Chafin v. Opm
CourtCourt of Appeals for the Federal Circuit
Date FiledMay 27, 2026
Docket24-2369
StatusPublished
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Full Opinion
Case: 24-2369 Document: 47 Page: 1 Filed: 05/27/2026
United States Court of Appeals
for the Federal Circuit
______________________
BARBARA LEE CHAFIN,
Petitioner
v.
OFFICE OF PERSONNEL MANAGEMENT,
Respondent
______________________
2024-2369
______________________
Petition for review of the Merit Systems Protection
Board in No. AT-844E-20-0506-I-1.
______________________
Decided: May 27, 2026
______________________
LAWRENCE BERGER, Mahon & Berger, Esqs., Glen
Cove, NY, for petitioner.
JANA MOSES, Commercial Litigation Branch, Civil Di-
vision, United States Department of Justice, Washington,
DC, argued for respondent. Also represented by STEVEN
JOHN GILLINGHAM, PATRICIA M. MCCARTHY, BRETT
SHUMATE.
______________________
Before MOORE, Chief Judge, MAYER and LOURIE, Circuit
Judges.
Case: 24-2369 Document: 47 Page: 2 Filed: 05/27/2026
2 CHAFIN v. OPM
LOURIE, Circuit Judge.
Barbara Chafin petitions for review from a final deci-
sion of the Merit Systems Protection Board (“the Board”)
that affirmed the denial of her application for Federal Em-
ployees’ Retirement System (“FERS”) disability retirement
benefits. J.A. 14–21 (Final Decision); J.A. 1–13 (Initial De-
cision). We affirm.
BACKGROUND
In November 1987, Chafin began her employment as a
GS-03 Operational Support Technician (“OST”) with the
Federal Bureau of Investigation (“the government”) in its
Miramar, Florida office. J.A. 2. In that role, Chafin per-
formed “clerical, assistant, or technician work,” and she
was required to be physically present to perform those du-
ties. J.A. 61; see J.A. 71. She drove from her home in
Goulds, Florida to the Miramar office. J.A. 71.
In December 2016, Chafin was found to have engaged
in workplace misconduct; specifically, that she was “under
the influence while on duty.” J.A. 2, 51. She was subse-
quently removed from her position in July 2018. J.A. 2.
In April 2019, Chafin applied for FERS disability re-
tirement benefits with a retroactive start date of February
2018. J.A. 86–110; see 5 U.S.C. § 8451 (listing the require-
ments for FERS disability retirement). Relying on state-
ments from her medical provider and work supervisor,
Chafin contended that she had suffered numerous seizures
that prevented her from driving to the Miramar office and
completing the duties of an OST, and that she was there-
fore disabled. See J.A. 112. The Office of Personnel Man-
agement (“OPM”) denied the application and request for
reconsideration, determining that Chafin did not establish
that her seizures prevented her from providing “useful and
efficient service” as an OST, see 5 U.S.C. § 8451(a)(1)(B),
and therefore that she did not establish that she was disa-
bled. J.A. 52–53, 112.
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CHAFIN v. OPM 3
Chafin then appealed to the Board. See J.A. 4. In an
Initial Decision, the administrative judge (“the AJ”) af-
firmed OPM’s conclusion that Chafin was not disabled.
J.A. 3–5. The AJ found that the evidence did not indicate
that Chafin could not perform the essential functions of her
OST position. J.A. 3–4. Moreover, the AJ rejected Chafin’s
argument that her inability to drive, together with the lack
of public transportation and the prohibitive cost of ride-
sharing services, should be considered in determining
whether she could render useful and efficient service under
§ 8451(a)(1)(B). J.A. 4.
Chafin then petitioned for review of the Initial Decision
by the full Board, which adopted the AJ’s determination
that Chafin was not disabled. J.A. 14–17.
Chafin timely petitioned to this court for review. We
have jurisdiction under 28 U.S.C. § 1295(a)(9).
DISCUSSION
We generally must affirm a final decision of the Board
unless it was (1) arbitrary, capricious, an abuse of discre-
tion, or otherwise not in accordance with law; (2) obtained
without procedures required by law, rule or regulation hav-
ing been followed; or (3) unsupported by substantial evi-
dence. 5 U.S.C. § 7703(c). However, when OPM makes
factual findings relating to physical disability determina-
tions, such findings are final and conclusive and not subject
to review by this court. See id. § 8461(d); Anthony v. OPM,
58 F.3d 620, 626 (Fed. Cir. 1995) (“[T]his court is precluded
by 5 U.S.C. § 8461(d) from reviewing the factual underpin-
nings of physical disability determinations.”). At the same
time, we may address “whether there has been a substan-
tial departure from important procedural rights, a miscon-
struction of the governing legislation, or some like error
going to the heart of the administrative determination.”
Anthony, 58 F.3d at 626 (quoting Lindahl v. OPM, 470 U.S.
768, 791 (1985)) (internal quotation marks omitted).
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4 CHAFIN v. OPM
I
Chafin challenges the denial of her application for
FERS disability retirement benefits under 5 U.S.C.
§ 8451(a)(1)(B) on two grounds. First, Chafin contends
that it was legal error for the Board to refuse to consider
evidence of her inability to make the commute to the gov-
ernment office in Miramar in determining that she was not
unable to render useful and efficient service. Open. Br. 10–
16. Second, Chafin argues that the Board’s factual deter-
mination that she was not unable to render useful and ef-
ficient service was otherwise not adequately supported by
the evidence. Open Br. 9–10. We address each argument
in turn.
A
We start with Chafin’s argument that the Board legally
erred in failing to consider evidence of her inability to
drive, as well as the lack of available public transportation
and the prohibitive cost of ride-sharing services, in deter-
mining that she was not unable to render useful and effi-
cient service under 5 U.S.C. § 8451(a)(1)(B). Specifically,
she argues that the reference to an employee’s “commuting
area” in § 8451(a)(2)(A), the next provision recited in the
statute, suggests that an employee’s ability to commute re-
quires consideration of that issue in determining whether
she is able to render useful and efficient service under.
§ 8451(a)(1)(B). See Open. Br. 15. We disagree.
Section 8451(a)(1)(B) recites:
For purposes of this subsection, an employee shall
be considered disabled only if the employee is found
by [OPM] to be unable, because of disease or injury,
to render useful and efficient service in the em-
ployee’s position.
(emphasis added).
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CHAFIN v. OPM 5
The very next provision of the statute, § 8451(a)(2)(A),
recites:
Notwithstanding paragraph (1), an employee shall
not be eligible for disability retirement under this
section if the employee has declined a reasonable
offer of reassignment to a vacant position in the
employee’s agency for which the employee is quali-
fied if the position—
(i) is at the same grade (or pay level) as the
employee’s most recent grade (or pay level)
or higher;
(ii) is within the employee’s commuting
area; and
(iii) is one in which the employee would be
able to render useful and efficient service.
(emphases added).
It is a fundamental canon of statutory construction
that “where Congress includes particular language in one
section of a statute but omits it in another section of the
same Act, it is generally presumed that Congress acts in-
tentionally and purposely in the disparate inclusion or ex-
clusion.” Russello v. United States, 464 U.S. 16, 23 (1983)
(cleaned up). Applying that canon here demonstrates that
the Board correctly refused to consider Chafin’s inability to
make the commute to the government office in Miramar in
determining that she was not unable to render useful and
efficient service under § 8451(a)(1)(B). We explain.
Both §§ 8451(a)(1)(B) and 8451(a)(2)(A) frame, in part,
the disability retirement benefits inquiry in terms of
whether the employee can “render useful and efficient ser-
vice.” Section 8451(a)(1)(B) recites that language in defin-
ing what an employee must show to be considered disabled:
“an employee shall be considered disabled only if the em-
ployee is found by [OPM] to be unable, because of disease
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6 CHAFIN v. OPM
or injury, to render useful and efficient service in the em-
ployee’s position.” Id.
Section 8451(a)(2)(A) uses almost identical language—
“the employee would be able to render useful and efficient
service”—to define the type of position that if “declined,”
renders an otherwise disabled employee ineligible for ben-
efits. Id. § 8451(a)(2)(A)(iii). But within that definition is
an explicit reference to the employee’s ability to commute:
the employee shall not be eligible for disability retirement
benefits if she declines a reasonable offer of reassignment
that is, inter alia, “within the employee’s commuting area.”
Id. § 8451(a)(2)(A)(ii).
As is evident from the text of the two provisions, an
employee’s ability to commute is only mentioned in
§ 8451(a)(2)(A)(ii), the provision concerning an employee’s
refusal of a reassignment position. That is, despite using
some of the same language in framing the disability retire-
ment benefits inquiry, only § 8451(a)(2)(A) references the
employee’s ability to commute. That explicit inclusion in
the refusal of a reassignment provision indicates that Con-
gress intended to exclude considerations of the ability to
commute in generally defining whether an employee can
“render useful and efficient service,” and is thus disabled,
under § 8451(a)(1)(B). Russello, 464 U.S. at 23 (“We refrain
from concluding . . . that the differing language in . . . two
subsections has the same meaning in each.”). Chafin
points to nothing in the text, structure, or history of the
provisions that suggests otherwise. Accordingly, the Board
correctly refused to consider Chafin’s inability to commute
in concluding that she was not unable to render useful and
efficient service.
We note that we are sympathetic to Chafin’s situation.
But the relevant provision, § 8451(a)(1)(B), as explained
above, does not provide for accommodation based on
Chafin’s inability to commute due to economic circum-
stances or proximity to her job.
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CHAFIN v. OPM 7
B
We next turn to Chafin’s fact-based argument that the
determination that she was not unable to render useful and
efficient service was otherwise not adequately supported.
Chafin specifically points to the “Agency Certification of
Reassignment and Accommodation Efforts” form that was
submitted to OPM in her application for disability retire-
ment benefits. J.A. 58. In that form, her supervisor
checked a box stating that “the medical evidence presented
to the agency shows that accommodation is not possible due
to the severity of the medical condition and the physical re-
quirements of the position.” J.A. 58 (emphasis added).
Based on that statement from her supervisor opining that
she could not perform the duties required of an OST,
Chafin asserts that it was “clear that [her] medical condi-
tion” caused her to be unable to “render useful and efficient
service,” and therefore the Board erred in finding other-
wise. Open. Br. 10.
But Chafin concedes that this is a fact-based argument
beyond our review. Reply Br. 1–2 (acknowledging
§ 8461(d) precludes review of factual determinations un-
derlying the denial of a physical disability). We are there-
fore statutorily barred from considering this argument
because it is a request to reconsider a factual matter relat-
ing to OPM’s determination that Chafin was not physically
disabled. 5 U.S.C. § 8461(d); Anthony, 58 F.3d at 626. Only
the Board can review such matters. 5 U.S.C. § 8461(d); An-
thony, 58 F.3d at 625.
CONCLUSION
We have considered Chafin’s remaining arguments but
find them unpersuasive. For the foregoing reasons, we af-
firm.
AFFIRMED