee's start time. S1 contended that he did not believe there were investigations
conducted into any complaints of harassment by Complainant because he was never approached
by the station manager for an investigation. 	S1 stated that he has received training on anti-
harassment/hostile work environment; and asserted that the agency's policy on harassment is
posted in the facility.
S2 stated that Complainant filed a harassment allegation, but it was thrown out because there was
no harassment. 	S2 asserted that she is not aware of anyone acting on behalf of Complainant
bringing forth concerns of harassment to management. 	S2 stated that Complainant's allegation
was investigated when Complainant filed a grievance. 	She asserted that through the appeals
process, there were no violations found. 	S2 stated that Complainant was informed that no
violations were found through a PS Form 8190. She stated that no corrective action was necessary.
S2 stated that she has received training on harassment and affirmed that the agency's policy on
harassment/hostile work environment is posted on the employee bulletin board.
The AJ noted that although properly and timely served with the Agency's September 6, 2019,
motion for summary judgment, no responsive pleadings were received on behalf of Complainant
in this case. 	Consequently, the AJ incorporated by reference and adopted the arguments and
rationale proffered in the Agency's uncontested motion for summary judgment as the basis for the
summary judgment decision in favor of the Agency.
In his summary judgment decision, the AJ stated that the record evidence is insufficient to show
that Complainant was subjected to discrimination on any basis or that the Agency's reasons for the
alleged discrimination were pretextual. Therefore, the AJ asserted, Complainant failed to meet his
burden of proof in this case and the Agency is entitled to judgment in its favor as a matter of law.
The AJ also cancelled any pending hearing related dates currently scheduled in this matter.
CONTENTIONS ON APPEAL
Complainant did not submit an Appeal Brief.
In its Appeal Brief, the Agency asserts that the AJ properly determined that the record is adequately
developed; that no genuine issue of material fact exists; and that the undisputed facts show that
Complainant failed to establish that he was subjected to retaliation or harassment. 	The Agency
requests that the Commission dismiss Complainant’s appeal and AFFIRM the AJ’s decision.
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 . . .”);

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see also Equal Employment Opportunity Management Directive for 29 C.F.R. Part 1614 (EEO
MD-110), at Chap. 9, § VI.B. (Aug. 5, 2015) (providing that an administrative judge’s
determination to issue a decision without a hearing, and the decision itself, will both 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”). We determine whether the AJ appropriately issued the decision without
a hearing. The Commission’s regulations allow an AJ to issue a decision without a hearing upon
finding that there is no genuine issue of material fact. 29 C.F.R. § 1614.109(g). EEOC’s decision
without a hearing regulation follows the summary judgment procedure from federal court. Fed. R.
Civ. P. 56. 	The U.S. Supreme Court held summary judgment is appropriate where a judge
determines no genuine issue of material fact exists under the legal and evidentiary standards.
Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986). 	In ruling on a summary judgment
motion, the judge is to determine whether there are genuine issues for trial, as opposed to weighing
the evidence. Id. at 249. At the summary judgment stage, the judge must believe the non-moving
party’s evidence and must draw justifiable inferences in the non-moving party’s favor. Id. at 255.
A “genuine issue of fact” is one that a reasonable judge could find in favor for 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 “material” fact has the potential to affect the outcome of a case.
ANALYSIS AND FINDINGS
AJ’s Issuance of a Decision Without a Hearing
An AJ may issue a decision without a hearing only after determining that the record has been
adequately developed. See Petty v. Dep’t of Def., EEOC Appeal No. 01A24206 (July 11, 2003).
We carefully reviewed the record and find that it is adequately developed. To successfully oppose
a decision without a hearing, Complainant must identify material facts of record that are in dispute
or present further material evidence establishing facts in dispute. Here, Complainant did not raise
any contentions regarding summary judgment. 	We will, therefore, discuss the AJ’s summary
judgment decision below.
After a careful review of the record in the instant complaint, we find that the AJ correctly
concluded that Complainant was not subjected to retaliatory harassment in reprisal for his prior
EEO activity.
The 	Commission 	has 	adopted 	the 	burden-shifting 	framework 	for 	analyzing 	claims 	of
discrimination outlined in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973).

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The Commission applies the McDonnell Douglas analysis to complaints involving retaliation
claims. Hochstadt v. Worcester Found, for Experimental Biology Inc., 425 F. Supp. 318, 324 (D.
Mass.), aff'd, 545 F.2d 222 (1st Cir. 1976). For Complainant to prevail, he must first establish a
prima facie case of discrimination by presenting facts that, if unexplained, reasonably give rise to
an inference of discrimination. He must demonstrate that a prohibited consideration was a factor
in the adverse employment action. McDonnell Douglas, 411 U.S. at 802; Furnco Constr. Corp. v.
Waters, 438 U.S. 567, 576 (1978).
Once a complainant has established a prima facie case, the burden then shifts to the Agency to
articulate a legitimate, nondiscriminatory reason for its actions. Texas Dep't of Com. Affairs v.
Burdine, 450 U.S. 248, 253 (1981). 	If the Agency is successful, the burden is again on
Complainant to demonstrate by a preponderance of the evidence that the Agency's reason(s) for
its action was a pretext for discrimination. At all times, it is Complainant’s obligation to show 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, 509 (1993); U.S. Postal Serv. Bd. of Governors v.
Aikens, 460 U.S. 711, 715-16 (1983).
To prevail in a retaliatory harassment claim, a complainant must show that a reasonable person
would have found the challenged action materially adverse, i.e., an action that might well have
dissuaded a reasonable worker from making or supporting a charge of discrimination in the future.
Burlington Northern and Santa Fe Ry. Co. v. White, 548 U.S. 53 (2006).
Here, we find that Complainant failed to establish a prima facie case of retaliatory harassment as
he has not provided any evidence or facts that give rise to an inference of unlawful discrimination
based on his prior EEO activity. Neither has Complainant described any management action that
could deter an employee from engaging in future EEO activity.
Notably, Complainant has failed to show that he was treated less favorably than a similarly situated
employee under similar circumstances who had not engaged in protected EEO activity. Two of
the four comparators identified by Complainant had previously engaged in protected EEO activity.
The third comparator no longer works for the Agency; and he did not provide an affidavit response.
A fourth comparator appears to have been mentioned in passing, and Complainant did not object
to the lack of witness testimony from that comparator in the record. 	Moreover, even if
Complainant 	had 	established 	a 	prima 	facie 	case, 	the 	Agency has 	articulated 	legitimate,
nondiscriminatory reasons for the actions at issue.
Specifically, regarding Claim 1, S2 explained that consistent with Agency policy, she conducted
an 	investigation, 	and 	subsequently 	issued 	Complainant 	the 	LOW, 	in 	order 	to 	control
Complainant’s 	unscheduled 	absences. 	Regarding 	Claim 	2, 	S1 	asserted 	that 	he 	denied
Complainant’s request for assistance because there was not enough mail volume to justify
Complainant receiving the assistance. Regarding Claim 3, S1 denied yelling at Complainant or
speaking to Complainant in an unprofessional manner.

2020001096	9
Regarding Claim 4, S1 explained that he changed Complainant’s scheduled begin time because
when Complainant reported to work at 8:00 a.m., the mail volume was not ready for his route
which caused Complainant to wait for the mail and work overtime even though Complainant was
not on the overtime desired list.
We note that Complainant has failed to provide evidence of actions undertaken by management
that would fall outside the category of ordinary workplace interactions. The claims of harassment
raised by Complainant are generic in nature; and the record is devoid of any evidence or
corroborating witness testimony. 	The Commission has found that petty slights and trivial
annoyances are not actionable, as they are not likely to deter protected activity, but that more
significant retaliatory treatment could be challenged regardless of the level of harm. Chavez v.
U.S. Postal Serv., EEOC Appeal No. 01A12435 (July 25, 2001) (citing EEOC Compliance Manual
on Retaliation at 8-13 through 8-15 (May 20, 1998); Smith v. Sec'y of Navy, 659 F.2d 1113, 1120
(D.C. Cir. 1981)). 	We find no evidence of any significant action that could be traced to
Complainant’s prior or current protected EEO activity in the instant complaint.
CONCLUSION
Based on a thorough review of the record and the contentions on appeal, including those not
specifically addressed herein, we AFFIRM the AJ’s decision finding no discrimination and the
Agency’s final action adopting and fully implementing it.
STATEMENT OF RIGHTS - ON APPEAL
RECONSIDERATION (M0620)
The Commission may, in its discretion, reconsider this appellate decision if the complainant or the
agency submits a written request that contains arguments or evidence that 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 for reconsideration must be filed with EEOC’s Office of Federal Operations (OFO)
within thirty (30) calendar days of receipt of this decision. If the party requesting reconsideration
elects to file a statement or brief in support of the request, that statement or brief must be filed
together with the request for reconsideration. A party shall have twenty (20) calendar days
from receipt of another party’s request for reconsideration within which to submit a brief or
statement in opposition. See 29 C.F.R. § 1614.405; Equal Employment Opportunity Management
Directive for 29 C.F.R. Part 1614 (EEO MD-110), at Chap. 9 § VII.B (Aug. 5, 2015).
Complainant should submit his or her request for reconsideration, and any statement or brief in
support of his or her request, via the EEOC Public Portal, which can be found at
https://publicportal.eeoc.gov/Portal/Login.aspx.

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Alternatively, complainant can submit his or her request and arguments to the Director, Office of
Federal Operations, Equal Employment Opportunity Commission, via regular mail addressed to
P.O. Box 77960, Washington, DC 20013, or by certified mail addressed to 131 M Street, NE,
Washington, DC 20507. In the absence of a legible postmark, complainant’s request to reconsider
shall be deemed timely filed if OFO receives it by mail within five days of the expiration of the
applicable filing period. See 29 C.F.R. § 1614.604.
An agency’s request for reconsideration must be submitted in digital format via the EEOC’s
Federal Sector EEO Portal (FedSEP). See 29 C.F.R. § 1614.403(g). Either party’s request and/or
statement or brief in opposition must also include proof of service on the other party, unless
complainant files his or her request via the EEOC Public Portal, in which case no proof of service
is required.
Failure to file within the 30-day time period will result in dismissal of the party’s request for
reconsideration as untimely, unless extenuating circumstances prevented the timely filing of the
request. 	Any supporting documentation must be submitted together with the 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 (S0610)
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 (Z0815)
If you want to file a civil action but cannot pay the fees, costs, or security to do so, you may request
permission from the court to proceed with the civil action without paying these fees or costs.
Similarly, if you cannot afford an attorney to represent you in the civil action, you may request the
court to appoint an attorney for you. You must submit the requests for waiver of court costs or
appointment of an attorney directly to the court, not the Commission. The court has the sole
discretion to grant or deny these types of requests.

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Such requests do not alter the time limits for filing a civil action (please read the paragraph titled
Complainant’s Right to File a Civil Action for the specific time limits).
FOR THE COMMISSION:
______________________________ 	Carlton M. Hadden’s signature
Carlton M. Hadden, Director
Office of Federal Operations
September 24, 2020
Date