EEOC Appeal 2025004586

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Office of Federal Sector
P.O. Box 77960
Washington, DC 20013
Nubia H.,1
Complainant,
v.
Markwayne Mullin,
Secretary,
Department of Homeland Security
(Customs and Border Protection),
Agency.
Appeal No. 2025004586
Hearing No. 460-2024-00061X
Agency No. HS-CBP-00922-2022
DECISION
Complainant filed an appeal, pursuant to 29 C.F.R. § 1614.403, from the Agency’s
August 6, 2025, final order concerning an 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
reasons that follow, we AFFIRM the Agency’s final order.
At the time of events giving rise to this complaint, Complainant was employed by
the Agency as a Customs and Border Protection Officer (CBPO) at the Agency’s
Houston Field Office, Houston International Airport in Houston, Texas.
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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On May 4, 2022, Complainant filed an EEO complaint alleging discrimination by
the Agency on the bases of race (African-American), sex (female), and reprisal for
protected EEO activity under Title VII of the Civil Rights Act of 1964 when she was
subjected to numerous incidents of harassment, including but not limited to:
(1) on December 4, 2021, an Acting Supervisor (Supervisor 1) belittled and
degraded Complainant in front of two Caucasian passengers who had made
racially charged remarks towards her and forced Complainant to continue
processing 	the 	passengers 	despite 	their 	racism 	and 	hostility 	and 	after
Complainant reported Supervisor 1’s behavior, management refused to act;
(2) another Supervisory CBPO (Supervisor 2) chastised Complainant via
email before several management officials, for stepping away from work to
take care of a family emergency and later that day, the Chief sent an all-hands
email that clearly targeted Complainant for the same reason;
(3) she was issued a Letter of Counseling for unprofessional conduct;
(4) she was issued a Letter of Reprimand for Failure to Follow Policies and
Procedures in the Performance of Inspectional Duties whereas a Hispanic
male co-worker made the same mistake and was not reprimanded; and
(5) she did not receive an “On the Spot” award and was not recognized at the
award ceremony for her assistance in a January 2022 case whereas two other
individuals involved in the case received awards.
Complainant identified the email she sent to management on December 5, 2021,
complaining about Supervisor 1’s treatment of her the day before as her prior
protected activity. See Report of Investigation (ROI) at 262. She asserted that she
believed that all the numerous management officials involved in her complaint,
which included at least eight different Supervisory CBPOs and several other
management officials, were aware of the December 5 email because “[a]ll of the
management officials talk.” See ROI at 262. She stated that on December 4, 2021,
a Caucasian couple approached the book she was working and she proceeded to
process them in the same “routine, robotic interview” she usually employed when
the male passenger told her, “You need to yell because I can’t hear you,” to which
Complainant responded that she was not going to yell because that would offend the
male passenger and she would remain professional. See ROI at 264.

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She stated that after this, she completed processing the male passenger and asked the
female passenger to remove her mask and the female passenger “began stomping,
yanking her mask and belongings off,” and when Complainant asked if the female
passenger was okay, the female passenger responded loudly, “You have an attitude
and I know why.” See ROI at 264. Complainant stated that she thought this was a
racist insinuation that Complainant was “an angry black female,” so she went to ask
Supervisor 1 for assistance and to have the passengers go to another line to be
processed. Supervisor 1 asked if the passengers were VIPs or diplomats and when
Complainant said no, he instructed Complainant to process the passengers and get
them out and when Complainant still said she did not want to process the female
passenger, Supervisor 1 insisted. 	See ROI at 264. 	Complainant took issue with
Supervisor 1’s behavior because she said that in forcing her to continue processing
a passenger who had made a racial comment, he was “ridiculing, bullying,
intimidating, and made a mockery [] out of [her.]” See ROI at 267. On December
5, 2021, Complainant sent an email to her second-line supervisor, the Chief, and two
union representatives about the incident, noting that Supervisor 1’s behavior in
making her process the female passenger was “humiliating and unnecessary,” as well
as being “demoralizing and improper.” See ROI at 456-457. Complainant also took
issue with being issued a Letter of Counseling for performing a “robotic” interview,
which she asserted was focusing on the single word from her December 5 complaint
“looking for something to use against [her]” while ignoring her own complaint. See
ROI at 301-302. She stated this was unfair because being “robotic” was actually a
“skill of de-escalation” and did not amount to unprofessionalism so she should not
have been counseled for it. See ROI at 302.
Supervisor 1 stated that on December 4, when Complainant asked for his assistance
because two passengers were being rude and she felt uncomfortable, he reviewed
the passengers’ passports and walked back towards the booth and observed the
passengers and “their body language was not [] assaultive or uncompliant,” and that
at no point did he see the passengers being “uncompliant, or rude, or impeding the
inspection.” See Hr’g Tr. May 5, 2025 (Hr. Tr. 5) at 42-44. Supervisor 1 asserted
that he did not “force” Complainant to process the passengers, only told her to
continue to perform her primary duty, which was to process passengers. See ROI at
500. 	He also asserted that Complainant did not tell him that the passengers were
being hostile or racist, but he did recall Complainant saying that she did not want to
raise her voice and be looked at as an “angry black woman.” See ROI at 501; Hr’g
Tr. 5 at 47.

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The Chief explained that as a CBPO, “you have to take control of the [] situation”
because sometimes “passengers are going to be upset” because “they don’t like being
questioned.” See Hr’g Tr. April 16, 2025 (Hr’g Tr. 3) at 147-48. He asserted that
in his opinion, as long as passengers were not being aggressive or saying anything
inappropriate, he would just tell the CBPO to process the passengers and get them
on their way because of how busy they are. 	See Hr’g Tr. 3 at 148. 	Supervisor 1
stated that after Complainant filed her complaint about the December 4 incident, he
was told to write a memo and the complaint was also forwarded to the Joint Intake
Center (JIC), which is where employees can report allegations of misconduct that
will then be investigated to determine if discipline is warranted, and the JIC closed
out 	the 	incident 	with 	no 	action 	because 	the 	allegation 	was 	found 	to 	be
unsubstantiated. See Hr’g Tr. 5 at 52-53, 178; ROI at 507.
A Labor and Employee Relation Specialist (LER Specialist) testified that a letter of
counseling is not a disciplinary action but is only to put an employee on notice of
some alleged violation or some other procedure. See Hr’g Tr. 5 at 144. He further
explained that during training, officers are instructed to engage in “unscripted
conversation” which are to “create a dialogue so that individuals can be engaged”
because it “helps the people relax” so that the officer can gather more information.
See Hr’g Tr. 5 at 149-50. 	He stated that a “robotic” interview rather than an
unscripted conversation during primary would be less beneficial and that he has
frequently seen letters of counseling issued to put employees on notice for failing to
use the unscripted conversation style. See Hr’g Tr. 5 at 150-52.
Complainant stated that on January 2, 2022, she received an emergency phone call
from her daughter that she needed to resolve so she told the lead officer that she was
going to the restroom to take the emergency phone call. 	See ROI at 272. 	She
asserted that when the emergency took a while to resolve, she called Supervisor 2 to
let her know that Complainant was still trying to resolve the emergency and a half
hour later, Supervisor 2 called Complainant and left a voice mail telling Complainant
she did not know where Complainant was and to report to the supervisor podium
when Complainant was done. 	See ROI at 272. 	She stated that when she finished
resolving the emergency, she reported to the supervisor podium and Supervisor 2
told her that next time she had an emergency that long, she would need to take leave
and Complainant responded that she did not know that the emergency would take
that long to resolve. See ROI at 272-73.

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Complainant asserted that the next day, Supervisor 2 sent an email to her and copied
several other supervisors and watch commanders and told them that Complainant
had been away from primary for about an hour and half to make a personal phone
call. See ROI at 273. Complainant also stated that later that day, the Chief sent an
“abrasive port-wide email” saying that there were a handful of officers who were
taking advantage of the hard work of their fellow officers by disappearing for long
periods of time and not notifying supervisors of their absence. 	See ROI at 273.
Complainant stated that both the emails were “harassing, bullying, retaliatory, and
discriminative (sic)” because they did not take into account her emergency and made
her feel targeted. See ROI at 273.
Supervisor 2 stated that on January 2, she was notified by the lead officer that day
around 20 to 30 minutes after Complainant left to take a phone call that Complainant
had still not returned. See Hr’g Tr. April 17, 2025 (Hr’g Tr. 4) at 42. She asserted
that she then went to look for Complainant just to make sure that Complainant was
okay and she found Complainant in the bathroom and Complainant told her she was
trying to book a hotel for her child and so she told Complainant to wrap it up as soon
as possible and then come to see her once Complainant was done. See Hr’g Tr. 4 at
42. She explained that she sent Complainant an email after the fact as a follow-up
to their earlier conversation about taking excessive time for personal matters while
on duty. See Hr’g Tr. 4 at 45. She stated that the Chief told her to email Complainant
and all the individuals in Complainant’s direct chain of command so she did. See
Hr’g Tr. 4 at 45-46.
The Chief explained that he directed Supervisor 2 to send Complainant the email
because Complainant had been away from her duty station for such a long time and
he wanted it to be documented that they had had a conversation with Complainant
about the issue even though they were not going to be issuing discipline or anything.
See Hr’g Tr. 4 at 106-107. He stated that he sent out the port-wide email later on
because other officers also leave their work areas and he cannot be certain that other
managers would address it because he is not there all the time so he sent it out as a
reminder that people need to return to their posts in a timely manner and inform their
supervisor if they are going to be gone. 	See Hr’g Tr. 4 at 109-10. 	He further
explained 	that 	he was 	trying 	to 	support 	Complainant, 	to 	have 	Complainant
understand that it was not just her and other officers are also leaving their work areas.
See Hr’g Tr. 4 at 110. He stated that he would have sent out a similar email if anyone
else had done the same thing and that he has, in fact, sent out similar emails about
such incidents before and since. See Hr’g Tr. 4 at 111-12.

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Complainant asserted that management “[was] taking every opportunity to retaliate,
harass, and bully [her],” by scolding her for being late or for taking a long break
even though she did not or for not processing passengers for a long time or yelling
at her in front of passengers. See ROI at 288-98. Complainant took issue with being
issued a Letter of Reprimand for failure to follow policies and procedures by missing
a referral, which she asserted was unfair because a Hispanic male co-worker made
the same mistake and was not reprimanded, and also because management did not
give her the opportunity to go find the passenger. See ROI at 308-309. Complainant
further took issue with being issued the Letter of Reprimand without the black
female union rep that she preferred, saying that management deliberately waited an
hour after the female union rep’s shift ended before contacting Complainant to
contact a male union rep instead who Complainant did not know. See ROI at 308-
309. Complainant also stated that in January 2022, she assisted in a false claim to
US citizenship case where she performed background checks on the subject and even
though one of the Chiefs told her that she would be receiving an award for the action,
she was not recognized with an “On the Spot” award while her other male coworkers
who interviewed the subject were. 	See ROI at 317-18. 	The record indicates that
Complainant received a Joint Awards Committee (JAC) award for the incident
instead. See Hr’g Tr. 5 at 174-75.
Complainant was issued a Letter of Reprimand for failing to refer a traveler for
agriculture inspection. See ROI at 936-37. The Assistant Port Director explained
that a referral is a passenger that needs to have additional inspections completed in
one of their secondary areas. See Hr’g Tr. 4 at 10. He stated that in the case of a
mishandled referral, they usually shut down the airport to try and locate the person
and afterwards, they issue the responsible officer their Weingarten rights, give a
memo, and put the officer through retraining. See Hr’g Tr. 4 at 11. He further stated
that supervisors are required to report such mishandled referrals to him and letters
of reprimand are always issued after the first incident of such a missed referral. See
Hr’g Tr. 4 at 13-14. He also stated that the officer is always held responsible for the
mishandled referral no matter what happens with the passenger afterwards so it is
not a case where it would not matter as long as the passenger is later found before
they leave the secured area. 	See Hr’g Tr. 4 at 16. 	The LER Specialist confirmed
that letters of reprimand are frequently handed out for missed referrals and that he
has probably issued around 50 of them to different employees for missing a referral
if it was the first offense. 	See Hr’g Tr. 5 at 153-55. 	He explained that missing a
referral is an important issue because CBPOs are “literally the gatekeepers” so if
they miss something, they could be letting anybody into the country.

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See Hr’g Tr. 5 at 156-57. The Chief of Staff explained that “on the spot” awards are
awards to recognize outstanding work in the performance of an employee’s regular
duties and that they are usually non-monetary in nature. See Hr’g Tr. 5 at 171. The
Chief of Staff further explained that JAC awards are another type of award where
employees can nominate themselves or a coworker to recognize outstanding work
but the JAC award is usually monetary. See Hr’g Tr. 5 at 171-72.
After its investigation into the complaint, the Agency provided Complainant with a
copy of the report of investigation and notice of right to request a hearing before an
Equal 	Employment 	Opportunity 	Commission 	(EEOC 	or 	Commission)
Administrative Judge (AJ). Complainant timely requested a hearing. The AJ held a
hearing over the course of five days, April 14-17 and May 5, 2025, and subsequently
issued a decision in favor of the Agency. 	The AJ found that the Agency offered
legitimate, nondiscriminatory reasons for all of its actions and Complainant offered
nothing beyond her own subjective beliefs to indicate pretext. She also found that
Complainant offered nothing beyond her repeated assertions that she felt that
management was harassing her but that the incidents of alleged harassment all
consisted of situations where Complainant disagreed with the Agency’s handling of
situations and application of discipline when Complainant violated Agency policies.
When the Agency failed to issue a final order within 40 days of receipt of the AJ’s
decision, the AJ’s decision became the Agency’s final action pursuant to 29 C.F.R.
§ 1614.109(i). The instant appeal followed.
On appeal, Complainant, among other things, argues that the AJ made erroneous
findings of fact and misinterpreted the evidence in the record and that the AJ’s
conclusion 	that 	Complainant 	did 	not 	establish 	that 	she 	was 	subjected 	to
discrimination wrongly discounts Complainant’s testimony and unquestioningly
accepted the Agency’s explanations. The Agency filed a brief in response, arguing
that the AJ’s decision is supported by substantial evidence and should be affirmed.
Pursuant to 29 C.F.R. § 1614.405(a), all post-hearing factual findings by an AJ will
be upheld if supported by substantial evidence in the record. Substantial evidence
is defined as “such relevant evidence as a reasonable mind might accept as adequate
to support a conclusion.” 	Biestek v. Berryhill, 587 U.S. 97, 103 (2019) (internal
citation omitted). 	A finding regarding whether or not discriminatory intent existed
is a factual finding. See EEOC Management Directive for 29 C.F.R. Part 1614 (EEO
MD-110), Chapter 9, at § VI.B. (Aug. 5, 2015).

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An AJ's conclusions of law are subject to a de novo standard of review, whether or
not a hearing was held. Id. An AJ’s credibility determination based on the demeanor
of a witness or on the tone of voice of a witness will be accepted unless documents
or other objective evidence so contradicts the testimony, or the testimony so lacks in
credibility that a reasonable fact finder would not credit it. Id.
EEO-MD-110, Chap. 9 § VI.C, further provides that on appeal to the Commission,
the burden is squarely on the party challenging the AJ’s decision to demonstrate that
the AJ’s factual determinations are not supported by substantial evidence. 	See id.
In this case, this means that Complainant has the burden of pointing out where and
why the AJ’s findings are not supported by substantial evidence. Cf. id. (pointing
out that “[t]he appeals statements of the parties, both supporting and opposing the
[AJ’s] decision, are vital in focusing the inquiry on appeal so that it can be
determined whether the [AJ’s] factual determinations are supported by substantial
evidence”).
We find that the AJ’s conclusion that Complainant did not establish that she was
subjected to discrimination is supported by substantial evidence in the record. 	At
the outset, we note that contrary to Complainant’s insistence, the email she sent on
December 5, 2021, does not constitute protected activity for purposes of an EEO
reprisal claim. 	See Mandi G. v. Dep’t of Agric., EEOC Appeal No. 2023003027
(June 12, 2025) (stating that protected activity for purposes of the EEO laws
generally means opposing some practice made unlawful under the EEO laws).
While Complainant contends that the female passenger’s comment that “You have
an attitude and I know why” was a racial reference, we disagree as there is nothing
in the context of the incident or the common understanding of the words to indicate
a 	racial 	undertone. 	Moreover, 	even 	if 	we 	accept 	Complainant’s 	subjective
interpretation of the comment as referring to her race, Complainant’s December 5th
email concerning the event did not state that Supervisor 1 had engaged in any
behavior that related to her race, only that it was “humiliating” and “demoralizing.”
See ROI at 456-57. Complainant first contacted the EEO counselor on January 20,
2022, so she cannot establish a prima facie case of reprisal for any of the incidents
of alleged harassment occurring prior to that date. 	In addition, contrary to
Complainant’s argument on appeal, we find that the AJ’s finding that Complainant
did not establish a prima facie case is supported by substantial evidence as other than
Complainant’s 	assertions, 	the 	evidence 	in 	the 	record 	does 	not 	support 	that
Complainant’s was treated differently from other similarly-situated employees.

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See Keri C. v. U.S, Postal Serv., EEOC Appeal No. 2024002670 (Aug. 12, 2025)
(unsupported assertions not sufficient to establish a prima facie case).
Moreover, even if Complainant did establish a prima facie case, we agree with the
AJ that the Agency articulated a legitimate nondiscriminatory reason for its actions
and Complainant did not establish that the Agency’s reasons were a pretext for
discrimination. 	Complainant’s arguments on appeal amount to little more than
insisting that the AJ erred in finding the management officials to be credible.
However, Complainant’s disagreement with the AJ’s credibility findings and her
interpretation of the evidence in the record is not sufficient grounds on which to
overturn the AJ’s findings. 	See Zetta B. v. Dep’t of Agric., EEOC Appeal No.
2020003201 (Sept. 2, 2021) (noting that the substantial evidence standard is a low
threshold). 	The AJ’s finding that there is no evidence in the record beyond
Complainant’s unsupported assertions to indicate that the Agency was motivated by
discriminatory or retaliatory animus is supported by substantial evidence in the
record. 	The Commission has repeatedly stated that mere assertions or conjecture
that an agency’s explanation is a pretext for intentional discrimination is insufficient
because subjective belief, however genuine, does not constitute evidence of pretext.
See Charlie O. v. Dep't of the Navy, EEOC Appeal No. 2021002639 (March 29,
2022); Juliet B. v. U.S. Postal Serv., EEOC Appeal No. 0120182519 (Oct. 8, 2019).
Furthermore, we find that the AJ’s conclusion that Complainant did not establish
that she was subjected to unlawful harassment is also supported by substantial
evidence. We agree with the AJ that all the alleged incidents of harassment amount
to little more than common workplace tribulations such as routine work assignments,
instructions, and admonishments that the Commission has repeatedly stated do not
rise to the level of an unlawful hostile work environment. 	See Arthur J. v. Social
Sec’y Admin., EEOC Appeal No. 0120142985 (Feb. 28, 2017). 	Moreover, the
alleged incidents of harassment generally consist of little more than instances where
Complainant disagreed with her various supervisors’ actions and decisions over how
work 	should 	be 	done 	and 	how 	employees 	should 	be 	supervised, 	and 	such
disagreements also do not constitute unlawful harassment. 	See Complainant v.
Dep’t of Def., EEOC Appeal No. 0120122676 (Dec. 18, 2014) (the record
established that the issues between the complainant and the supervisor were because
of personality conflicts and fundamental disagreements over how work should be
done and how employees should be supervised, and there is no indication that the
supervisor was motivated by discriminatory animus towards the complainant’s race,
sex. or age).

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Finally, while Complainant repeatedly insists that she was harassed and bullied, her
subjective perception of her supervisors’ and managers’ behavior is not sufficient to
satisfy the objective standard required to establish unlawful harassment. See Mattson
v. Dep’t of Homeland Sec’y, EEOC Appeal No. 0120052563 (July 3, 2007) (stating
that a hostile work environment is established by an objective standard and not a
complainant’s subjective perceptions). It is well settled that Title VII is not a civility
code and EEO statutes do not guarantee a complainant a right to work in a pleasant
or stress-free environment. See Carl T. v. Social Security Admin., EEOC Appeal
No. 2022000277 (Jan. 5, 2023); Terese D. v. Dep’t of Veterans Affs., EEOC Appeal
No. 2022003100 (Nov. 15, 2022).
Upon careful review of the AJ’s decision and the evidence of record, as well as the
parties’ arguments on appeal, we conclude that substantial evidence of record
supports the AJ’s determination that Complainant has not proven discrimination by
the Agency as alleged.
Accordingly, we AFFIRM the Agency’s final order implementing the AJ’s decision.
STATEMENT OF RIGHTS - ON APPEAL
RECONSIDERATION (M1125)
The Commission may, in its discretion, reconsider this appellate decision if
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 Sector
(OFS) 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.

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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 their request for reconsideration, and any statement or
brief in support of their request, via the EEOC Public Portal, which can be found at
https://publicportal.eeoc.gov/Portal/Login.aspx. 	Alternatively, Complainant can
submit their request and arguments to the Director, Office of Federal Sector, 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, a complainant’s
request to reconsider shall be deemed timely filed if OFS 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 their 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(f).
COMPLAINANT’S RIGHT TO FILE A CIVIL ACTION (S0124)
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 their
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.

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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. 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:
T. Gimbrere __________ 	Gul Chaudhry’s signature
T. Gimbrere, Acting Director
Office of Federal Sector
September 24, 2026
Date