Rafael Zamot v. Merit Systems Protection Board

PAULINE NEWMAN, Circuit Judge,

dissenting.

I respectfully dissent, for the uncertainties as to Mr. Zamot’s veterans’ preference status require resolution and clarification. Consideration should have been given to the letter from the Chief of Naval Operations concerning the Commendation and to the letter from the Regional Representative stating that the Navy consulted the Judge Advocate General and advised that the Chief of Naval Operations’ letter should suffice for the purpose of preference eligibility jurisdiction. Consideration also should have been given to the difficulties Mr. Zamot encountered in obtaining detailed information from the Navy, and to the purpose of the veterans’ preference law.

Mr. Zamot provided evidence that he had five years of active service in the United States Navy, from 1984 to 1989, and was honorably discharged. He subsequently joined the Army Ready Reserve, and was called to active duty in October 2001. During his Naval service he received a Sea Service Deployment Ribbon, a Navy Battle “E” Ribbon, a First Good Conduct Medal, and a Meritorious Unit Commendation.

Mr. Zamot encountered obstacles in his efforts to establish compliance with the statutory definition of a “preference eligible” veteran. The definition of “preference eligible,” at 5 U.S.C. § 2108(3) is incorporated into 39 U.S.C. § 1005(a)(4)(A)® which grants the right of appeal to the Board to veterans who “served on active duty in the armed forces during a war, [or] in a campaign or expedition for which a campaign badge has been authorized”. 5 U.S.C. § 2108(1). See *1380Flanagan v. Young, 228 F.2d 466, 472 (D.C.Cir.1955) (“It is a truism to say that the Veterans’ Preference Act is to be construed, wherever possible, in favor of the veteran.” (citations omitted)); Adler v. United States, 129 Ct.Cl. 150, 156 (1954) (“[I]t is plain that the [1944] Act did not mean to restrict the preference of veterans, but to enlarge them.”) In construing Section 2108(1), this court held that military service alone is inadequate, and that a veteran must show “involvement or participation” in a qualifying campaign or expedition. Perez v. Merit Systems Protection Board, 85 F.3d 591, 594 (Fed.Cir.1996) (holding that a soldier stationed at a base geographically distant from a campaign is not preference eligible). The holding of Perez was overruled by the Defense Authorization Act of Fiscal Year 1998, Pub.L. No. 105-85, Div. A, Title XI, § 1102(a) (1997), with regard to preference eligibility for service during the Gulf War, the issue in Perez.

The administrative judge advised Mr. Zamot that he must establish that he served in a campaign or expedition for which a campaign badge was authorized, and directed Mr. Zamot to an Office of Personnel Management (OPM) resource that listed campaigns, expeditions, or awards that qualify for preference eligible status. Mr. Zamot requested more time to assemble this documentation, and the administrative judge dismissed the appeal without prejudice, giving Mr. Zamot an additional three months to refile the appeal.

Mr. Zamot timely refiled in January 2001, and submitted a letter from the Chief of Naval Operations stating that Mr. Zamot received a unit award for meritorious service for the period April 1, 1988 to September 30, 1989. Mr. Zamot filed a statement that “appellant was informed by the Navy that Naval JAG was consulted and that this letter should suffice for his purpose of Preference Eligibility/Jurisdiction before the US-MSPB.” Mr. Zamot stated that he was “able to secure [the letter] with great difficulty,” because the “Naval Service and War Office were most reluctant to release the enclosed letter.”

Before the Board Mr. Zamot stated that he served on a “Warship [ ] on duty station in the Middle East in direct support of both Overt as well as Covert Combat Operations” during the period leading to the Gulf War. He stated that the Navy was reluctant to release additional information as much of it was classified. He again asked for more time, on the ground that the criteria set by OPM were difficult to establish through Navy personnel, who had already told him that Navy JAG had stated that his service and the letter from the Chief of Naval Operations met the requisite criteria. The Postal Service objected to the request for more time, and the administrative judge denied the request.

The administrative judge held that Mr. Zamot had not shown that his military service qualified for veterans’ preference, for his active Naval service was not during the Gulf War period stated in the statute that overruled Perez, viz. August 2, 1990 to January 2, 1992, and for other periods the materials submitted did not show that he met the statutory requirements of participating in a campaign or expedition. Mr. Zamot states that he served in the Persian Gulf in support of covert and overt operations between 1988 and 1989. The OPM materials referred by the administrative judge state that an Armed Forces Expeditionary Medal was authorized for participation in a United States military operation that involved the protection of shipping vessels in the Persian Gulf between July 1987 and August 1990. Mr. Zamot’s statements concerning the view of Navy officials upon consultation with Navy *1381JAG, and the letter from the Chief of Naval Operations, were given no weight. The administrative judge held that Mr. Zamot did not meet the requirements of veterans’ preference eligibility, referencing Hamilton v. United States Postal Service, 86 M.S.P.R. 215, 217 (2000), and explaining as follows:

Unlike Hamilton, however, the appellant in this appeal has not shown that he received an Expeditionary Medal and, therefore, has not shown that he is a preference eligible entitled to appeal his removal to the Board. Although the appellant argues that he is precluded by law from releasing information about his service due to the seeret/classified information involved, See Refiled Appeal File, Tab 1, this undisclosed information is insufficient to establish that he received an Expeditionary Medal in a campaign or expedition for which a campaign badge was authorized.

This explanation suggests that Mr. Zamot was required to show that he received an Expeditionary Medal. Mr. Zamot could reasonably have understood this decision to set a requirement that he could not meet, for he did not continue that appeal. The statutory requirement, however, is not receipt of an Expeditionary Medal, but service in a campaign for which a medal was authorized. See Perez, 85 F.3d at 594. Hamilton states only that a veteran who did receive an Expeditionary Medal is not required to provide further proof that he served in a qualifying campaign. 86 M.S.P.R. at 217. Mr. Zamot explains that he was “under the impression or understanding that he no longer had any legal standing” with the Board as a veteran, and that he therefore pursued EEOC relief.

Mr. Zamot returned to the Board, stating that the EEOC made an affirmative finding that he was a whistleblower, and seeking to appeal his dismissal on this ground. However, the Board did not consider the case as a whistleblower action, but treated the filing as an appeal of the Initial Decision denying veterans’ preference of almost a year earlier. The Board then examined the issue of timeliness, and ruled that Mr. Zamot had not established good cause for the delay in appealing the Initial Decision because his submission concerning delay was not properly sworn, and that he had six months after the Initial Decision before his recall to active duty. The Board held that Mr. Zamot’s pro se status and inexperience with legal matters were no excuse, and dismissed the action. This dismissal is now before us. Mr. Za-mot, as a pro se petitioner, is entitled to sympathetic review. See Wright v. United States Postal Service, 183 F.3d 1328, 1332 (1999) (“The board has broad discretion in deciding whether reconsideration of a decision is necessary to preserve consistency or achieve the ‘right result.’ ”) The Board is obligated to exercise this discretion when needed to assure compliance with the legislative purpose of the merit system of federal employment. This purpose includes equitable application of penalty— for it cannot be ignored that the person with whom Mr. Zamot scuffled in the locker room, appealing as a veteran, received only a sixty-day suspension, while Mr. Za-mot remains terminated.

The Board had the opportunity and indeed the obligation to review, clarify, and if warranted to correct the administrative judge’s decision as to veterans’ preference. As the Supreme Court has recognized, procedural latitude is appropriate for pro se parties. Haines v. Kerner, 404 U.S. 519, 520-21, 92 S.Ct. 594, 30 L.Ed.2d 652 (1972). In view of the importance of recognizing veterans’ rights, the material provided by the Navy should not have been rejected by the administrative judge. The statement of the Chief of Naval Operations, the view of Navy JAG, and the *1382OPM materials concerning his time and area of service, should have been interpreted generously, not rejected out of hand. The matter should be remanded for further consideration,