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AF | BCMR | CY2013 | BC 2013 05059
Original file (BC 2013 05059.txt) Auto-classification: Approved
RECORD OF PROCEEDINGS
AIR FORCE BOARD FOR CORRECTION OF MILITARY RECORDS


IN THE MATTER OF:	DOCKET NUMBER:  BC-2011-05059

			COUNSEL:  

			HEARING DESIRED:  YES


________________________________________________________________

APPLICANT REQUESTS THAT:

Her records be corrected to show she was continued on active 
duty for the period 1 Oct 10 to 11 Dec 11, she receive all back 
pay, allowances, and benefits to which she would have been 
entitled.

________________________________________________________________

APPLICANT CONTENDS THAT:

On 20 Sep 10, she invoked sanctuary pursuant to Title 10 U.S.C, 
§12686 and should have been entitled to remain on active duty 
until she was eligible for retirement; however, her request was 
wrongfully ignored and denied a year later.  At the time she 
invoked sanctuary she had been on continuous orders since 2003.  
She initially signed a sanctuary waiver on 5 Oct 09 that was 
voided because it exceeded 179 days and did not contain the 
required waiver statement.

However, due to the initial confusion as to whether her National 
Guard unit or the gaining agency was responsible to process the 
request, there were inordinate delays.  On 23 Nov 10, she 
submitted a request for resolution to the state National Guard, 
only to be notified on 16 Dec 10 that that the agency who 
afforded her the tour that took her into sanctuary was 
responsible for resolving the situation.

In Sep 11, the Colonel’s Group determined that she was indeed 
entitled to be retained on active duty under the provisions of 
sanctuary until she was eligible for retirement and offered her 
an active duty deployment.  However, at the same time, the Judge 
Advocate General (JAG) requested resolution to this matter 
directly from the Secretary of the Air Force (SECAF).  On 
4 Oct 11, the SECAF determined she had obtained sanctuary status 
as a result of error and directed her release from active duty.  

Such action was inappropriate and erroneous and resulted in her 
release from active duty without due process.  As the action 
resulted in her being without active orders for over a year, 
causing her an extreme financial hardship, she is also the 
victim of an injustice.
The applicant’s complete submission, with attachments, is at 
Exhibit A.

________________________________________________________________

STATEMENT OF FACTS:

The applicant was a member of the Arizona Air National Guard 
(ANG) and was ordered to active duty on 31 Mar 03.  She served 
on a variety of consecutive tours of active duty, which resulted 
in her serving on active duty continuously until the matter 
under review.

Title 10 U.S.C, §12686(a), also known as “Sanctuary,” provides 
that under regulations to be prescribed by the Secretary 
concerned, a member of a reserve component who is on active duty 
(other than for training) and is within two years of becoming 
eligible for retired pay or retainer pay under a purely military 
retirement system, may not be involuntarily released from that 
duty before he/she becomes eligible for that pay, unless release 
is approved by the Secretary.  

Title 10 U.S.C, §12686(b), provides that the Secretary concerned 
may require a member to waive their right to invoke the 
provisions above when performing a period of duty of less than 
180 days as a condition of such order to active duty.

On 5 Oct 09, the applicant initiated a waiver of her rights to 
invoke the provisions of sanctuary for the period 1 Oct 09 
through 30 Sep 10, a period of one year.

On 20 Sep 10, the applicant invoked her right to retention under 
the provisions of sanctuary, indicating, in part, that the 
waiver she signed on 5 Oct 09 was legally ineffective as the law 
precluded such a waiver from being executed on periods of active 
duty of 180 days or more.

On 30 Sep 10, the applicant was released from active duty and, 
according to information extracted from the Military Personnel 
Data System (MilPDS), she was credited with 18 years, 8 months, 
and 23 days of active service as of the date of her release from 
active duty."

On 23 Nov 10, the applicant requested resolution to her 
sanctuary issue through Arizona National Guard officials.

On 2 Dec 10, the Adjutant General, Arizona National Guard, 
responded to the applicant’s request for sanctuary indicating 
that such a request fell under the purview of the agency that 
afforded the applicant the active duty tour in question.

On 5 Oct 11, SAF/JAR notified the applicant of the Secretary’s 
determination that she should be released from active duty, 
indicating the applicant obtained retention under the provisions 
of sanctuary as the result of an error and therefore approved 
her release from active duty.  Notwithstanding this decision, 
the Secretary directed that the applicant be afforded 
opportunities for future Title 10 service.

On 1 Mar 13, the applicant was retired and credited with 
20 years and 17 days of active service.

The remaining relevant facts pertaining to this application are 
contained in the letters prepared by the appropriate offices of 
the Air Force, which are attached at Exhibits C and D.

________________________________________________________________

AIR FORCE EVALUATION:

NGB/A1P recommends denial of the applicant’s request for back 
pay and entitlements.  While there was confusion and delay 
regarding the applicant’s claiming sanctuary, she was eventually 
able to obtain the days needed to qualify for active duty 
retirement. 

A complete copy of the NGB/A1P evaluation is at Exhibit C.

SAF/GCI notes on 20 Sep 10, the applicant invoked sanctuary 
under Title 10 U.S.C, §12686(a).  At the time of her request for 
sanctuary, she was on active duty orders for 365 days.  Prior to 
being issued said orders, the applicant signed a waiver waiving 
her rights to claim sanctuary.  She was released from active 
duty upon the expiration of her orders.  However, her waiver was 
deemed invalid due to her orders exceeding 179 days.  On 
4 Oct 11, the SECAF approved the applicant’s release from active 
duty.  On 12 Dec 11, the applicant once again began serving on 
active duty until she obtained 20 years of service for an active 
duty retirement.  She retired on 1 Mar 13.

The applicant was properly released from active duty on 4 Oct 11 
and is not entitled to back and entitlements for the time period 
between that release and her return to active duty on 11 Dec 11.  
However, an error occurred when the applicant was released from 
active duty on 1 Oct 10, and because she invoked sanctuary, her 
records should be corrected to reflect she remained on active 
duty from 1 Oct 10 through 4 Oct 11.

A complete copy of the SAF/GCI evaluation, with attachment, is 
at Exhibit D.

________________________________________________________________

APPLICANT'S REVIEW OF AIR FORCE EVALUATION:

Counsel indicates that it has been acknowledged that the 
applicant was on active duty in sanctuary from 1 Oct 10 to 
4 Oct 11 with entitlement to pay and allowances for that period.  
Therefore, the issue of whether the Secretary acted within the 
law by releasing the applicant from active duty involuntarily 
three months prior to her becoming eligible for retirement needs 
to be resolved. 

The advisory writer is correct that under the provisions of 
10 U.S.C. §12686(a) a service member who has invoked sanctuary 
“may not be involuntarily released from active duty before they 
become eligible for retired pay unless the Secretary approves 
the release.”  The statute also states the Secretary is to 
prescribe the regulations under which he has authority to act 
pursuant to the law.  Under the provisions of AFI 36-2131, 
Administration of Sanctuary in the Air Reserve Components, a 
service member on active duty that asserts sanctuary must be 
retained on active duty unless they are voluntarily separated, 
medically disqualified for continued service, or is 
separated/discharged for cause.  In effect, the Secretary 
determined he can only involuntarily release a service member 
who has invoked sanctuary, is medically qualified and wants to 
continue to serve for cause.

The Secretary cited error as the basis for the applicant’s 
release from active duty, however; under AFI 36-2131 error is 
not a basis for release from active duty.  The Secretary was not 
acting under the regulation he prescribed when he released the 
applicant involuntarily without cause in Oct 11.  Furthermore, 
the applicant was not afforded any due process in relation with 
her involuntary release from active duty.  The Secretary acted 
outside the purview of his authority when he involuntarily 
released the applicant from active duty on 4 Oct 11.

While SAF/GC recommends the applicant be credited with active 
duty service, with pay and entitlements for the period 1 Oct 10 
through 4 Oct 11, Counsel states the applicant should also 
receive credit for active duty with full pay allowances for the 
period 5 Oct 11 to 11 Dec 11.

Counsel’s complete response is at Exhibit F.

________________________________________________________________

THE BOARD CONCLUDES THAT:

1.  The applicant has exhausted all remedies provided by 
existing law or regulations.

2.  The application was timely filed.

3.  Sufficient relevant evidence has been presented to 
demonstrate the existence of an error or injustice warranting 
partial relief.  The applicant contends that she was erroneously 
released from active duty on 1 Oct 10, despite properly invoking 
her right to retention on active duty under the provisions of 
the law commonly known as “Sanctuary” when it was determined 
that the waiver of her right to retention was legally 
ineffective.  After a thorough review of the evidence of record 
and the applicant’s complete submission, we agree.  In this 
respect, we note the comments of SAF/GC indicating that an error 
occurred when the applicant was released from active duty on 
30 Sep 10, despite invoking her right to retention under 
Sanctuary on 20 Sep 10.  Instead, she should have been retained 
on active duty until she qualified for retirement under the 
provisions of 10 USC 12686(a), unless said release was approved 
by the Secretary concerned.  However, in our view, once the 
Secretary determined that she should be released from active 
duty on 1 Oct 11, she was no longer entitled to be retained on 
active duty until qualifying for retirement.  While Counsel 
argues the Secretary acted outside his authority as prescribed 
in AFI 36-2131, Administration of Sanctuary in the Air Reserve 
Components, because the applicant was not released from active 
duty voluntarily, medically disqualified for continued service, 
or separated/discharged for cause, we are not convinced the 
Secretary acted outside his authority when he directed the 
applicant be released from active duty on 1 Oct 11.  In this 
respect, we note that while the applicant was not released from 
active duty for these three noted exceptions to the protections 
provided by 10 USC §12686(a), the governing instruction in no 
way limits the Secretary’s authority to release a member from 
active duty who has attained sanctuary for another reason.  In 
this respect, we note that that AFI 36-2131, paragraph 1.1, 
indicates that in general (emphasis added), Active Duty 
sanctuary means any Air National Guard (ANG)/United States Air 
Force Reserve (USAFR) officer/enlisted member who attains 18 
(but less than 20) years of AD must be retained on active duty 
unless he/she: voluntarily separates; is medically disqualified 
for continued service; or is separated or discharged for cause.  
Therefore, while Counsel’s arguments on this point are duly 
noted, we are not convinced that the Secretary acted outside his 
authority when he directed the applicant be released from active 
duty on 1 Oct 11.  We note the applicant was able to 
subsequently qualify for an active duty retirement shortly after 
the events in question and therefore are not convinced that 
granting relief beyond that being recommended is in the interest 
of justice.  Therefore, we recommend the applicant’s records be 
corrected to the extent indicated below.

4.  The applicant’s case is adequately documented and it has not 
been shown that a personal appearance with or without counsel 
will materially add to our understanding of the issues involved.  
Therefore, the request for a hearing is not favorably 
considered.

________________________________________________________________

THE BOARD RECOMMENDS THAT:

The pertinent military records of the Department of the Air 
Force relating to the APPLICANT be corrected to show that she 
was not released from active duty on 30 September 2010, but on 
that date, she continued to serve on active duty until 4 October 
2011, when her release from active duty was approved by the 
Secretary of the Air Force. 

________________________________________________________________

The following members of the Board considered AFBCMR Docket 
Number BC-2013-05059 in Executive Session on 14 Oct 14, under 
the provisions of AFI 36-2603:

	Mr., Panel Chair
	Mr., Member
	Mr., Member

All members voted to correct the records, as recommended.  The 
following documentary evidence was considered:

	Exhibit A.  DD Form 149, dated 24 Oct 13, w/atchs.
	Exhibit B.  Applicant's Master Personnel Records. 
	Exhibit C.  Letter, NGB/A1PP, dated 29 Jan 14.
	Exhibit D.  Letter, SAF/GCI, dated 23 Jun 14, w/atch.
	Exhibit E.  Letter, SAF/MRBR, dated 25 Jun 14.
	Exhibit F.  Letter, Counsel, dated 16 Jul 14.


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