Federal Disability Retirement Under FERS & CSRS - A Second (And Sometimes Third) Bite at the Apple

In filing a claim for Federal Disability Retirementbenefits. However, one can get around the
benefits under the Federal Employees Retirementdefense of res judicata if you can show two
Systems (FERS) or Civil Service Retirementthings: First, that the time period in question is
System (CSRS), there are certaindifferent from the previous time-period, and
time-constraints: (1) You must file within one yearsecond, that the medical condition worsened since
of being separated from Federal Service, and (2)the original time-period. This makes sense, if you
Your medical condition must last for a minimum ofstop and think about it: For, if the principle of res
12 months. This does not mean that you mustjudicata is meant to stop people from re-litigating
wait for twelve months after your medicalthe same issue over and over again, you must
condition arises and prevents you fromshow not only that the second application was for
performing one or more of the essential elementsa different time-period, but further, that the
of one's job; rather, it merely means that themedical condition was somehow "different"
prognosis of your medical condition is such that it(worse) than what was shown during the first
is expected to last for at least 12 months. Thus,time around.
a person who is diagnosed with multi-level discAnd, indeed, this is precisely what the Merit
degeneration, or suffers from plantar fasciitis, orSystems Protection Board decided in the case of
Chronic Pain syndrome, failed back syndrome,Luzi v. Office of Personnel Management, 106
Chronic Fatigue Syndrome, Fibromyalgia, orM.S.P.R. 160 (2007), where the Merit Systems
psychiatric disabilities of Major Depression,Protection Board found that a disability retirement
Anxiety, panic attacks, etc., or a multitude ofappeal following a denial of an appellant's second
other kinds of medical conditions not listed herein,application for disability retirement benefits was
need not wait for 12 or more months before filingnot barred by res judicata arising from a prior
for Federal Disability Retirement benefits underBoard decision, where the second application was
FERS or CSRS. Rather, the medical condition mustbased on a different time period than was
be expected to last for a minimum of twelveaddressed in the original appeal and was based on
months.evidence that could not have been raised in the
Now, within those time constraints, the question isprior appeal. Thus, if you file a Federal Disability
often asked as to whether a Federal or PostalRetirement application, and take the case all the
worker can file for disability retirement benefitsway through the MSPB Hearing Stage, you need
more than once. In other words, what if a Federalto be cautioned that your ability to file a
or Postal worker tries once - and gets a denialsubsequent application may be restricted.
from the Office of Personnel Management. CanNow, while the case of Luzi allows for a "second
you try again? The answer is - as with most legalbite at the apple", it obviously imposes some
questions - both yes and no.onerous restrictions, and such restrictions further
Remember, first, that there are many stages tobring up other issues. For example: Might it not be
win a Federal Disability Retirement claim: you havea wise move to think about re-filing a new,
the First, or Initial Stage of the application; if it issecond application after a denial at the
denied, you can Request for Reconsideration (theReconsideration Stage but before an appeal to
"Second Stage"); if denied again, you can file anthe MSPB? (Answer: In some cases, depending
appeal to the Merit Systems Protection Board (anupon the facts of the case, the answer is, "Yes").
"MSPB Appeal"); if the Administrative Judge deniesIf you drop the first case at either the Initial
your claim at the MSPB, you can file a Petition forApplication stage or the Reconsideration Stage,
Full Review to the Full Board of the MSPB; and ifdoes the principle of res judicata still apply?
the Full Board denies your claim you can file a(Answer: No, but OPM will still have your file from
further appeal to the United States Court ofthe first case to refer back to, so it would be
Appeals for the Federal Circuit. Thus, there arewise to approach the second filing in a different
many "bites at the apple".manner). If you get denied at both the Initial
Secondly, however, within those many "bites atStage and the Reconsideration Stage, but before
the apple", there are some restrictions. Take thefiling an appeal to the Merit Systems Protection
following scenario: A Federal or Postal employeeBoard, you are removed from Federal Service
files a Disability Retirement Application in January,for your Medical Inability to perform your job -
2008. It is denied in May, 2008. A Request forwhat should you do? Drop it and Refile? File the
Reconsideration is filed, and it is again denied inMSPB Appeal? (Answer: There are too many
August, 2008. He files an Appeal to the Meritvariables to answer such a question here, and
Systems Protection Board, and the Administrativeeach individual case must be decided based upon
Judge denies his case in an opinion datedthe unique set of circumstances) If you take a
December, 2008. The Applicant does not pursuecase to the MSPB and get a denial from the
any further appeals, but lets the MSPB opinion onAdministrative Judge, what will be needed to file a
the matter stand. Question: Can the samesecond time? (Any subsequent application will
individual file a new application with the Office ofhave to be for a different time-period than the
Personnel Management in January, 2009, assumingfirst application, and any medical evidence must
that he has not, in the meantime, been separatedshow that the medical condition worsened in the
from Federal Service for more than one year?subsequent time-period, in contrast to the first
The answer: One must be careful. In the arena oftime-period - see Luzi, herein).
law, there is a legal principle known as res judicataFiling for Federal Disability Retirement under FERS
-- which, in fundamental terms, simply means thator CSRS is a complex process, and each stage of
an issue which has been previously decided by thethe process needs to be carefully evaluated - not
court cannot be re-litigated. In the example givenonly for a given particular stage, but for setting
above, if an Applicant files a new claim for theup the next stage, and the next one after that.
same time-period of disability, then there is aTo think that you will "win" at any given stage of
likelihood that the Office of Personnelthe process without giving thought to a
Management will bring up the legal principle of ressubsequent stage, is to ignore one's future, and
judicata, and attempt to prevent the applicantthat is indeed a foolish way to proceed.
from being granted his disability retirement