Wisconsin Personnel Commission's             Digest of Decisions        March, 1999 Version

Sections 102.08 through 102.16

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102.08 Early filing

Where appellants filed an appeal prior to receiving written notice of their reclassification, any procedural defect was cured when they reaffirmed at the prehearing conference that they wished to continue to contest the effective date of their reclassification. Mayer et al. v. DHSS & DER, 95-0002-PC, 7/24/95

In an appeal of the effective date of appellants' reclassification, the fact that the appellants had filed their appeal prior to both the date of the written notice and the effective date of the action did not deprive the Commission of subject matter jurisdiction. Any jurisdictional defect caused by the premature filing was cured when appellants subsequently received written notice of the effective date and they notified the Commission that their third step grievance had been denied and they wished to proceed with their appeal. Heath & Mork v. DOC & DER, 93-0143-PC, 6/23/94

Appellant failed to file any appeal of a reallocation following a survey, but subsequently requested a review of the classification level of his position. Respondent DOT replied that it would review the class level of his position in the context of reviewing a number of positions in the aftermath of the survey. Approximately two years after filing his request, respondent DOT had made no decision thereon and appellant filed an appeal withe the Commission. This appeal was untimely, because it was more than 30 days after the reallocation, and respondent DOT had not yet rendered an appealable decision on his request for classification review. While appellant could attempt to appeal a decision on that request, the current appeal must be dismissed. Mueller v. DOT & DER, 93-0030-PC, 6/23/93

The appellant's statement, made at the prehearing conference, that she was contesting the hiring procedure used to fill a particular vacant position constituted an amendment of her original letter of appeal which alleged that respondent's decision not to select the appellant for the position was flarbitrary, capricious and discriminatory", and the amendment related back to the date of the original filing. Larson v. DILHR, 86-0013-PC, 6/12/86

Where an employe alleged that his position was classified as Storekeeper 1 and that he was being required to perform Motor Vehicle Operator I duties and alleged that he might be "demoted" to the latter classification, the Commission held that no appealable demotion had occurred and there was no other basis of jurisdiction. Helm v. UW, 81-65-PC, 10/21/81


102.09 Relation back of amendment or of appeal to prior complaint

In an appeal of the effective date of appellants' reclassification, the fact that the appellants had filed their appeal prior to both the date of the written notice and the effective date of the action did not deprive the Commission of subject matter jurisdiction. Any jurisdictional defect caused by the premature filing was cured when appellants subsequently received written notice of the effective date and they notified the Commission that their third step grievance had been denied and they wished to proceed with their appeal. Heath & Mork v. DOC & DER, 93-0143-PC, 6/23/94

Appellant's appeal of an August, 1990 negative employment reference was untimely filed where it was not filed within 30 days of the date of the reference and the claim did not arise out of the same occurrence or transaction set forth in a discrimination complaint appellant had filed in 1989. The negative reference was a discrete action which, in order to be cognizable under §230.44(1)(d), was required to have been the subject of a specific filing with the Commission, either as an original complaint, as an amendment to an original complaint, or as a separate appeal within 30 days of its occurrence. Seay v. DER & UW-Madison, 89-0082-PC-ER, 92-0855-PC, 3/10/93

Appellant was permitted to amend a discrimination complaint to state a civil service appeal that ran against a party not named in the original complaint and to have the amendment relate back to the date of filing of the original complaint where there was no specific showing of prejudice to a respondent and were no circumstances from which prejudice could be inferred. The requirements of §802.09(3), did not apply to the Commission's processes. Lipford v. DER & UW, 91-0118-PC, 7/22/92

Appellant was permitted to amend her equal rights complaint, which contested a reallocation decision, to include a civil service appeal of the same decision. Lipford v. UW & DER, 91-0118-PC, 12/23/91

Because a document, viewed as a proposed amendment, contained an additional allegation (lack of just cause) which was related to the subject matter of a previously filed charge (an allegedly discriminatory discharge), it was an appropriate amendment and related back to the original date of filing. Schilling v. UW-Madison, 90-0064-PC-ER, 9/19/90

An amendment relates back to the date of filing of the original pleading if the claim asserted in the amendment arises out of the occurrence or transaction set forth in the original pleading. An amendment was timely where appellant had, on December 7th filed a complaint of discrimination regarding a selection decision on November 12th and where on December 20th, complainant filed an amendment asking that the complaint also be considered as a letter of appeal filed under §230.44(l)(d), Stats. Van Rooy v. DILHR, 84-0253-PC, 4/12/85

Where an appeal was stated to be of a letter of reprimand and the letter informed the appellant of the termination of her probationary employment, the appeal could be amended to clearly state that the termination was being appealed and the amendment would relate back to the time that the original appeal was filed. Fisk v. DOT, 79-83-PC, 1/23/80


102.10 Equitable estoppel as to issues of timeliness (see also 522.05)

It is appellant's burden of proof to show that he was misled by respondent regarding his appeal rights. The nature of the actual statement made is critical to an equitable estoppel analysis, as are the name and position of the person who responded to appellant's inquiries. Livingston v. DOT, 98-0001-PC, 4/8/98

Under certain circumstances, a failure to comply with §230.44(3) will not be fatal to an employe's ability to pursue an appeal. The most common circumstance leading to this result is when an agency responsible for the personnel transaction in question misleads the employe as to the nature of his or her appeal rights, and the employe, reasonably relying on this information, fails to file a timely appeal. Austin-Erickson v. DHFS & DER, 97-0113-PC, 2/25/98

A person in the employing agency who was clearly functioning in a clerical capacity and who offered to do a purely clerical favor, to forward the appeal to the proper place, was not functioning as an arm of the Commission or of the Department of Employment Relations. There was no procedural aspect to the actions of the clerical employe that might place her actions within the scope of an instruction on petitioner's notice of reallocation to contact his agency's Personnel Officer, "If you have any question on the procedural aspects of filing an appeal." Complete reliance such as petitioner gave to the clerical employe was inadequate when working with hard and fast rules and regulatory agencies. Millard v. Wis. Pers. Comm., Dane County Circuit Court, 93CV1523, 1/26/94

Where neither the Commission nor the respondent knew of the existence of this appeal until over a year after it was to have been filed, it could not be said that no prejudice attached. Millard v. Wis. Pers. Comm., Dane County Circuit Court, 93CV1523, 1/26/94

In a layoff appeal, appellant's statement that he was told that "nothing could be done" in response to his question "if there was anything that could be done, and what our rights were" was not inconsistent with a statement to the effect that as of that time there were no positions available into which the appellant could transfer, demote or displace, rather than a statement that appellant had no right to appeal the layoff decision. Based upon this understanding of the context of the information provided by respondent, respondent's misconduct did not cause "a serious injustice" to appellant. In addition, if equitable estoppel was applied, the public's interest would be harmed to the extent that respondent would be required to defend a layoff decision made over two years after the statutory period for obtaining review had ended. Blomquist v. DATCP, 94-1032-PC, 5/26/95

Appellant's reliance on a statement by a receptionist in the DOT personnel office that his appeal would be forwarded to the Commission was not reasonable and justifiable, where appellant was aware of the need for timely filing and understood from the receptionist's comments that the receptionist in effect was making a commitment on behalf of a third person who was on vacation and would not be returning for several days, which was during the period when appellant himself was going on vacation. Millard v. DER, 92-0713-PC, 3/19/93; affirmed, Millard v. Wis. Pers. Comm., Dane County Circuit Court, 93CV1523, 1/26/94

A receptionist in the DOT personnel office was not an agent of DER for purposes of the application of equitable estoppel merely because DER had provided in its notice of reallocation that: [i]f you have any questions on the procedural aspects of filing an appeal, please contact your agency Personnel Officer," and where the appellant asked the receptionist for the Commission's address and she gratuitously offered to have the appeal forwarded to the Commission. Millard v. DER, 92-0713-PC, 3/19/93; affirmed, Millard v. Wis. Pers. Comm., Dane County Circuit Court, 93CV1523, 1/26/94

Whether or not actions of respondent led appellant to cease actively pursuing a matter, where any such reliance could not have occurred until after the 30 day filing period had already expired, equitable estoppel would not lie. Hallman v. WCC & DOA, 96-0146-PC, 2/12/97

It was not reasonable to rely on the statement by an employe of appellant's employing agency's administrative services section that appellant had properly addressed his reallocation appeal letter where the employe was neither the person identified in the reallocation notice as being able to answer questions on the procedural aspects of filing an appeal, nor was the employe employed by the Department of Employment Relations, where it was undisputed that the underlying action of reallocating the appellant's position was taken by DER. Kenyon v. DER, 95-0126-PC, 9/14/95

It was not reasonable to rely on the non-action of two of respondent's employes who received appellant's misdirected reallocation appeal just 2 working days before the final day for filing with the Commission and the reallocation notice very clearly stated that the appeal had to be submitted to the Commission. Equitable estoppel did not apply. Kenyon v. DER, 95-0126-PC, 9/14/95

Respondent was equitably estopped from contending that appellant's appeal was filed untimely because it was not filed with, i.e. received by, the Commission within 30 days where it was reasonable for appellant to rely on respondent's letter informing her that she could appeal the hiring decision by merely "writing" to the Commission within 30 days, which she did. Stone v. DHSS, 92-0789-PC, 12/29/92

The right to assert equitable estoppel does not arise unless the party asserting it has acted with due diligence and the conclusion as to whether or not an employe has exercised due diligence is, in part, a function of the nature of the respondent's action. An employe has a substantially greater responsibility to investigate the employer's information or action when the information/action is adverse to the employe's interests. Fletcher v. ECB, 91-0134-PC, 12/23/91

Where the appellant was clearly notified that an adverse personnel action had been taken against him, i.e., that he was not being promoted, and he was told that the reason was that he was keeping book on his co-workers in violation of work rules and he had received two previous written reprimands referencing this conduct, a reasonably prudent employe should have promptly filed an appeal. The appellant was barred from filing an appeal 3 years later after he learned that the promotion decision may have been based upon other factors. Fletcher v. ECB, 91-0134-PC, 12/23/91

Where the appellant failed to provide any evidence that DER has a duty to supply the Commission's address to employes who receive a reallocation notice, the appellant failed to establish the basis for an equitable estoppel theory. Brady v. DER, 91-0085-PC, 9/19/91

Alleged misconduct by DNR cannot serve as the basis for an equitable estoppel theory when it is undisputed that the underlying action of reallocating the appellant's position was taken by DER rather than DNR. In dicta, the Commission also noted that the mere provision of an office directory which included an incorrect address for the Commission cannot be said to amount to fraud or a manifest abuse of discretion. Brady v. DER, 91-0085-PC, 9/19/91

The doctrine of equitable estoppel applied where in the letter informing appellant of the decision to remove him from a register, respondent gave one reason, the appellant then asked respondent for a "full and explicit statement of the exact cause of such refusal" and respondent replied 2 weeks later, when the time for appeal had almost run and gave a different, additional reason with which the appellant took issue. Desrosiers v. DMRS, 87-0078-PC, 8/5/87; motion for reconsideration denied, 9/10/87

The Commission has implicit authority to apply the principle of equitable estoppel in deciding timeliness issues. Desrosiers v. DMRS, 87-0078-PC, 8/5/87; motion for reconsideration denied, 9/10/87

Equitable estoppel did not apply where respondent DER promptly forwarded a misdirected appeal to the Commission and the appeal was received by the Commission after the 30 day period had run. Gensch v. DER, 87-0072-PC, 7/8/87

Equitable estoppel did not lie against respondent where reallocation denial letter was not misleading but had clearly indicated that any appeal should be sent within 30 days to the Personnel Commission and provided the Commission's correct address. Appellant incorrectly sent her appeal to a DER employe at DER's address. Gensch v. DER, 87-0072-PC, 7/8/87

The elements of equitable estoppel were present to prevent respondents from arguing that a hold placed on appellant's reclassification to permit review of a request to create a new classification series could have had no effect on the original decision to reclassify the appellant's position. Kriedeman v. UW & DER, 85-0048-PC, 10/23/85

Respondent DER abused its discretion and was equitably estopped from asserting an objection based on timeliness where the appellant's letter of appeal was addressed to the Commission but listed DER's post office box and where DER failed to forward the letter to the Commission during the two weeks that remained in the 30 day filing period. Toth v. DILHR & DER, 84-0009-PC, 2/29/84

The respondents' argument that equitable estoppel is not available to prevent an allegation of untimely filing under §230.44(3), Stats., because subject matter jurisdiction cannot be conferred by estoppel, was rejected. Ferguson v. DOJ & DP, 80-245-PC, 7/22/81

Where the appellant received information from the agency personnel manager regarding her projected salary for the next year, which, although given in good faith, was erroneous, and this influenced her to decide not to appeal a reallocation, the Commission found that there was no fraud or manifest abuse of discretion on the part of the respondent, and hence equitable estoppel was not present as to the respondent, a state agency. Ferguson v. DOJ & DP, 80-245-PC, 7/22/81

Where the employe relied on information contained in the "Handbook for DILHR Employes" to file a non-contractual grievance and to appeal to the Commission at the fourth step rather than to have appealed directly to the Commission in the first instance, the respondent was equitably estopped from arguing that the appeal should have come directly to the Commission and that the appeal was untimely because it was filed more than 30 days after the original transaction. Newbury v. DILHR, 80-50-PC, 9/23/80

Equitable estoppel against a state agency requires inequitable conduct by the agency which amounts to fraud or a manifest abuse of discretion, and irreparable injury to the other party acting honestly and in good faith reliance on the agency conduct, and equitable estoppel would not be present where the appellant alleged that after having received his exam notice on September 4, 1979, he wrote to the Division of Personnel on September 14th requesting an explanation of the "ambiguity" of his exam grade, eight days later the division phoned him, the possibility of an appeal was discussed and he requested a written confirmation of the conversation, and in a letter dated September 27th, the division quoted §230.44 but did not specify to whom the appeal should be addressed, and thereafter, the appellant wrote to the division on October 2nd requesting a hearing on the entire selection process, by letter of October 4th the division advised that the appeal should be directed to the Commission, and on October 9th he wrote to the Commission requesting a hearing. Schleicher v. DILHR & DP, 79-287-PC, 8/29/80

The Commission found that equitable estoppel applied and declined to accept the respondent's contention that the complainant should have investigated the matter further rather than relying exclusively on the erroneous advice of respondent's employe. Butler et al. v. DILHR & DER, 79-138-PC, 11/8/79


102.11 Continuing violation

A grievance arising from the alleged failure of respondent to grant appellant premium pay for overtime hours he worked in a certain capacity during the period from 1985 to 1991 was timely only with respect to the single instance during which he worked in that capacity within the 30 days prior to filing his grievance. Each of the instances in which appellant was not granted premium pay for working overtime hours represented a discrete and separable transaction, so a continuing violation theory was inapplicable. The Commission went on to dismiss the timely claim because pay issues are non-grievable. Bornick v. DOC, 91-0084-PC, 4/1/92

The Commission declined to apply a continuing violation theory to an appeal of a decision to reduce the appellant's salary soon after his transfer to a new position, citing Junceau v. DOR & DP, 82-112-PC, 6/14/82. The appeal was filed nearly 3 months after the appellant was notified of his new rate of pay. Jacobus v. UW, 88-0079-PC, 10/20/88

An appeal of an attorney regrade computation is not a continuing violation, since there is no ongoing violation but rather the damages are continuing in nature. Junceau v. DOR & DP, 82-112-PC, 10/14/82

As to employe who transferred from DILHR to LIRC in 1977 and filed appeal in September 1978 relating in part to alleged civil service violations by DILHR, appeal is untimely as to DILHR, as against argument of continuing violation, inasmuch as LIRC exercises independent personnel authority and is not a unit of DILHR, and appellant's employment relationship with LIRC ended when she transferred to DILHR, and inasmuch as LIRC is not the successor agency to DILHR commission. Jacobson v. LIRC & DILHR, 78-192-PC, 12/4/79


102.13 Effect of filing grievance (or seeking other internal reconsideration) on the timeliness of subsequent appeal

The filing of a contractual grievance or other misdirected appeal does not toll the running of the time limit. Austin-Erickson v. DHFS & DER, 97-0113-PC, 2/25/98

Respondents' 1993 letters to appellants, which 1) were written decisions issued in response to requests by the appellants, 2) reviewed the classification levels of the appellants' positions, and 3) affirmed the correctness of the original reallocation decisions that had been made effective in 1990 were appealable pursuant to §230.44(1)(b), Stats. The fact that appellants had failed to timely appeal the reallocation decisions in 1990 did not prohibit them from filing timely appeals from the 1993 letters. Vesperman et al. v. DOT & DER, 93-0101-PC, etc., 2/15/94

An appeal of a certification action was untimely where it was filed more than 30 days after the date of the certification and the date the appellant, who was not certified, learned that someone else was appointed to the position. The Commission rejected appellant's contention that she had entered into "negotiations" with respondent to change the decision and that the filing period should be based on the date respondent DOT ceased to offer relief to correct their previous error where the only event occurring within the 30 day period was the appellant's rejection of an earlier proposal by respondent to allow the appellant to interview for the position, distinguishing Adams v. DHSS, 83-0050-PC, 8/17/83, and Schein v. DHSS, 79-370-PC, 5/15/80 Morris v. DMRS & DOT, 90-0232-PC, 11/16/90

The time limit for filing an appeal is not tolled by the employe's pursuit of a non-contractual grievance of the same transaction Cleveland v. DHSS, 86-0133, 0151, 0152-PC, 7/8/87

The reclassification appeal was untimely filed where appellant was denied her Officer 2 rating by memo dated June 7, 1984, she was promoted to Officer 3 on July 22, 1984, she learned in October of 1985 that she might have been eligible to receive her Officer 2 rating on July 18, 1984, four days before she started at the Officer 3 level, and after she was informed by respondent DHSS on November 22, 1985 that her reclass request to Officer 2 was untimely, the appellant filed an appeal with the Commission on December 9, 1985. The adverse decision appellant sought to appeal was the 1984 decision rather than the November 22, 1985 "decision." Although appellant had essentially asked the respondent in October or November of 1985 to reconsider its position on reclassifying the appellant to Officer 2 and to correct its past error, the respondent, on November 22,1985, refused to do so because the time had run for appeal of the earlier decision. LaRoche v. DHSS & DER, 85-0227-PC, 4/30/86

The appeal of a non-selection decision was untimely where it was filed on June 18, the date of notification was April 8, nothing in the record suggested that the effective date was on or after May 19 and the appellant had sought an explanation of the decision from the person who made the decision but had not sought reconsideration by someone with the authority to overturn the selection decision, distinguishing Adams v. DHSS, 83-0050-PC, 8/17/83. Bachman v. UW-Madison, 85-0111-PC, 11/7/85

An appeal was held to be timely filed where it was submitted within 30 days of a letter from respondent secretary to the appellant stating that her review of a non-selection decision indicated the institution had not acted improperly, even though the institution's personnel director had some 45 days before the appeal was filed, advised appellant in writing that he had not been selected. The Commission's decision in Junceau v. DOR & DP, 82-112-PC, 10/14/82 was distinguished. Adams v. DHSS, 83-0050-PC, 8/17/83

An appeal was timely filed within 30 days of the letter notifying appellant of respondent's final decision, where after the first letter (received by appellant more than 30 days before the appeal was filed), the respondent reconsidered its action in light of appellant's inquiry. Stellick v. DOR & DP, 79-211-PC, 4/10/81

Where following notice of her nonappointment, the appellant wrote the respondent requesting directions for appealing the method used to interview her, and the respondent's agent replied in a letter that was not inconsistent with the possibility that the matter was still pending until a future discussion between the parties, the time for appeal did not start to run until the date of that meeting. Schein v. DHSS, 79-370-PC, 5/15/80


102.14 When appellant realizes unfairness

It is the date that notice of the action is received or the effective date of the action, not the date that an affected employe realizes what the consequences of this action will be that determines the date from which the 30 day time lime will be measured. Where appellant received notice by his written performance evaluation that he was no longer being assigned plan review duties, his appeal, in which he contended he had been demoted, filed more than 1 year later was untimely. Appellant filed the appeal only after he was notified that his position had been reallocated based in part on the absence of plan review duties. Meisenheimer v. DILHR & DER, 94-0829-PC, 4/28/95

The time limit for filing an application for benefits under §230.36, Stats., for a hazardous employment injury, is 14 days from the date of the injury, §ER 28.04(1), Wis. Adm. Code. This time limit is in the nature of a statute of limitations rather than a jurisdictional requirement, and does not begin to run until the employe discovers, or should have discovered under an objective standard, the relationship between the injury and his employment. Where the complainant alleges he did not become aware of a possible link between his lung disease and a source of infection among inmates with whom he worked until several months after he became aware of his diagnosis, respondent's motion to dismiss on the ground of untimely filing was denied. Rose v. DOC, 93-0180-PC, 11/30/93

Once the appellant learned he had not been selected to fill certain vacancies, he had an obligation to determine whether the decisions were proper and to promptly file an appeal with the Commission if he wanted to obtain review of the decisions. His appeal, filed nearly 3 years later and resulting from having read a newspaper article regarding personnel disputes within the respondent agency, was untimely. Grimes v. Wis. Lottery, 91-0158-PC, 10/31/91

An appeal of a scope of competition decision was timely, even though it was filed more than one year after the appellant was initially notified of that decision, because an appeal filed within 30 days of the date of notification would have been subject to dismissal for lack of standing in light of the fact that the decision had the effect of including rather than excluding the appellant, who at the time was an employe of DHSS. It wasn't until 1) the appellant transferred to another facility which became part of a different agency upon the subsequent creation of the Department of Corrections as a separate agency and 2) the decision to use the previously established register to fill DOC vacancies that the appellant became adversely affected by the underlying scope of competition decision. The appeal was filed within 30 days of when the appellant was notified of this injury. Augustin v. DMRS & DOC, 90-0254-PC, 11/28/90

The time for an appeal under §230.44(3), Stats., runs from the effective date of the action or the date of notice of the action. This precludes the use of a later date where the appellant learns of something that suggests the action was improper. Even if the principles set forth in Sprenger v. UW-Green Bay, 85-0089-PC-ER, 1/24/86, would be applicable to appeals, the appellant would be charged with the obligation to make inquiry at the time he learned of his nonselection to determine whether respondent had effected the transaction in compliance with the civil service code. Oestreich v. DHSS & DMRS, 89-0011-PC, 9/8/89

Where the appellant was hired in 1970 and allegedly performed supervisory duties continuously while in a non-supervisory classification, until in 1982 when her position was audited and the supervisory duties were removed, an appeal filed in 1982 seeking back pay for supervisory duties performed from 1970 was not timely, as opposed to the appellant's argument that she first received "notice of her misclassification" in 1982, since she had to have had notice of her actual classification, salary, and duties and responsibilities continuously since 1970, and the time for appeal does not begin to run from the date an employe first learns of the alleged illegality of his or her employment status. Cronin v. DHSS, 82-118-PC, 9/23/82

Where the appellants filed an appeal in 1979 with respect to a failure to pay overtime in 1977, and alleged that they were not aware they were aggrieved until after an order by the Commission in a similar case in 1979, the Commission held that the appeal time set forth in §230.44(3), Stats., starts to run from the date of notice of the action, not the date of notice of matters that might lead the appellants to believe that the action was improper, and hence the appeal was not timely filed. Wickman v. DP, 79-302-PC, 3/24/80

Appeal time in §230.44(3), Stats., does not commence from date appellant learns of fact that leads to belief that transaction was unfair. Bong & Seeman v. DILHR, 79-167-PC, 11/8/79

102.15 Failure to appeal subsequent decision

Where appeal was filed on August 11, 1983 alleging, inter alia, that respondents failed to give proper consideration to appellant's qualifications when making selection decisions, and where appellant filed a "more definite statement" on January 9, 1984 alleging, inter alia, that respondent DHSS "ignored" appellant's certification for positions available in June, August and October, 1983, the Commission held that the appeal was not timely as to the October hiring decision because the appellant failed to either file a separate appeal or file an amendment to his pending appeal within 30 days of that decision. Pflugrad v. DER, DHSS & BVTAE, 83-0176-PC, 3/29/84

Where a reallocation to Typist was appealed and a second, unilateral reallocation to Program Assistant was not appealed, this did not deprive the Commission of jurisdiction over the original appeal. (Note: to same effect, see Jensen v. DP, 79-PC-CS-386, 9/26/80) Adkins v. DP, 79-PC-CS-23, 9/25/80


102.16 Effect of statutory period falling on weekend/holiday

Appeals were timely filed on a Monday where the 30th day of the 30 day period fell on the preceding Sunday. §990.001(4)(b), Stats. Starczynski & Mayfield v. DOA, 81-275, 276-PC, 12/3/81

Pursuant to §990.001(4)(c), Stat., where the 30th day for filing an appeal was a Saturday, the appeal was timely when received the following Monday. Cirilli & Jones v. DP, 81-39-PC, 4/10/81


While this digest has been prepared by Personnel Commission staff for the convenience of interested persons, it should be remembered that the decisions themselves are the ultimate source of Commission precedent.

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