Search Decisions

Decision Text

CG | BCMR | Advancement and Promotion | 2007-195
Original file (2007-195.pdf) Auto-classification: Denied
DEPARTMENT OF HOMELAND SECURITY 

BOARD FOR CORRECTION OF MILITARY RECORDS 

 
Application for the Correction of 
the Coast Guard Record of: 
 
                                                                                BCMR Docket No. 2007-195 
 
xxxxxxxxxxxxxxxxxxx 
xxxxxxxxxxx, LTJG (former) 
   

FINAL DECISION 

 

 
 

 

This proceeding was conducted according to the provisions of section 1552 of title 10 and 
section 425 of title 14 of the United States Code.  The Chair docketed the case on August 24, 
2007, upon receipt of the completed application, and assigned it to staff member J. Andrews to 
prepare the decision for the Board as required by 33 C.F.R. § 52.61(c). 
 
 
appointed members who were designated to serve as the Board in this case. 
 

This final decision, dated December 17, 2008, is approved and signed by the three duly 

APPLICANT’S REQUEST 

 
 
The applicant, who was relieved of command of a patrol boat, the CGC XXXX, on April 
4,  2007,  asked  the  Board  to  correct  his  record  by  (1)  expunging  any  and  all  documentation 
referring to special board proceedings and the delay of his promotion to lieutenant (LT), includ-
ing memoranda dated May 2 and June 14, 2007; (2) vacating or overruling the special board pro-
ceedings  as  moot;  (3)  removing  his  special  officer  evaluation  reports  (OERs)  for  the  periods 
January 26 to 27, 2007 (OER1) and April 26, 2006, to April 4, 2007 (OER2);1 (4) promoting him 
to LT  immediately; (5) backdating his LT date of rank to May 21, 2007; and (6) awarding him 
back pay and allowances.   
 

                                                 
1 The applicant requested the removal of these OERs on February 25, 2008, several months after his application was 
docketed.  In accordance with 33 C.F.R. §§ 52.26(a)(3) and (c), the Chair advised the applicant that he could amend 
his request for relief but that the ten-month deadline for a decision in his case would be extended as if his case had 
been docketed on February 25, 2008.  She also informed him that his new request would be submitted to the Coast 
Guard  for  further  review,  since  the  Coast  Guard  had  just  issued  its  advisory  opinion  when  the  applicant’s  new 
request for relief was received.  In response to the new request for relief, on July 8, 2008, the Coast Guard issued a 
supplemental advisory opinion, which was sent to the applicant on July 9, 2008.  The applicant, having previously 
been granted an extension of the 30-day period for response, responded to both advisory opinions on August 26, 
2008. 

SUMMARY OF THE RECORD 

 
 
On May 21, 2003, upon graduating from the Coast Guard Academy, the applicant was 
appointed an ensign.  After spending the summer as a cadet platoon officer at the Academy, he 
was assigned to a medium endurance cutter as a deck watch officer (DWO).  On his first OER in 
this assignment, the applicant received marks2 of 4 and 5 in the various performance categories, 
a mark in the 5th spot on the Comparison Scale,3 and the comment that he was “[o]n track & 
highly  recommended  for  promotion  to  LTJG  w/  peers.”    On  his  second  OER  as  a  DWO,  the 
applicant received marks of 5 and 6 in the performance categories, a mark in the 5th spot on the 
Comparison Scale, and the comment that he was “[d]eserving of forthcoming promotion to O-2, 
on track for continued promotion with peers.”  He was promoted to LTJG/O-2 on November 21, 
2004.  On this third OER as a DWO and his first as an LTJG, the applicant received primarily 
marks of 6 in the performance categories, a mark in the 5th spot on the Comparison Scale, and 
the comment that he was “on track for continued promotions with the best of his peers.”   
 

From May 2005 to early June 2006, the applicant served as the Executive Officer (XO) of 
a patrol boat stationed in a combat zone.  On his two OERs in this billet, which together cover 
his service from February 1, 2005, to April 25, 2006, the applicant received primarily marks of 5 
and 6, marks in the 5th spot on the Comparison Scale, and the comment that he was “[h]ighly 
recommended for promotion [with] peers.”  He also received his commanding officer’s recom-
mendation for command afloat on a patrol boat.   

 
According to the applicant’s DD 214, upon returning stateside, he attended two weeks of 
“Prospective CO” training and a week of “Antiterrorism/Force Protection” in June 2006 and a 
week of DWO renewal training in July 2006. 
 
 
On  July  17,  2006,  as  a  26-year-old  LTJG,  the  applicant  took  command  of  the  CGC 
XXXX, with a crew of eleven active duty members.  The XXXX’s homeport is Xxx Xxxxxx,  
xxxxx, and it is a subordinate unit of Sector Xxxxxxx within the  xxxxxx Coast Guard District.   
 

The  applicant  was  selected  for  promotion  by  the  LT  selection  board  that  convened  on 
September 25, 2006, and his name was placed on the promotion year 2007 (PY07) LT promotion 
list, which was subsequently approved by the Secretary on behalf of the President.  As a result of 
this selection and if the applicant’s chain of command had reported no adverse information about 
him, the applicant would have been promoted to LT on May 21, 2007. 
 

In  January  2007,  the  XXXX  entered  drydock  in    xxxxxxx,    xxxxx,  for  regular  main-
tenance and repairs.  On February 2, 2007, the  xxxxxx District Commander sent the applicant a 
memorandum regarding his “Temporary Relief for Cause” as CO of the XXXX, which stated the 
following: 

 

                                                 
2 Coast Guard officers are rated in a variety of performance categories on a scale of 1 (worst) to 7 (best). 
3 The Comparison Scale on an OER form is not actually numbered, but as with the performance categories, there are 
seven possible marks on the Comparison Scale from the 1st (“unsatisfactory”) to the 7th (“a distinguished officer”).  
For ensigns and LTJGs, a mark in the 3rd, 4th, or 5th spot denotes “one of the many competent professionals who 
form the majority of this grade.”  A mark in the 2nd spot denotes merely “a qualified officer.” 

1.  You are temporarily relieved of  your duties as Commanding Officer USCGC XXXX (WPB  
xxxxx) under the provisions of [the Personnel Manual].  I am taking this action based on my loss 
of confidence in your ability to continue to serve in that position.  This request is consistent with 
the Sector Commander’s analysis, input and recommendation. 
 
2.  As detailed in enclosure (1), you have been repeatedly counseled by your Sector Commander 
and his  staff for repeated lapses in judgment and failure to exercise leadership as  Commanding 
Officer of USCGC XXXX.  On 4 Oct 2006, you  were involved in an incident involving a near 
miss with a deep draft vessel that caused your Commander and your Command Cadre to question 
your judgment.  On 16 November 2006, you were involved in an incident responding to a SAR 
case that resulted in significant questions  with regard to  your command judgment.  Due to that 
incident, XXXX was not able to sortie the next day for the SAR case.  You were specifically coun-
seled  by  the  Sector  Commander  with  regard  to  these  incidents.    You  failed  to  respond  to  this 
counseling and again demonstrated poor judgment in failing to keep the Sector properly informed 
with regard to several issues as detailed in enclosure (1). 
 
3.  On 26 January 2007, you departed from USCGC XXXX on leave without leaving a qualified 
person  in  command.    The  person  who  you  assigned  as  Acting  was  not  qualified  to  act  as 
commanding officer and did not know he was the Acting Commanding Officer.  Your response to 
this violation indicated an absence of an appreciation for what it means to be in command.  You 
were slow to return to your unit and have failed to exercise appropriate leadership since returning 
to USCGC XXXX. 
 
4.  You have failed to uphold your leadership responsibilities.  These incidents demonstrate signifi-
cant lapses in judgment, and have posed unacceptable risks to USCGC XXXX and its crew.  Your 
actions have caused me to lose confidence in your ability to continue to serve in the position of 
Commanding Officer of USCGC XXXX (WPB  xxxxx). 
 
5.  You are temporarily assigned to Sector Xxxxxxx while this action pends.  You have the right to 
submit to me a detailed written statement, on your behalf, within five working days of your receipt 
of  this  letter.   You  also  have  the  right  to  consult  legal  counsel.    If  you  desire  to  consult  legal 
counsel, contact … 
 
6.  This action is independent of any potential UCMJ [Uniform Code of Military Justice] action 
that  may  be  taken  based  upon  the  allegations  contained  in  enclosure  (1)  which  are  still  under 
investigation.  
 
On February 15, 2007, the applicant submitted a reply to the notification of his temporary 

relief for cause (RFC).  The applicant stated the following in pertinent part: 

 
2.  Upon taking command my guiding philosophy has been to champion the chain of command to 
create a culture of growth and achievement in the pursuit of operational excellence.  In short, if it 
wasn’t prohibited, improved morale, maintained discipline and accomplished the mission, I’d do 
it. 
 
3.  I recognized that creating a culture that valued initiative and innovation would be particularly 
challenging as I was not collocated with my Sector.  I initiated command-concern updates monthly 
through my entire chain of command to the Sector Commander, and weekly through the Response 
Chief to overcome that challenge.  Immediate feedback I received indicated those updates were 
not  appropriate  for  the  Sector  Commander.    In  person  feedback  I  received  from  the  Response 
Department indicated those emails weren’t helpful, so I stopped. 
 
4.  XXXX’s decline in non-emergent communication with her Sector continued through my seven-
month tour.  Sector’s  weekly release of the  Command Snapshot, an overview of  highlights and 
upcoming events in our area of responsibility stopped.  Highly anticipated Commanding Officer’s 

conferences  turned  into  a  forum  for  staff  presentations,  and  much  needed  lessons  learned  from 
major  evolutions  like  hurricane  evasion  and  a  cruise  ship  bomb  scare  were  never  promulgated.  
Despite  my  sense  that  performance  could  be  measured  by  silence,  I  had  improvements  I  felt 
obligated to make. 
 
5.    By  engaging  my  Sector  supervisors  in  person,  we  reviewed  old  policy  to  improve  cutter 
employment  standards.    Our  efforts  ultimately  overcame  the  unsustainable  and  frequent  shifts 
between police-station model to fire-station model operations that were stifling morale, undermin-
ing efficiency and jeopardizing cutter performance.  Our efforts realized over 5 weeks of motor-
lifeboat SAR coverage without degrading XXXX’s readiness or mission effectiveness. 
 
6.  Operating under the premise that a $5M asset should be operated with $5M worth of effort, I 
corrected cutter practices that were out of compliance with Commandant Instructions.  Those cor-
rections resulted in XXXX only logging underway hours when underway and only sailing with an 
operational communications suite.  Additionally, by instituting the practice of realistic training, my 
crew was not just minimally qualified to do their job, but trained to meet that high level of per-
formance we’ve come to expect of our cutter fleet.  Their performance is documented in XXXX’s 
after-action report of the nighttime interdiction and repatriation of 23 migrants … 
 
7.  I believe I have arrived at this point because my failure to fully recognize that communication 
was my chief challenge.  I continually struggled with performance challenges amongst my com-
mand cadre.  My personal problems unavoidably filled the communication void and my supervi-
sors recognized  my attempt to take on command alone.  While I  was initially  grateful for their 
effort to  mentor, coach and protect me, I quickly became  defensive to the  new oversight as the 
boundaries blurred with their role as supervisors.  Sector queries and my ego met with increasing 
amperage until our working relationship collapsed. 
 
8.  I appreciate the opportunities the Coast Guard has provided me, and the level of responsibility 
it has afforded me this early in my career.  I’m particularly grateful for the experience of working 
with truly incredible officers whose influence has taught me to fear mediocrity, base initiative on 
innovation and the privilege of public service.  I would like nothing more than to apply the lessons 
I learned from my 7 months in command and the last 2 weeks debriefing it, towards continued ser-
vice. 
 
On February 28, 2007, the applicant was taken to mast by the Sector Commander and 
awarded a Punitive Letter of Admonition as non-judicial punishment (NJP) for two violations of 
Article 92 of the UCMJ (dereliction of duty and failure to obey an order) committed on January 
26 and 27, 2007.  The Punitive Letter of Admonition, which was entered in the applicant’s record 
as  an  attachment  to  OER1,  and  was  delivered  to  the  applicant  on  March  2,  2007,  states  the 
following: 
 

1.  In accordance with [Article 15, UCMJ, which concerns NJP; Article 1.E.2.a. of the Military 
Justice Manual; and Article 8.E.2. of the Personnel Manual], you are hereby ADMONISHED for 
your conduct on 25 and 26 January 2007 at  xxxxxxx,  xxxxx.  You were derelict in your duties as 
Commanding Officer of USCGC XXXX when you left the cutter on leave and in the absence of 
the  Executive  Petty  Officer  (XPO)  or  any  other  person  qualified  and  properly  designated  to 
assume Command.  You also failed to obey an order to promptly return to the cutter and resume 
Command.  By your actions, you placed the cutter and crew in jeopardy and you failed to fulfill 
your duties and responsibilities as Commanding Officer. 
 
2.  You are advised of your right to appeal to Commander,  xxxxxx Coast Guard District in accor-
dance with [Article 1.F. of the Military Justice Manual]. 
 

On March 1, 2007, the applicant’s Supervisor notified CGPC-opm in an email that Sector 
Xxxxxxx “believe[s] that the PERSMAN requires that the promotion (May 2007) of [the appli-
cant] be delayed due to  imposition of NJP until his record can be  reviewed by CGPC (opm).  
Yesterday, [the applicant] went to mast.  He was found in violation of Article 92 – Dereliction of 
Duty and Article 92 – Failure to Obey an Order.  He was awarded a Punitive Letter of Admoni-
tion.  Our plan is to allow him his five days to file an appeal if he chooses to.  Assuming no 
appeal is entered, we will prepare a recommendation to the District Commander for a PRFC at 
that time.”  The Supervisor also acknowledged that the Sector needed to prepare a special OER 
to document the NJP and a derogatory OER “[o]nce RFC becomes permanent.” 

 
On  March  9,  2007,  the  District  Commander  notified  the  applicant  that  he  was  recom-
mending to Commandant that the applicant be permanently relieved for cause.4  On March 16, 
2007, the applicant submitted a reply to the Commandant through his chain of command, stating 
the following: 

 
1.    I  have  reviewed  [the  temporary  and  permanent  RFC  notification  letters]  and  would  like  to 
respond to the stated grounds for my permanent relief for cause recommendation.  [The District 
Commander] asserts that I’ve 1) continually made unsound operational and administrative deci-
sions despite repeated counseling, 2) ignored the advice of my Engineering Petty Officer, and 3) 
failed to follow the advice of my chain of command.  I disagree with the District Commander’s 
analysis  and  respectfully  request  that  you  review  this  letter,  the  above  references  and  all  their 
enclosures before making a final decision to permanently relieve me for cause.  I understand the 
basis for my temporary relief for cause, but I believe a permanent relief for cause is an extreme 
measure not suitable  under these circumstances.  I respectfully request instead to be transferred 
and given an opportunity to put into practice the lessons I have learned from this situation. 
 
2.  I am not aware of the repeated counseling sessions cited in the [temporary and permanent RFC 
notifications].  There were a number of brief conversations I had with the Sector Commander and 
his senior staff that took place to clarify facts.  I did not realize these were intended to be counsel-
ing sessions.  Had I realized these conversations were indeed counseling sessions, I would have 
responded  accordingly  without  question.    I  appreciate  that  regardless  of  my  understanding,  I 
should have been  more attentive.  However, I do not believe that this is a basis to permanently 
relieve me. 
 
 
a.    I  met  the  Sector  Senior  Staff  on  9  Nov  to  discuss  administrative  errors  I  made 
handling a good order and discipline issue of a non-rate.  My sense from that meeting was I’d lost 
my Deputy’s confidence and severely shaken the Response Chief’s.  Before departing, I met with 
the Sector Commander who reassured me of his confidence in my ability to command.  He also 
mentioned if I was guilty of anything it was being overzealous in handling a good order and disci-
pline issue. 
 
 
b.  I met with the Sector Commander again on 14 Dec when he informed me my Chiefs 
had informed him, through the Sector Command Senior Chief, that I’d hazarded XXXX on two 
separate occasions.  The Sector Commander informed me he ordered an administrative investiga-
tion into the M/V KYRIAKOULA incident but thought the F/V BIGGINS case was a non-issue.  
He also told me he was particularly concerned as my Chiefs (XPO/EPO) went around me, and if 
their allegations didn’t have merit it would constitute insubordination.  He also told me he’d be 
issuing me a letter of censure to “cover himself,” which I fully appreciated.  I realized at that point 
I’d lost my Sector Commander’s confidence in my ability to command. 

                                                 
4  No  copy  of  this  March  9,  2007,  permanent  RFC  recommendation  notification  appears  in  the  record,  but  the 
applicant referred to it repeatedly in his reply to Commandant. 

 
 
c.  That day I also met with the Deputy and Response Chief.  I told them of my reluctance 
to address my Chiefs’ insubordination due to the perception of reprisal, especially amidst an ongo-
ing investigation.  I was unable to ever address this insubordination as the investigation was com-
pleted the day my XPO departed for CPO academy and XXXX’s departure for drydock, where I 
was relieved. 
 
 
d.  The 4 Jan counseling I had with the Sector Commander lasted 2 minutes.  Though the 
M/V KYRIAKOULA investigation was not yet complete, I received the letter of censure including 
inaccurate  findings  of  that  investigation.    The  counseling  ended  when  I  told  the  Sector  Com-
mander I was concerned with factual discrepancies throughout the letter.  I was contacted by the 
Response Chief and told to provide an email addressing the factual discrepancies which would be 
filed with the letter of censure.  I also spoke separately with the Deputy about my suggestion that I 
draft a formal reply addressing the discrepancies.  She convinced me it was not worth the effort 
and instead to move forward.  For that reason I discounted the contents of the letter of censure and 
the  counseling  I  received  by  the  Sector  Commander,  understanding  the  purpose  of  both  was  to 
“cover” the Sector Commander. 
 
 
e.    The  24  Jan  counseling  I  had  with  my  Sector  Commander  was  part  of  our  weekly 
leadership discussion.  In that phone conversation he told me the M/V KYRIAKOULA investiga-
tion  was  complete  and  it  revealed  the  incident  wasn’t  nearly  as  concerning  as  he  was  led  to 
believe.  He also said he would be issuing me an action memo instructing me to do some things he 
knew I’d already done, including updating the CORM, verifying navigation standards and verify-
ing  log  requirements  as  they  were  completed  after  the  M/V  KYRIAKOULA  incident.    I  really 
didn’t  receive  that  final  action  memo  until  after  I  was  relieved;  however  I  did  take  that  24 Jan 
conversation as renewed validation of his confidence in my ability to command. 
 
3.  My perception of how I responded to the advice of my Engineering Petty Officer (EPO) is not 
the same as the District Commander’s.  My decisions executing the F/V Biggins SAR case on 16 
Nov 06 were based entirely on the advice of my EPO.  Only after verifying the cutter’s endurance 
and  consulting  with  the  EPO  did  I  respond.    I  disagree  with  the  assertion  in  [the  notification 
regarding  permanent  RFC]  that  I  moored  with  an  unacceptably  low  fuel  state  contrary  to  an 
expectation managed by Sector, District or Service guidance.  While I requested and received both 
an escort and a 4-hour crew fatigue status in light of XXXX’s extended exposure to an extreme 
sea-state,  it  was  ultimately  the  CAT-IV  casualty  cited  in  [the  notification  regarding  permanent 
RFC] that prevented our protracted participation in this SAR case. 
 
4.  I have never been insubordinate nor questioned my supervisors’ qualifications, even in private.  
If I dissented to a decision, my objection was rare, private and made only once before adopting 
that decision as my own.  While I believe my dissent has been taken as disloyalty, the [enclosures 
to the temporary and permanent RFC notifications], especially those emails written by me, docu-
ment that simply is not the case.  Though the continual criticism of my judgment despite my unit’s 
consistent operational successes over time left me less than receptive to performance feedback, it 
never interfered with my ability to take tasking for action, nor my command responsibility to pro-
vide direct, honest feedback up the chain of command. 
 
5.  I am particularly upset by the suggestion that I refused to take advice.  It was my effort to seek 
advice in handling the insubordination issues challenging XXXX that led to the miscommunica-
tion ultimately resulting in my Letter of Admonition.  The details of that investigation are included 
in enclosure (1) of enclosure (2) of [the notification regarding permanent RFC]. 
 
 
a.  My Sector Commander found I was derelict in not appropriately appointing a member 
to command in my absence, and slow to return to resume command.  While I understand I made 
mistakes in how I handled my departure, and delegated my authority, I assert that I was more in 
command during the 20 hours in question than in  my 2 days onboard (2-4 Feb)  when  I’d been 
unknowingly relieved of command.  This assertion is evidenced by my 1) balancing a dynamic, 

accelerated drydock schedule, 2) a pending Sector-assisted NJP proceeding and 3) providing guid-
ance to my supervisors handling a government vehicle accident, during the 20 hours in question. 
 
6.  It is my sincerest regret that my failure to maintain the confidence in my ability to command 
has  left  XXXX  operationally  ineffective  and  placed  a  tremendous  load  on  the  crew  of  CGC  
XXXXX.  I’m indebted to all the officers that have helped manage the operational load I couldn’t. 
 
7.  I appreciate the time it takes to review  this letter and its references.  While I  wish I  wasn’t 
responsible for taking this time away from the service’s business, I want nothing more than to con-
tinue serving in the Coast Guard and not be permanently relieved for cause. 
 
Disputed OER1, which was prepared in late March 2007, is a special OER covering the 
applicant’s performance during a two-day period from January 26 to 27, 2007.  Block 2 explains 
that  OER1  was  “submitted  under  Article  10.A.3.c.1.b.  due  to  NJP  awarded  for  violation  of 
UCMJ Article (92), Failure to obey an order & Article (92) Dereliction of duty.  Awarded a Puni-
tive  Letter  of  Admonition.”    Most  of  the  performance  categories  in  OER1  are  marked  “not 
observed,” but the rating chain included the following low marks and comments: 
 
2 for “Professional Competence”   

 
[The applicant] was found to have committed a violation of Article 92 of the UCMJ, Dereliction of 
Duty, in that on 26 January  2007 [he] failed to leave USCGC XXXX  under the command of a 
qualified individual in mbr’s absence.  Mbr was also found to have committed a violation of Arti-
cle 92, Failure to Obey an Order, in that after being ordered to return to XXXX by the Chief of 
Response, [he] delayed his return by over 28 hours in violation of that order.  Both of these behav-
iors exhibit performance well below the expectation of professional competence for a cutter Com-
manding Officer. 

 
2s for “Directing Others” and “Teamwork”   

 
2 for “Judgment” 

 

 
Upon [the applicant’s] departure from USCGC XXXX at the Master Marine shipyard in  xxxxxxx, 
xx on 26 January 2007, mbr released a CO departure message in CGMS listing a BM1 as Acting 
Commanding Officer.  Upon questioning by the Chief of Response, [he] admitted knowing that the 
BM1 was not on XXXX’s Succession to Command letter because the BM1 had not yet qualified 
as an underway Officer of the Deck (OOD).  However [the applicant] decided to put the BM1 in 
charge  against  Shipboard  Regulations  because  XXXX  was  on  blocks  in  the  drydock  with  no 
possibility of getting underway.  Mbr took this action without consulting or informing the Chief of 
Response  or  anyone  on  the  Sector  Xxxxxxx  staff.    Upon  further  investigation,  the  BM1  in 
question  departed  XXXX  with  [the  applicant]  to  XXXX’s  homeport  of  xxx  Xxxxxx,  an 
approximately 9 hour drive from the cutter in  xxxxxxx, AL.  The BM1 had not been informed he 
would  be Acting  Commanding  Officer.    The  BM1  thought  the  MKC  Engineering  Officer  was 
Acting Commanding Officer.  This incident highlights [the applicant’s] inability to properly direct 
mbr’s crew or exercise the team cooperation expected of a Commanding Officer. 

 
[The  applicant]  exercised  poor  judgment  when  he  left  his  cutter  “not  under  command”  in  the 
yards.  Member’s poor analysis and understanding of a WPB CO’s authority and the fundamental 
nature of command led to a very bad decision.  It also demonstrates a serious lack of risk manage-
ment skills in an operational setting. 

Comparison Scale mark in 2nd spot:  “A qualified officer” 

 
Potential:  [The applicant] was already selected for O-3 based on performance at previous unit, but 
the member’s promotion & record should be reviewed due to this NJP.  Recent actions in the high 
risk environment of WPB operations indicate that member is not prepared at this point in time to 
assume  duties  with  increased  responsibilities.    Member  should  be  assigned  to  a  staff  position 
where  member  will  be  given  ample  opportunity  to  hone  leadership  and  management  skills  and 
again demonstrate high performance. 
 
 
 
OER1  was  signed  by  the  Chief  of  the  Sector  Response  Department,  as  the  applicant’s 
Supervisor, on March 26, 2007; by the Deputy Sector Commander, as the applicant’s Reporting 
Officer, on March 27, 2007; and by the Sector Commander, as the Reviewer, on March 29, 2007.  
However,  Sector  Xxxxxxx’s  published  rating  chain,  which  was  issued  on  February  8,  2006, 
shows that the designated rating chain of the CO of the XXXX was the Chief of the Response 
Department as Supervisor; the Sector Commander (rather than the Deputy Sector Commander) 
as Reporting Officer; and the  xxxxxx District Chief of Response (rather than the Sector Com-
mander) as Reviewer.  OER1 bears a stamp indicating that it was received from Sector Xxxxxxx 
and validated by the Coast Guard Personnel Command (CGPC) on April 18, 2007. 
 

On April 4, 2007, the applicant was permanently relieved of command of the XXXX due 
to  loss  of  confidence  by Acting  Commandant  (CG-12).    On  May  2,  2007,  a  lieutenant  in  the 
Officer Personnel Management Division (opm-1) of CGPC, sent the applicant a memorandum 
regarding a “Delay of Promotion,” which stated the following: 
 

1.  You were scheduled for promotion to LT on 21 May 07.  However, based on the information 
contained in [the email from the applicant’s Supervisor to CGPC-opm dated March 1, 2007], your 
promotion is delayed in accordance with Article 5.A.13. of [the Personnel Manual].  You will be 
contacted when it has been determined that either you will be promoted or further administrative 
action is necessary. 
 
2.   Your  command  shall  ensure  that  you  notify  Commander,  Coast  Guard  Personnel  Command 
(opm-1) immediately upon receipt of this letter.   

On May 15, 2007, the applicant acknowledged receipt of this memorandum and asked for 
a copy of the email from Sector Xxxxxxx to CGPC-opm dated March 1, 2007.  The lieutenant at 
CGPC-opm replied the same day and forwarded the applicant a copy of the requested email. 

 
OER2  covers  the  period April  26,  2006,  through April  4,  2007,5  and  was  prepared  in 
early May 2007 to document the applicant’s permanent RFC pursuant to Article 10.A.3.c.1.e. of 
the Personnel Manual.  OER2 is a “derogatory” report.6   

 

 

                                                 
5 During the first 37 days of this period, the applicant was still serving as the Executive Officer of the XXX.  He 
received a Navy and Marine Corps Achievement Medal dated May 9, 2006, for his service on the XXX, and the 
citation for the medal is attached to OER2. 
6 Under Article 10.A.4.h. of the Personnel Manual, any OER that documents an officer’s removal from his primary 
duty due to poor performance or misconduct is considered “derogatory,” and so the officer is allowed to attach an 
addendum of written comments to the OER for entry in his record. U.S. COAST GUARD, COMDTINST M1000.6A, 
COAST GUARD PERSONNEL MANUAL, Art. 10.A.4.h. (Change 40, 2005) (hereinafter “PERSONNEL MANUAL”). 

# 

CATEGORY 

MARK  WRITTEN COMMENTS 

MARKS AND COMMENTS IN OER2 

3a  Planning and 
Preparedness 

3b  Using 

Resources 

3c  Results/ 

Effectiveness 

3d  Adaptability 

3e  Professional 
Competence 

4a  Speaking and 

Listening 

4b  Writing 

5a 

Looking Out 
for Others 
5b  Developing 

Others 

5c  Directing 

Others 
Teamwork 

5d 

5f 

6 
7 

5e  Workplace 

Climate 
Evaluations 

3 

4 

4 

3 

3 

3 

3 

4 

4 

3 

3 

4 

4 

“Established  a  pattern  of  poor  operational  planning  &  lack  of  professional  competence/adapt-
ability.  Prior to reporting to XXXX, failed to allow time to take second DWO exam accounting for 
mandatory re test waiting period required Sector to request last-minute HQ waiver to retake in 
sufficient time to execute orders as CO.  Twice arrived in port on near-minimum fuel, the second 
time  only  one  day  after  formal  counseling  on  the  same  issue  by  Sector  CO.    Failed  to  follow 
proper risk management or prudent seamanship in near miss with commercial vsl w/ embarked 
pilot in xxx  Xxxxxx.  Invited media to ride along on potential migrant case in violation of public 
affairs guidance & w/o prior coord w/co-located Station CO; media did not embark aboard cutter 
and Station & cutter OODs had to escort them.  Was argumentative and resistant to counseling 
on subject asserting that decision was right until presented w/ existing public affairs AMIO [alien 
migrant interdiction operations] guidance that mbr should have researched in advance.  Demon-
strated  appropriate  skills  for  administrative  tasks  before  departing  XXX;  arranged  &  executed 
Joint Civ. Orientation Course (JCOC), demonstrating CG capabs & role in GWOT.  Conducted 
smooth reliefs/changes of command for both XXX and XXXX.  Scheduled projects to max XXXX’s 
48-day drydock.  Put XXXX on pace to exceed FY06’s 96% training completion rate.  Assisted in 
early completion of FY07 WPB sked w/ sister WPB and boat manager.” 

“Communications  skills  fell  below  expectations.    Demonstrated  reluctance  to  listen  to  advice, 
even when mbr had specifically requested assistance.  When mbr found inconsistencies between 
pub & advice, mbr chose to act independently, requiring Sector staff to correct improper paper-
work.  Mbr resisted tasking to report to Sector for performance counseling; failing to understand a 
request by a more senior officer is an order.  Writing skills equally sub-standard; wrote volumi-
nous insubordinate e-mails defending own actions w/o making clear or valid points.” 

“Leadership skills did not meet expectations; mbr is dedicated to mission performance but is inef-
fective  at  building  teams  and  directing  crew,  resulting  in  unhealthy  command  climate  aboard 
XXXX and increased work for Sector staff in correcting mbr’s actions.  Inappropriately withheld 
cell phone privileges from mbr w/o NJP against  XX legal advice.  Own Chiefs sought advice fm 
Sector Cmd Chief due to negative command climate & their inability to establish daily routine due 
to mbr’s unpredictable actions.  Mbr had difficulty building crew into a cohesive team; isolated self 
from crew during drydock; did not eat w/ crew nor meet w/ them for 5 days in one stretch; had to 
be  ordered  to  meet  daily  w/  EPO  during  drydock.    Took  unnecessary  risks  with  cutter  without 
clearly communicating intentions to Sector, including TAD training plan while XPO was simulta-
neously TAD.  Did not work well  w/ Sector staff; advised Sector CO of issues prior to seeking 
resolution  w/  staff.    Became  frustrated  with  speed  of  service  from  Sector  admin  &  command 
center, failing to recognize that Sector’s nine other sub-units share support from same staff.  Mbr 
did exhibit care for OCONUS crew of XXX; worked w/ Lant Area legal to alleviate mbr’s financial 
liability for third party damage to gov’t vehicle; enabled another mbr to take paternity leave fm  
xxxx.” 

Signature of the Chief of the Response Department, dated May 4, 2007 
Reporting 
Officer’s 
Comments 

NA 

[Concurred with Supervisor’s evaluation.]  “[The applicant] failed to perform as expected from a 
WPB CO in a demanding Sector multi-mission environ.  Struggled to temper eagerness to com-
plete oper missions w/ proper execution of assigned missions & correct use of chain of cmd.  Mbr 
often expressed indignation at Sector oversight.  Initially seemed to respond to counseling, then 
repeated some of behavior for which specifically counseled.  Technically proficient; kept XXXX’s 
op hours & trng plans well on track & made good preps for drydock.  However, had trouble with 
teamwork w/in unit & w/ Sector staff elements.” 

8a 

Initiative 

8b 

Judgment 

8c  Responsibility 

8d  Professional 

Presence 

4 

2 

4 

5 

“Mbr challenged beyond performance & leadership abilities working independently as WPB CO.  
Demonstrated initiative; helped create WPB SAR standby periods for MLB maintenance periods.  
Insightful feedback fm migrant transfer at sea/repatriation will aid in future Sector cases.  Demon-
strated questionable judgment & poor risk assessment skills.  Got u/w [underway] for SAR case 
w/out prior fueling, didn’t notify SMC or request early release fm SAR pattern, resulting in unnec-
essary risk to cutter & crew.  Lost sit[uational] awareness & didn’t properly brief Sector on close 
quarters nav situation w/ commercial vessel until issue was highlighted by XXXX chiefs to Sector 
Cmd Chief.  Didn’t fully analyze & research CG policies before making decisions.  Struggled w/ 
properly  addressing  personnel  issues;  on  several  occasions  dismissed  legal  &  Sector  advice 
including filing add’l CG-3307s after Deputy advised against it.  Resulted in improper admin in 

8e  Health & Well-

Being 

9 

Comparison 
Scale 

5 

2 

10  Potential 

NA 

case of poor-perf nonrate & increased workload for Sector staff.  Good professional presence & 
conveyed positive image of CG to public.  VADM complimented appearance of XXX/crew while 
hosting  JCOC  mbrs.    Enforced  3  times/wk  XXXX  crew  workouts;  maintained  own  personal 
fitness.” 

[A mark  of  2 means that  in comparison  with  all  the  other  LTJGs  he  has known,  the  Reporting 
Officer rated the applicant as “a qualified officer.”] 

“Despite best efforts of Command, [the applicant] did not develop as hoped.  Made critical errors 
in judgment early; often resulting in add’l work for remainder of Sector staff.  Several verbal coun-
seling  &  coaching  sessions  proved  fruitless  as  mbr  rejected  advice  fm  seniors  &  continued  to 
struggle.  [He] is a very intelligent JO with a strong operational background who initiated a num-
ber of constructive initiatives.  However, mbr’s brash demeanor hampers ability to build camara-
derie and confidence in abilities.  Already selected for O-3 based on previous performance.  Mbr 
relieved of cmd of XXXX due to loss of confidence.  Not recommended for increased responsi-
bilities ATT [at this time].” 

11  Signature of the Deputy Sector Commander as the Reporting Officer, dated May 4, 2007  
12  Signature of the Sector Commander as the Reviewer, dated May 23, 2007 
REVIEWER COMMENTS 
 

Despite  a  history  of  strong  performance,  this  officer  was  not  ready  for  Command.    Perhaps  because  of  the  super-high 
OPTEMPO and non-traditional missions/operational relationships experience as XO of the XXX, ROO was pre-disposed to 
take unnecessary risks, quick to dismiss advice and direction from others, and unable to leverage or develop the experience 
and expertise of his crew, particularly the CPOs.  These short-comings could have been overcome in almost any other O2 
position that allowed more leeway for professional growth.  As a Commanding Officer, however, the risks to the crew and the 
mission were too high to continue to allow ROO to struggle with these responsibilities. 
Given the low tolerance for failure and associated high career risk that comes with assignment as CO, particularly in relation 
to other O2 assignments, ROO should be given every chance to continue CG career, and to be promoted to O3. 

 
 
 
Prior to the Sector Commander’s review of OER2 on May 23, 2007, the applicant, as the 
Reported-on  Officer  (ROO),  submitted  the  following  addendum  addressing  the  negative  com-
ments in OER2, which was endorsed by the rating chain and forwarded to CGPC with OER2: 
 

Comment:    Poor  operational  planning  pattern,  lack  of  competence/adaptability  demonstrated  by 
DWO exam, fuel levels, near-miss, media invite. 
Views of ROO: 

DWO exam.  Before returning stateside, twice requested later change-of-command date.  
Last-minute  combat  tour  extension  to  13  months  as  XXX  XO,  80  days  accumulated  leave,  no 
regular leave taken en route, only departing member of XXX unable to take 30 consecutive days 
of regular leave upon return to U.S.  Operated in a region famous for Coast Guard’s most intense 
OPTEMPO, on a cutter that logged the highest OPTEMPO of all CG patrol boats and Navy patrol 
craft (5500 hrs), citation documenting operational demands and performance attached to OER. 

Fuel levels.  Sector, District, Area, HQ have never promulgated a fuel-level expectation 
outside of hurricane season.  Letter of Censure[7] dated 4 Jan 07 cited ROO ignored “safe opera-
tional standards” without promulgating or citing a class-wide fuel standard. 

Near-miss.    Risk-based  decision  by  ROO  to  get  [underway]  for  tanker  mooring  vice 
remain anchored, determined to ensure cutter safety vice relegating both ships’ safety to ship driv-
ing ability of unknown pilot. 

Media-invite.  3-month-old public affairs detachment endorsed program.  Involved same 
operational risk as when taking media underway for a scheduled ride-along.  “Argumentative” and 
“resistant” comment not supported by read of email concurrent with incident; ROO obligated by 
position to provide direct honest feedback and express concerns up the chain of command; expres-

                                                 
7 The applicant indicates that on January 4, 2007, he received an Administrative Letter of Censure for returning to 
port with very little fuel.  As such letters are handed directly to an officer and are not entered in an officer’s military 
record, no copy of this letter is in the record before the Board. 

sion of views factual, focused, organized, and respectful in tone and content.  OOD did not escort 
media; ROO did. 

Comment:  Communications skills—Reluctance to take advice.  Acting independently amidst dis-
crepancy between COMDTINST (referred-to publication) and advice.  Fails to understand request 
by senior officer is really an order.  Writing skills sub-standard, voluminous insubordinate emails 
failed to make clear or valid points. 
Views of ROO: 
COMDT  guidance  to  FY07  promotion  boards  encourages  promotion  of  officers  with  a  bias  for 
action.  ROO acted in accordance with COMDTINST, perceived instruction from higher authority 
as an order vice “advice” from a lesser authority as advisory/interpretative.  Performance counsel-
ing was less than a month from end of marking period.  Emails explaining ROO’s actions were 
requested from superior; emails deferential in tone, factual, on-point, honest, and well-written. 
 
Comment:  Leadership skills—Ineffective team builder/crew director demonstrated by unhealthy 
command climate and increased Sector workload. 
Views of ROO: 

Team builder/crew director.  ROO was catalyst for horizontal communication.  Champi-
oned “team Xxxxxx” uniting effort of STA Xxxxxx and MSD Xxxxxx for cross-training and joint 
boardings.    Led  team  of  COs  in  creating  new  operating  model  incorporating  cutter  and  station 
schedules  around  chronic  motor-lifeboat  casualties.    Directed  crew  in  2  major  protracted  SAR 
cases, one extended migrant interdiction/repatriation and 1 accelerated drydock all in less than 7 
months. 

Unhealthy command climate.  Improved climate  was contingent on enforcing perform-
ance standards within framework of COMDTINST.  Report of command climate issue was inci-
dent  to  XPO/EPO  receipt  of  performance  counseling  and  circumventing  chain  of  command.  
Subsequent investigation crippled the command as it undermined CO’s authority and prohibited 
unit’s foremost command concern from being addressed:  insubordination. 

Increased  Sector  workload.  Comment  not  substantiated.   XXXX’s  parent  command  is 

 

her only support command. 

Illegal withholding of privileges.  Policy (SORM) was being rewritten; crew couldn’t use 
cell phone during workday; enforcing policy already in place.  Crew’s liberty and “recall-ability” 
during short-notice standby contingent on personal cell phones, standards promulgated in SORM. 
Chiefs  unable  to  establish  daily  routine  due  to  ROO’s  unpredictable  actions.    Drafting 
and enforcing plan of the day is XPO’s responsibility.  EPO has no role establishing daily routine.  
ROO’s actions segregated responsibility IAW CG Regs.  CO’s/ROO’s documentation of chronic 
performance  deficiencies  in  XPO  kicked  off  climate  report  to  Sector  Command  Senior  Chief.  
ROO denied the opportunity to address issues with XPO, due to ongoing investigation. 

Isolation in drydock; ordered to meet daily with EPO.  Assessment and order made from 
430-mile  distance  without  on-scene  perspective.    ROO  consistently  acted  in  best  interest  of 
XXXX.  ROO well practiced in leading a crew on small units on long deployments in challenging 
environment.  XXX averaged 25 days [underway] each month in combat zone for 1 yr.  XXXX 
spent 3 weeks away from homeport for hurricane evasion and SAR standby.  At time of RFC, in 
drydock for only 20 days.  ROO had no knowledge of specific expectation for the frequency of 
dining  or  meeting  with  crew;  experience  is  healthy  level  of  separation  is  critical  for  unbiased 
decision-making  and  exercise  of  NJP  authority.    Five  days  at  issue  were  during  time  Sector 
authorized ROO’s 14 days of [temporary active duty] for training and associated leave en route. 

Advised Sector CO of issues before seeking resolution with staff.  ROO advised Sector 
Commander  in  relief  letter  of  intention  to  submit  command  concerns  within  a  month.    ROO 
submission cc’d the entire chain of command, and explicitly stated the content was not for action 
but for transparency.  ROO acted in good faith and believed it appropriate for CO to forward his 
command concerns to his operational commander. 

Frustrated  with  speed  of  Sector  support.    ROO  recognized  support  demands  of  Sector 
staff;  ROO  believes  frustration  justified.    Highlighted  by  XXXX  XPO  requesting  a  Sector-
appointed investigating officer (IO) due to the small crew size—on the advice of Sector.  Took a 

month for the IO to submit the investigation to Sector, skipping XXXX altogether.  Another month 
passed without XXXX receiving the investigation. 

On June 14, 2007, Commander, CGPC sent the applicant a memorandum regarding “Pro-

 
 
posed Board Action,” which stated the following: 
 

1.  Action has been initiated under Article 5.A.13. of [the Personnel Manual] to convene a board of 
officers to recommend whether or not your name should be removed from the PY07 Lieutenant 
Selection list.  This panel will review your CG PC Personnel Data Record (PDR) and all docu-
ments related to [OER1; the Sector’s email to CGPC-opm dated March 1, 2007; and CGPC-opm’s 
memorandum to the applicant dated May 2, 2007]. 
 
2.  Commander, Coast Guard Personnel Command (CGPC) may initiate special board action when 
information of an adverse nature is discovered.  In your case, this action was initiated up receipt of 
[OER1], which documents NJP for violations of the UCMJ – Article 92 (Dereliction of Duty) and 
Article  92  (Failure  to  Obey  an  Order).    In  conjunction  with  the  NJP  proceedings,  you  were 
awarded a punitive letter of admonition.  Specifically, on 26 Jan 2007, you “failed to leave CGC 
XXXX  under  the  command  of  a  qualified  individual  in  his  absence.”   Also,  “when  ordered  to 
return to the ship by the Chief of Response, [the applicant] delayed his return by over 28 hours in 
violation of that order.”  As a result of these actions, you were relieved for cause as the CO, CGC 
XXXX. 
 
3.  Your scheduled promotion to Lieutenant on 21 May 2007 has been withheld pending the out-
come of special board action. 
 
4.  You are extended an opportunity to submit comments on your behalf.  Comments must be sub-
mitted to Commander, Coast Guard Personnel Command (CG-opm-1) via your chain of command 
as soon as possible  upon receipt of this  notification.  To establish the date of  notification,  your 
command shall ensure that you execute and return the attached endorsement to Commander, Coast 
Guard Personnel Command (CGPC-opm-1) immediately upon receipt. 
 
5.  If you have any questions, you may contact … 

 

On June 19, 2007, the applicant acknowledged receipt of the memorandum dated June 
14, 2007, and indicated that he would submit a statement on his own behalf.  The proceedings of 
the  special  board  of  officers  are  not  in  the  record,  but  the  applicant  was  removed  from  the 
promotion list as a result of the proceedings, which constituted a “failure of selection.”  He was 
not selected for promotion in 2007.  As a result of this second failure of selection, he would have 
been involuntarily discharged from the service on June 30, 2008.  Instead, he requested resigna-
tion  and  was  honorably  discharged  on  May  22,  2008,  upon  completion  of  his  five  years  of 
required active service. 
 

APPLICANT’S ALLEGATIONS 

 
Allegations About the Denial of Promotion 
 
 
The applicant alleged that he was removed from the LT promotion list in contravention of 
statutory authority and caselaw.  His name appeared on the list of LTJGs selected for promotion 
to  LT issued on November 1, 2006, and so he  should have been promoted on May 21, 2007.  
However, on May 2, 2007, he was notified in writing that his promotion would be delayed.  He 
alleged that the action to delay his promotion was undertaken by a lieutenant—someone without 

authority and that the delay violated 14 U.S.C. § 271(f), which states that “[t]he promotion of an 
officer who is under investigation or against whom proceedings of a court-martial or a board of 
officers are pending may be delayed without prejudice by the Secretary until completion of the 
investigation or proceedings.”  The applicant alleged that in May 2007 he was not under investi-
gation, he was not facing court-martial, and there was no “pending” board of officers.  
 

The applicant stated that he was not notified that a board of officers would review his fit-
ness for promotion until July 19, 2007,  when he was shown  a letter headed “Proposed  Board 
Action” dated June 14, 2007.  Therefore, there was no board of officers pending in May 2007 
and  he  should  have  been  promoted  on  schedule.    The  applicant  argued  that  the  meaning  of 
“pending” in 14 U.S.C. § 271(f) was directly addressed in United States v. Law, 11 F.3d 1061, 
1065-66 (1993), as follows: 

 

 
Law’s further argument is that the delay  was  unlawful because  no proceedings  were  “pending” 
before the board of officers as required by § 271(f) to sanction a delay of his promotion otherwise 
scheduled for June 1, 1990. There is no dispute that the officers of the Special Board  were not 
selected until June 11, 1990, which was after Law’s originally scheduled promotion date. In Law’s 
view, specific officers must have actually met or convened by June 1, 1990 for proceedings to be 
“pending” before June 1. Judge Andewelt ruled that proceedings were pending against appellant 
from “the date on  which the Special Board was approved, rather than the date on which it first 
convened.” 26 Cl. Ct. at 387 n.5.  Again, we agree. 
On April 25, 1990, the Chief of Personnel and Training referred the matter to a board of officers to 
be convened for the specific purpose of determining whether Law’s name should be removed from 
the  active  duty  promotion  list.  The  selection  of  officers  for  the  Special  Board  thereafter  was 
merely  ministerial. We conclude that the interpretation of  § 271(f) that  matters  were  “pending” 
from the date the board was authorized does not conflict with any provision of any applicable stat-
ute and is reasonable. By analogy, court proceedings are “pending” before a case is assigned to a 
particular judge or judges. Accordingly, we cannot agree with Law that § 271(f) was improperly 
interpreted by the trial court. 
 
Therefore, the applicant argued, under Law, a board of officers is only “pending” as of 
the date it is authorized.  Since the applicant was not referred to a board until June 14, 2007, no 
board of officers was pending in May 2007, and he should have been promoted on schedule on 
May  21, 2007.  Therefore, the applicant alleged the Coast Guard’s failure to promote him on 
May 21, 2007, was illegal, and he should be promoted illegally and awarded back pay and allow-
ances.  The applicant further alleged that if he had been properly promoted on May 21, 2007, 
there would have been no need for a board of officers to decide whether he should be promoted.  
Therefore,  the  proceedings  of  and  any  references  to  the  board  of  officers  should  be  removed 
from his record. 
 
Allegations about Both Disputed OERs 
 

In his addendum to his application, the applicant alleged that OER1 and OER2 should be 
removed from his record because they contain misstatements of significant hard fact.  In addi-
tion, he alleged that both OERs were prepared in violation of the Personnel Manual because they 
were not prepared by his designated rating chain.  Whereas both OERs were signed by the Dep-
uty Sector Commander as Reporting Officer and the Sector Commander as Reviewer, the appli-
cant  alleged  that  his  designated  rating  chain  did  not  include  the  Deputy  Sector  Commander.  
Instead, the Sector Commander was his designated Reporting Officer and the Chief of Response 

for the District was his proper Reviewer.  In support of this allegation, he submitted a copy of 
“Sector Xxxxxxx Instruction 1611.1,” dated February 8, 2006, which contains a chart showing 
that the rating chains of all the officers in Sector Xxxxxxx.  The chart shows that the rating chain 
of the CO of the XXXX and another cutter includes the Chief of the Response Department as the 
Supervisor, the Sector Commander as the Reporting Officer, and the  xxxxxx District Chief of 
Response as the Reviewer.  The applicant alleged that the impermissible alteration of his rating 
chain  was  a  prejudicial  violation  of  the  Personnel  Manual  and  that  the  Deputy  Sector 
Commander  who  erroneously  acted  as  his  Reporting  Officer  made  erroneous  comments  and 
marks in the OERs. 

 

Allegations about Errors in OER1 

 
Regarding OER1, the applicant alleged that there is no evidence to support the claims 
therein that he failed to leave his vessel under the command of a qualified individual and that, 
upon being ordered to return to the vessel, he delayed his return by 28 hours in violation of Arti-
cle 92 of the Uniform Code of Military Justice (UCMJ).  The applicant argued that although Arti-
cle 10.A.4.c.4.e. requires OER comments to be “sufficiently specific to paint a succinct picture 
of the officer’s performance,” neither OER1 nor the Punitive Letter of Admonition he received 
cited any policy or order that he had violated.  Moreover, he alleged, the person he left in com-
mand had been “designated in accordance with existing Coast Guard policy.”  In addition, the 
applicant  alleged  that  when  he  was  ordered  to  return  to  his  vessel,  he  did  so  “as  quickly  and 
safely as possible.”  He argued that because nothing in his record explains with specificity why 
his conduct was punishable, the negative claims in OER1 are erroneous and unjust. 
 
Allegations about Errors in OER2 
 

Regarding OER2, the applicant alleged that the comments in this OER are not objective 
or supported by evidence.  He noted that he detailed the misstatements of fact in the addendum 
he prepared for OER2 to no avail as nothing was changed.  The applicant alleged that the mis-
statements of fact in OER2 result from the Deputy Sector Commander’s improper insertion of 
himself in the applicant’s rating chain.   

 
Regarding the comment in OER2 about poor planning, the applicant explained that his 
deployment on the XXX was extended from 12 to 13 months without notice.  As soon as he was 
informed of the extension, he requested a later report date to the XXXX to no avail.  Therefore, 
he had an entire month less time to prepare for his assignment to the XXXX than was expected 
and should not be blamed for not having had time to complete the DWO qualifications.  Because 
of the extension of his deployment, upon arriving in the United States, he had no chance to take 
leave and was required to report immediately for several weeks of mandatory training and, from 
training, he had to report immediately to the XXXX.  

 
Regarding  the  comment  about  fuel  levels,  the  applicant  argued  that  neither  the  Sector 
Commander nor the District had set fuel endurance standards.  He stated that he was criticized 
for returning to port with an 18% fuel level on November 16, 2006, after the XXXX responded 
to an urgent SAR and for mooring for drydock with a 20% fuel level, which he had done “to 

minimize fuel-storage costs.”  The applicant stated that these fuel levels provided “a safe reserve 
of over 5 hours and 50 nautical miles of endurance at XXXX’s designed cruising speed.” 

 
Regarding the comment about the “near miss” with another vessel, the applicant stated 
that the investigation showed that on October 4, 2006, the XXXX unmoored at 1610 hours “to 
clear the way for an inbound commercial vessel.  [The applicant] maneuvered CGC XXXX to 
the  west  to  maintain  station,  clear  of  the  commercial  vessel,  during  the  commercial  vessel’s 
mooring evolution.”  The applicant alleged that the investigator concluded that his actions were 
not “reckless.”  In addition, the applicant alleged that his CPOs did not report the “near miss” to 
his chain of command until the day after he had prepared a negative Page 7 for the XPO due to 
his missing a routine deadline for the third month in a row. 
 
 
the applicant alleged that  
 

Regarding the comment that he violated public affairs guidance and was argumentative, 

[t]he media was invited to ride along for a SAR case on 2 Dec 2006 in accordance with District x’s 
Public Affairs  Detachment  (PADET)  endorsement  of  XXXX’s  public  affairs  program  dated  10 
August 2006.  I was the media’s only escort.  The subject news crews did not get underway with 
XXXX due to a casualty to XXXX’s main propulsion plant.  The public affairs guidance referred 
to was promulgated and dated 18 Dec 2006.  The only exchange I had with my supervisor on the 
subject was her emailed suggestion that my crew film footage, and my reply stating safety con-
cerns for a minimally manned unit sparing crewmembers for filming footage while engaged in an 
all-hands evolution. 

 
 
Regarding the comment that he failed to listen to advice that he had specifically request-
ed, the applicant alleged that it refers to the Deputy Sector Commander’s disagreement with his 
decision to dismiss a Report of Offense against a non-rate on his crew who had recurring disci-
plinary problems in lieu of issuing the non-rate a negative Page 7.  When the non-rate filed an 
EEO complaint against the applicant, the Deputy Sector Commander ordered the applicant “to 
hold prepared documentation from being submitted into [the non-rate’s] record, undermining [the 
applicant’s] ability to maintain good order and discipline.”  The applicant alleged that the Sector 
staff never  had to correct any improper paperwork, and that this comment contradicts another 
comment  in  OER2  that  says  he  “demonstrated  appropriate  skills  for  administrative  tasks.”  
Regarding the comment that he withheld a member’s cell phone privileges against advice, the 
applicant  stated  that  he encouraged  his  XPO  and  CPOs  to  enforce  the  Coast  Guard’s  existing 
policy  prohibiting  cell  phone  use  during  the  work  day.    Moreover,  he  alleged,  the  advice  he 
sought from the District legal office validated this course of action. 
 
 
Regarding the comment that he resisted an order to report to the Sector for performance 
counseling, the applicant alleged that the comment reveals the existence of “a coercive command 
climate that ignored the special trust and confidence inherent in command.”  He alleged that he 
never resisted any such tasking but merely questioned the necessity of the performance counsel-
ing since his performance evaluation was due in a few days.  The applicant further stated that his 
CPOs complained to the Sector that he was hazarding the  XXXX on December 11, 2006; his 
presence  at  the  Sector  was  requested  on  December  12,  2006,  “for  counseling  on  formatting 
marks  input”;  his  concerns  about  the  timing  of  the  counseling  were  raised  and  answered  on 
December 13, 2006; and on December 14, 2006, he reported to the Sector office, where he was 
informed of his CPOs’ allegations and received marks formatting counseling. 

 
 
Regarding the comment that he was ineffective at building teams and directing the crew, 
which created  an unhealthy command climate on the  XXXX, the applicant claimed that these 
assertions are not supported.  He stated that the command cadre of the XXXX never filed any 
complaints of mistreatment against him or complaints about an unhealthy command climate even 
after he was relieved of command.  The applicant stated that the comment that he increased the 
workload of the Sector staff “is indicative of Sector staff undermining my authority as command-
ing  officer  and  executing  tasking  appropriate  for  XXXX’s  department  heads.”    Regarding  his 
chiefs’ alleged complaint about a negative command climate on the XXXX and their inability to 
establish  a  routine  due  to  his  unpredictable  actions,  the  applicant  stated  that  these  complaints 
were made only after he formally counseled his XPO about significant performance problems.  
Regarding the comment about his isolation from the crew during drydock, the applicant alleged 
that the comment “suggests a standard for how to command during drydock, though such expec-
tations were never made.”  He stated that he maintained a “healthy level of separation from the 
crew  during  liberty  hours”  because  of  the  ongoing  disciplinary  problems  of  a  non-rate  and 
enforced the segregation of duties to hold supervisors accountable.  He alleged that his leader-
ship resulted in the XXXX progressing through drydock 25% ahead of schedule. 
 
 
Regarding the allegation that he took unnecessary risks with the cutter and went on TAD 
while his XPO was also TAD, the applicant alleged that his actions minimized the impact on 
Sector operations and that the command of the XXXX was properly left under the control of the 
Engineering  Petty  Officer  (EPO)  while  he  and  the  XPO  were  on  TAD  and  the  cutter  was  in 
drydock.  Moreover, he stated that the comments in the OER showing that he coordinated and 
lengthy, complex, and dangerous interdiction and repatriation of illegal immigrants contradicts 
the  comment  suggesting  that  he  was  unable  to  calculate  the  XXXX’s  fuel  endurance  and  got 
underway for a SAR mission without enough fuel. 
 
 
Regarding his relations with the Sector staff, the applicant alleged that after he sent an 
email listing his “command concerns” to his entire chain of command, the Sector Commander 
commended  him  for  his  proactive  effort.   The  applicant  alleged  that  he  was  frustrated  by  the 
month-long delay in his receipt of the investigation of the non-rate’s misconduct and that he hon-
estly informed his Supervisor and Reviewer that the delay negatively affected his ability to main-
tain good order and discipline.  The applicant further alleged that the comment about his eager-
ness to complete missions conflicting with the proper execution of missions and with his use of 
the correct chain of command is “not supported, confusing, and highlight[s] objections to style, 
not substance.”  He argued that his email about his “command concerns” to his entire chain of 
command “champion[ed] transparency” and “invited oversight.” 
 

VIEWS OF THE COAST GUARD 

 
 
On February 6, 2008, the Judge Advocate General (JAG) of the Coast Guard submitted 
an advisory opinion regarding the applicant’s original application for an immediate, back-dated 
promotion.  The JAG recommended that the Board deny the requested relief.   
 
 
The JAG argued that the applicant’s promotion was lawfully delayed.  He alleged that on 
May 21, 2007, the applicant was still “under investigation” as required by 14 U.S.C. § 271(f).  

The JAG stated that due process demands that, prior to convening a special board of officers, the 
Coast Guard compile a thorough record for review and decision-making.  The JAG stated that 
there is a “continuum of procedures for delaying an officer’s promotion [which] begins with an 
investigation and may conclude with a special board of officers’ decision to either remove the 
officer from the promotion list, or promote the officer to the next higher grade.”   In addition, 
“there are various levels of investigations which are conducted concurrently and consecutively in 
order to accumulate the proper record.” 
 
 
The JAG stated that the fact that the Sector Commander had concluded his own investi-
gation of the circumstances of January 26 and 27, 2007, and had awarded the applicant NJP does 
not mean that the investigation of the applicant  was complete.   The JAG pointed out that the 
command  notified  CGPC  that  further  steps  were  necessary  in  that  the  applicant’s  promotion 
should be delayed so that CGPC could review his record.  In addition, under the Personnel Man-
ual, both the imposition of NJP and the permanent RFC required preparation of special OERs.  
The JAG pointed out that the applicant’s addendum to OER2 is dated May 22, 2007—the day 
after he would have been promoted.  He submitted a declaration from the Chief of the Boards 
Section at CGPC-opm (see below), who stated that CGPC requires that adverse information be 
documented in an officer’s record in OERs before the “record read” begins to decide whether a 
special board should be convened.  Therefore, before CGPC-opm-1 could complete its review, 
CGPC-opm-3 had to validate all of the information in the applicant’s record, including the two 
special OERs that were required by his NJP and RFC.   
 

The JAG argued that it  “would have been improper [for CGPC] to authorize, refer, or 
even convene a special board of officers hastily, without properly investigating and reviewing the 
record.”  The JAG stated that because the applicant’s record was not yet complete on May 21, 
2007, the investigation was ongoing.  Therefore, CGPC-opm-1 warned the applicant in advance, 
in a memorandum dated May 2, 2007, that his promotion would be delayed.  The JAG noted that 
in this memorandum, CGPC-opm-1 advised the applicant that he would be contacted “when it 
has been determined” whether further administrative actions were necessary, and that this lan-
guage showed that CGPC’s investigation was ongoing.  The JAG stated that this investigation 
was not concluded until June 14, 2007, when CGPC determined that a special board of officers 
was required and the applicant was informed of the outcome of CGPC’s investigation. 
 
 
The  JAG  attached  to  the  advisory  opinion  a  declaration  signed  by  the  lieutenant  com-
mander who, as Chief of the Officer Boards Section at CGPC-opm, worked on the applicant’s 
case from February 2, 2007, when adverse information was first received by his section, until the 
special  board  process  was  complete.    The  Chief  of  the  Boards  Section  wrote  the  following 
regarding Coast Guard law, policies, and procedures: 
 

The process the Officer Boards Section follows in managing Troubled Officer cases is delineated 
by law, policy and practice to ensure the efficient management of the Service and [the] balance 
that is needed with upholding the due process of the member.  The general process will be dis-
cussed, but with specifics regarding [the applicant’s] case. 
 
While an officer is on a list of selectees for promotion to the next higher grade, it is possible that 
the officer could demonstrate some characteristics which cast doubt on his moral or professional 
qualities,  and  would  potentially  disqualify  that  officer  for  promotion  to  the  next  higher  grade.  

Boards Section considers this “adverse information.”  (See PERSMAN 5.A.13.f. and 14 USC § 
271(f).) 
 
Normally, this adverse information is first presented informally, often by the chain of command, 
through  a  telephone  call,  electronic  mail  or  memorandum.   While  we  note  that  an  offense  may 
have  been  committed,  a  criminal  investigation  started,  or  an  Article  15/32  hearing  scheduled, 
Boards Section reserves judgment until the officer’s record is complete, to uphold the members’ 
due process.  The timeline to complete the military justice aspect of the case, to submit and vali-
date an acceptable [OER] documenting the case, and to complete a record review to determine if a 
Special Board is justified is often a lengthy process.  Boards Section requires that a special OER 
document an officer’s misconduct or substandard performance, and that this special OER be vali-
dated and inserted into the officer’s CGPC PDR prior to commencing a record read to determine if 
a Special Board should ensue.  The applicable policy on completing a  special OER is found at 
Article 10.A.3.c.1. of the CG Personnel Manual.  If the command pursues disciplinary action then 
the command would prepare a special OER after that process has run its course.  The specific pol-
icy is found at Article 10.A.3.c.1.b. of the CG Personnel Manual.  Upon receipt of the final OER, 
an  internal  review  by  Boards  Section  Chief,  Boards  Promotions  Separations  Branch  Chief  and 
Officer Personnel Management Deputy Division Chief recommends to convene a special board or 
not, and Officer Personnel Management Division Chief renders a decision based on the circum-
stances of the case, the officer’s record, and any other pertinent matters of record. 
 
In an emerging case, where the record is not complete, and investigation into the officer’s contin-
ued qualification for promotion is ongoing, Promotions Section will notify the officer of a tempo-
rary delay to the scheduled promotion by memo, and ask the officer so notified to acknowledge 
receipt of the memo in writing.  This memo is sent via the chain of command.  In this way, the 
officer is put on  notice that  Boards Section is aware of potentially adverse information, that an 
investigation into these matters has commenced, and that the temporary delay of promotion was 
effected. 
 
In the event that the circumstances do not support board action, opm-1 summarily promotes the 
officer with back date, pay and allowances to the day that he would have been promoted without 
the delay.  In the event that a review of the officer’s record shows that doubt exists regarding the 
officer’s qualification to promote to the grade to which selected, a Special Board is initiated.  The 
officer is notified of proposed special board action by memo and is asked to acknowledge receipt 
of the memo in writing.  This memo is sent via the chain of command. 

 
 
On July 8, 2008, after reviewing the applicant’s additional requests for relief and allega-
tions  concerning  the  disputed  OERs,  the  JAG  submitted  a  supplemental  advisory  opinion  in 
which he recommended that the Board deny this request as well.  The JAG argued that the appli-
cant failed to rebut the presumption of regularity accorded his NJP and failed to prove that the 
comments about his violations of Article 92 of the UCMJ in OER1 were erroneous.  The JAG 
also argued that the applicant’s violations of Article 92 were explained in sufficient detail in both 
OER1 and the attached Punitive Letter of Admonition.  The JAG also noted that the applicant did 
not appeal his NJP, which caused the preparation of OER1, as permitted under section 1.F.1. of 
the Military Justice Manual. 
 
 
Regarding the applicant’s claims about OER2, the JAG stated that the applicant has failed 
to prove his allegations of misstatements of fact by submitting supporting evidence.  The JAG 
alleged that a BCMR applicant is required to prove his allegations about an OER with “clear, 
cogent, and convincing evidence.” 
 

 
Regarding the applicant’s allegations about the improper rating chain, the JAG stated that 
“[a]ssuming arguendo that failure to follow the Sector Instruction is a violation of regulation, the 
applicant fails to show prejudice.”  The JAG stated that the Personnel Manual allows a Deputy 
Sector Commander to be designated as a Reporting Officer.  In addition, he pointed out that the 
Sector Commander, who was the applicant’s designated Reporting Officer, did sign the disputed 
OERs as the Reviewer.  He alleged that the Reviewer’s signature on the disputed OERs shows 
that he concurred with the assigned marks.  Therefore, the JAG argued, the applicant has failed 
to show that he was prejudiced by the alleged violation of regulation. 

 

APPLICANT’S RESPONSE TO THE VIEWS OF THE COAST GUARD 

 
 
On August 26, 2008, the applicant responded to the original and supplemental advisory 
opinions.  The applicant alleged that there is no evidence in the record that the applicant was 
“under investigation” in May 2007 when his promotion was delayed.  He alleged that he was 
never informed that he was still under investigation and nothing in the record indicates that there 
was  an  ongoing  investigation  at  the  time.    In  fact,  he  argued,  the  record  indicates  that  the 
investigation was completed as of March 2007 “and that all military justice action(s) had been 
completed.” 
 
 
The  applicant  stated  that Article  5.A.13.f.3.  does  authorize  the  Commander  of  CGPC-
opm to delay promotions, but not a lieutenant in the CGPC-opm office.  The applicant alleged 
that the memorandum he received dated May 2, 2007, shows that a mere lieutenant delayed his 
promotion, which is a violation of Article 5.A.13.f.3.  In addition, the applicant argued, Article 
5.A.13.f.3. requires the Commander of CGPC-opm to notify him in writing of the reasons for the 
delay, and the May 2, 2007, memorandum does not state that the applicant was “under investi-
gation.”    The  applicant  alleged  that  the  JAG’s  argument  that  the  applicant  was  still  “under 
investigation” in May 2007  
 

suggests  that  all  officers  are  always  “under  investigation”  when  they  are  being  considered  for 
promotion and are also “under investigation” if their records are being reviewed by CGPC for any 
reason  whatsoever.    This  is  nonsense,  and  tellingly  there  is  no  law  or  authority  cited  for  this 
proposition.  The record is clear that no formal or informal Administrative Investigation or CGIS 
investigation  was  being  conducted  at  the  time  [the  CGPC-opm  lieutenant]  delayed  [the  appli-
cant’s] promotion.  The Coast Guard utterly fails to explain how or why its “review” of a “record” 
that it did not term an investigation at the time can be morphed into an after-the-fact “investiga-
tion” for the purpose of complying retroactively with 14 U.S.C. section 271(f).  This is nothing 
more  than  a  transparent  attempt  by  legal  counsel  to  transmute  a  non-compliant  process  into  an 
“investigation” for the purpose of avoiding a records correction. … 
 
A “record read” does not constitute an investigation for the purpose of 14 U.S.C. section 271(f).  
The Coast Guard’s premise relies on the possibility that CGPC-opm can conduct a “record read” 
and decide against convening a board of officers.  Therefore, since a “record read” is a separate 
process  distinctly  different  from  a  pending  board  of  officers,  a  “record  read”  is  the  functional 
equivalent of an investigation.  However, if a “record read” constituted an investigation, then the 
companion requirement that a “board of officers be pending” would be obviated and/or superflu-
ous because a “record read” must be conducted before CGPC-opm can decide to convene a board 
of officers.  The Coast Guard’s excuse for its statutory non-compliance is weak and inconsistent 
with rules of statutory interpretation. 

 

 
Regarding  his  declaration  about  the  misstatements  of  fact  in  the  disputed  OERs,  the 
applicant pointed out that his sworn statement is “competent evidence” and that the JAG did not 
challenge his claims with contradictory evidence.  In addition, he pointed out that the JAG did 
not  explain  why  the  rating  chain  published  in  SECXXXINST  1611.A  was  violated.    The 
applicant argued that the violation of the published rating chain is strong evidence that rebuts the 
presumption of regularity afforded his chain of command.  In addition, he cited the purpose of 
the  requirement  that  rating  chains  be  published  under  Article  10.A.1.d.2.  of  the  Personnel 
Manual, and alleged that the Sector’s  failure to  use the published rating chain “highlights the 
lack of common understanding of roles and responsibilities of the entire chain of command for 
the  entire  rating  period.    This  confusion  explains  the  heightened  scrutiny  and  perception  of 
insubordination that led to the loss of confidence in [the applicant’s] ability to command.”  The 
applicant alleged that his chain of command lost confidence in his ability to command because of 
the “confusion of roles and responsibilities” and that the loss of confidence was not supported in 
the record. 
 
 
Finally, the applicant alleged that he did not appeal his NJP because he thought it was in 
the best interest of his crew not to do so.  He stated that if he had appealed his NJP, his own reas-
signment and thus the assignment of a new CO for the XXXX would have been delayed. 
 

APPLICABLE LAW 

 

Under  14  U.S.C.  §  271(f),  the  “promotion  of  an  officer  who  is  under  investigation  or 
against whom proceedings of a court-martial or a board of officers are pending may be delayed 
without prejudice by the Secretary until completion of the investigation or proceedings. How-
ever, unless the Secretary determines that a further delay is necessary in the public interest, a 
promotion may not be delayed under this subsection for more than one year after the date the 
officer would otherwise have been promoted. An officer whose promotion is delayed under this 
subsection and who is subsequently promoted shall be given the date of rank and position on the 
active duty promotion list in the grade to which promoted that he would have held had his pro-
motion not been so delayed.” 
 

Article 5.A.13.f. of the Personnel Manual provides the following procedures for delaying 

the promotion of an officer whose name is on a list of selectees: 

 
1.  Each officer in the chain of command or Commander, (CGPC-opm) is responsible for delaying 
a promotion if he or she knows the appointee has disqualified him or herself after being placed on 
a promotion list.  Disqualification here means any circumstance which casts doubt on the moral or 
professional qualifications of the officer concerned, including pending action by a board of offi-
cers, courts-martial, or investigative proceedings (14 U.S.C. 271(f)). 
 
2.  A complete report of the circumstances recommending removing the selectee from the promo-
tion list under Article 5.A.4. shall be sent to Commander (CGPC-opm).  If the promotion letter is 
used for notification, include it if received; a copy of the OPAL need not be included.  The selec-
tee shall be furnished a copy of the report and required to acknowledge receipt.  Attach a signed 
copy of the acknowledgment as an enclosure to the report. 
 
3.  If Commander (CGPC-opm) initiates delaying a promotion, he or she shall advise the officer 
concerned in writing of the reasons for so doing and require acknowledgment of receipt. 
 

4.    The  Commandant  shall  refer  the  case  to  a  board  of  officers  to  recommend  to  the  President 
whether to remove the selectee from the promotion list.  The officer concerned will be afforded 21 
days’ notice of the proceedings, and may communicate directly by letter to the board, in care of 
Commander  (CGPC-opm-1),  before  the  board  convenes.  Chain  of  command  endorsements  are 
optional.  Enclosures or attachments are limited to copies of official records and materials allowed 
to be submitted with Officer Evaluation Reports under Article 10.A.4.c.3.  Letters from other offi-
cers shall not be solicited or submitted as enclosures.  To receive an acknowledgement, the officer 
should submit a completed, self-addressed  Acknowledgement/Referral  Card, CG-4217, with the 
letter. 
 
5.  The President of the Board will forward a report of the proceedings of the board containing a 
recommendation  to  the  Commandant  as  to  whether  the  officer  should  be  promoted,  along  with 
reasons  for  the  recommendation.    If  the  Commandant  finds  removal  from  the  promotion  list 
appropriate, he or she will forward the report with endorsements to the Secretary of [Homeland 
Security] (acting as  the alter ego of the President),  who is the  final reviewing authority.  If the 
Commandant determines that removal is inappropriate, the case is closed, and the delay of promo-
tion is cancelled.  [Emphases added.] 

 

Article 5.A.4.h.3. of the Personnel Manual provides the following regarding the removal 

of an officer from a list of selectees for promotion:   

 
An officer whose name is removed from a list under these subparagraphs remains eligible for con-
sideration for promotion. If promoted as a result of selection by the next selection board, he or she 
holds the date of rank and position on the ADPL in the grade to which promoted which he she 
would have held if his or her name had not been removed. However, if the next selection board 
does not select the officer or if his or her name again is removed from the list of selectees, the 
officer shall be considered for all purposes as having twice failed of selection for promotion (14 
U.S.C. 272).  
 

Regulations Regarding Relief for Cause (RFC) 
 

Article  4.F.1.a.  of  the  Personnel  Manual  states  that  “relief  for  cause”  (RFC)  is  “the 
administrative removal of a commanding officer (CO) or officer in charge (OIC) from his or her 
current duty assignment before the planned rotation date.”  It “normally consists of a two-step 
process:  1.  The  flag  officer  in  the  unit’s  chain  of  command  orders  a  temporary  RFC;  and  2. 
Commandant … orders a permanent RFC after reviewing the case.”  Article 4.F.3. of the Per-
sonnel Manual provides that the bases for RFC may be misconduct, unsatisfactory performance, 
unacceptable relationships, or loss of confidence.    
 
 
Article 4.F.4. states that after deciding to institute the temporary RFC process, the reliev-
ing authority must notify the member in writing of the “RFC action being taken and the reason 
for it” and of “[h]is or her right to submit a statement in writing on his or her behalf within five 
working days.”  The member is temporarily reassigned while the permanent RFC action is pend-
ing.  If grounds for a permanent relief for cause are substantiated, the relieving authority should 
“recommend  the  CO’s  or  OIC’s  permanent  RFC  and  send  appropriate  documentation  to  the 
Commandant.”   
 

Article 4.F.6.2. prohibits forwarding  a request for permanent RFC to the Commandant 
until the CO being relieved has had five working days to submit a statement on his own behalf.  
Article 4.F.6.3. states that “[t]he command must afford the member the advice of counsel within 

the meaning of UCMJ Article 27(b)(1) during the temporary RFC process and in preparing any 
statement he or she submits about the permanent RFC request.” 

 

Regulations Regarding Special OERs 
 

Article 10.A.3.c.1.b. of the Personnel Manual states that a  
 
special OER is also required when an officer receives non-judicial punishment [NJP] which is not 
subject to appeal or when the final reviewing authority’s action on an investigation includes direc-
tion that a Special OER shall be prepared because the evidence established that the officer  was 
criminally culpable. …  The report shall clearly state: (1) the nature of the proceeding prompting 
the report and the result of the proceeding, e.g. criminal conviction, non-judicial punishment, or 
final  reviewing  authority’s  action  directing  a  special  OER  due  to  criminal  culpability;  (2)  any 
punishment imposed as a result of criminal conviction or non-judicial punishment; and (3) other 
information as necessary to accurately reflect the performance being evaluated. Information about 
the  proceeding  may  be  included  in  the  report  even  if  the  proceeding  took  place  outside  of  the 
reporting period. The evaluation shall be limited to those areas affected by such conduct, since all 
other  dimensions  will  be  evaluated  in  the  regular  OER.  Any  dimension  which  is  not  evaluated 
shall  be  marked  "not  observed."  A  Section  9  comparison  or  rating  scale  mark  and  Section  10 
comments on the officer’s potential are required. This OER does NOT count for continuity. 

 
 
Article 10.A.4.h. requires the preparation of a special, derogatory OER whenever an offi-
cer  is  relieved  for  cause  (RFC)  from  his  or  her  duty  as  a  commanding  officer  (CO).    The 
Reported-on Officer is shown the OER by the Reporting Officer before the OER is forwarded to 
the Reviewer  and is permitted to submit an addendum of comments to explain a failure or to 
provide an alternate view of his or her performance within 14 days of receiving the OER from 
the  Reporting  Officer.    A  derogatory  OER  prepared  under  this  article  counts  for  continuity.  
Article 10.A.4.h.2.d. states that 
 

[t]he Reviewer shall ensure that the evaluation of the Reported-on Officer is consistent and that 
the derogatory information is substantiated. If the Reviewer finds otherwise, he or she shall return 
the  report  to  the  Reporting  Officer  for  additional  information  and/or  clarifying  comments.  Any 
substantive changes to the OER require its return to the Reported-on Officer to provide another 
14-day opportunity for the Reported-on Officer to revise the addendum. 

 
Responsibilities of the Command and Rating Chain 
 
 
Article 10.A. of the Personnel Manual governs the preparation of officers’ OERs. Article 
10.A.1.b.1. states that “Commanding officers must ensure accurate, fair, and objective evalua-
tions are provided to all officers under their command.”  Every officer normally has a “rating 
chain” of three senior personnel, including a Supervisor, a Reporting Officer, and a Reviewer.  
Personnel  Manual,  Article  10.A.2.e.1.e.    Article  10.A.2.b.2.b.  states  that  each  command  must 
designate and publish an officer’s rating chain.  Article 10.A.1.c.4. states that the Supervisor is 
“[n]ormally, the individual to whom the Reported-on Officer answers on a daily or frequent basis 
and from whom the Reported-on Officer receives the majority of direction and requirements.”  
The Reporting Officer is normally the Supervisor’s supervisor, and the Reviewer is normally the 
Reporting Officer’s supervisor. 
 

Article 10.A.2.d.2.a. states that it is the responsibility of the Supervisor to evaluate the 
reported-on officer in the execution of her duties and to prepare the Supervisor’s portion of the 
OER form. 

 
Article 10.A.2.e.2.a. states that it is the responsibility of the Reporting Officer to evaluate 
the reported-on officer based on direct observation, reports of the Supervisor, and other reliable 
reports and to prepare the Reporting Officer’s portion of the OER form.  Article 10.A.2.e.2.c. 
states that an Reporting Officer 

 
[e]nsures  the  Supervisor  fully  meets  responsibilities  for  administration  of  the  OES.  Reporting 
Officers are expected to hold designated Supervisors accountable for timely and accurate evalua-
tions. The Reporting Officer shall return a report for correction or reconsideration, if the Supervi-
sor’s  submission  is  found  inconsistent  with  actual  performance  or  unsubstantiated  by  narrative 
comments. The Reporting Officer may not direct that an evaluation mark or comment be changed. 
 
Article  10.A.2.f.2.a.  states  that  the  Reviewer  “[e]nsures  the  OER  reflects  a  reasonably 
consistent picture of the Reported-on Officer’s performance and potential.”  Article 10.A.2.f.2.b. 
states that the Reviewer “[a]dds comments as necessary, using form CG-5315 (series), that fur-
ther address the performance and/or potential of the Reported-on Officer not otherwise provided 
by the Supervisor or Reporting Officer.”  Article 10.A.2.f.2.c. states that the Reviewer “[e]nsures 
the Supervisor and the Reporting Officer have adequately executed their responsibilities under 
the OES. The Reviewer shall return an OER to the Reporting Officer to correct errors, omissions, 
or  inconsistencies  between  the  numerical  evaluation  and  written  comments.  However,  the 
Reviewer may not direct in what manner an evaluation mark or comment be changed.”  
 
Instructions for Preparing an OER 

 
Article 10.A.4.c.3. states that block 2 of an OER shall reference any Punitive Letter of 

Admonition or Censure received by the officer during the evaluation period. 

 
Article 10.A.4.c.4. instructs Supervisors to assign marks and write comments for the first 
thirteen  performance  categories  on  an  OER  as  follows  (nearly  identical  instructions  appear  in 
Article  10.A.4.c.7.  for  Reporting  Officers,  who  complete  the  rest  of  the  OER,  except  for  any 
comments the Reviewer may choose to add on a separate page): 
 

b.  For each evaluation area, the Supervisor shall review the Reported-on Officer's performance 
and qualities observed and noted during the reporting period.  Then, for each of the performance 
dimensions, the Supervisor shall carefully read the standards and compare the Reported-on Offi-
cer's performance to the level of performance described by the standards.  The Supervisor shall 
take care to compare the officer's performance and qualities against the standards—not to other 
officers and not to the same officer in a previous reporting period.  After determining which block 
best describes the Reported-on Officer's performance and qualities during the marking period, the 
Supervisor fills in the appropriate circle on the form in ink. 

•   •   • 

d.    In  the  "comments"  block  following  each  evaluation  area,  the  Supervisor  shall  include  com-
ments citing specific aspects of the Reported-on Officer's performance and behavior for each mark 
that deviates from a four.  The Supervisor shall draw on his or her observations, those of any sec-
ondary supervisors, and other information accumulated during the reporting period. 
 

 e.    Comments  should  amplify  and  be  consistent  with  the  numerical  evaluations.    They  should 
identify specific strengths and weaknesses in performance.  Comments must be sufficiently spe-
cific to paint a succinct picture of the officer's performance and qualities which compares reasona-
bly  with  the  picture  defined  by  the  standards  marked  on  the  performance  dimensions  in  the 
evaluation area.  Mere repetition or paraphrasing of the standards is not sufficient narrative justifi-
cation for below or above standard marks. 

•   •   • 

g.  A mark of four represents the expected standard of performance. Additional specific perform-
ance observations  must be included  when an officer has been assigned a  mark of  five  or six to 
show how they exceeded this high level of performance. … 
 
 
Article 10.A.4.c.8.a. instructs the reporting officer to complete the comparison scale on 
an OER by filling in the circle that most accurately reflects his or her ranking of the reported-on 
officer  in  comparison  to  all  other  officers  of  the  same  grade  whom  the  reporting  officer  has 
known.  Article 10.A.4.c.9. states that in the comment block titled “Potential,” the reporting offi-
cer  “shall  comment  on  the  Reported-on  Officer’s  potential  for  greater  leadership  roles  and 
responsibilities in the Coast Guard.” 
 

Enclosure  6  of  the  Military  Justice  Manual  provides  the  following  text  for  a  Punitive 

Letter of Admonition awarded at NJP: 

 
1. In accordance with references (a), (b), and (c), you are hereby [REPRIMANDED or ADMO-
NISHED] for your conduct at [PLACE] on [DATE]. You behaved in a reproachable manner in 
that  you  [SPECIFY  THE  EXACT  CONDUCT  BEING  ADMONISHED  OR  REPRIMANDED, 
EXPLAINING SURROUNDING FACTS AND CIRCUMSTANCES].  

 

2. You are advised of your right to appeal to [APPROPRIATE NJP APPEAL AUTHORITY] in 
accordance with Section 1.F. of reference (b).  
 

FINDINGS AND CONCLUSIONS 

The Board makes the following findings and conclusions on the basis of the applicant's 

 
 
military record and submissions, the Coast Guard's submissions, and applicable law: 
 

The Board has jurisdiction concerning this matter pursuant to 10 U.S.C. § 1552.  

1. 

The application was timely. 
 

2. 

The applicant alleged that his promotion to LT on May 21, 2007, was improperly 
delayed under Article 5.A.13.f.3. of the Personnel Manual because (a) the officer who notified 
him of the delay in a memorandum dated May 2, 2007, was a lieutenant assigned to CGPC-opm, 
rather than Commander, CGPC-opm; and (b) on May 21, 2007, he was not under investigation, 
nor was his special board “pending,” as required by 14 U.S.C. § 271(f) for the delay of a promo-
tion.  Absent specific evidence to the contrary, the Board presumes that Coast Guard officers, 
including the applicant’s chain of command and those within CGPC-opm, have acted correctly, 
lawfully, and in good faith in performing their duties.8  The applicant alleges and bears the bur-

                                                 
8 33 C.F.R. § 52.24(b); Arens v. United States, 969 F.2d 1034, 1037 (Fed. Cir. 1992); Sanders v. United States, 594 
F.2d 804, 813 (Ct. Cl. 1979).   

3. 

4. 

den of proving by a preponderance of the evidence9 that the Coast Guard committed an error or 
injustice in removing his name from the list of selectees for promotion.  
 
 
Article 5.A.13.f.1. of the Personnel Manual states that “[e]ach officer in the chain 
of command or Commander (CGPC-opm) is responsible for delaying a promotion if he or she 
knows  the  appointee  has  disqualified  him  or  herself  after  being  placed  on  a  promotion  list.”  
Article 5.A.13.f.3. states that “[i]f Commander (CGPC-opm) initiates delaying a promotion, he 
or  she  shall  advise  the  officer  concerned  in  writing  of  the  reasons  for  so  doing  and  require 
acknowledgment of receipt.”  The applicant’s notification of delay, dated May 2, 2007, is signed 
by a lieutenant within CGPC-opm rather than by the head of that office.  The applicant alleges 
that the fact that the notification was signed by a lieutenant proves that the delay of his promo-
tion  was  not  properly  authorized  by  Commander  (CGPC-opm).    Article  5.A.13.f.3.,  however, 
does not require that Commander (CGPC-opm) personally notify the officer that he has delayed 
that officer’s promotion.  A member of his staff may be delegated to send the notification.10  The 
Board is not persuaded that the fact that the notification memorandum was signed by a subordi-
nate  of  Commander  (CGPC-opm)  overcomes  the  presumption  that  the  lieutenant  acted  with 
proper authority in that Commander (CGPC-opm) had in fact authorized the delay of the appli-
cant’s promotion and delegated the notification to the lieutenant.  In this regard, the Board notes 
that the delay of the applicant’s promotion was long expected.  A comment in OER1, for exam-
ple, indicates that the delay of the applicant’s promotion was anticipated by his chain of com-
mand at least as early as March 2007, when they prepared OER1.  The comment states that the 
applicant “was already selected for O-3 based on performance at previous unit, but the member’s 
promotion & record should be reviewed due to this NJP.”  Moreover, the Chief of the Officer 
Boards Section, which is part of CGPC-opm, stated in his declaration that his office first became 
aware of the adverse information about the applicant on February 2, 2007, when the applicant 
was temporarily relieved for cause.  His declaration indicates that the Officer Boards Section was 
aware  of  and  had  been  working  with  the  chain  of  command  on  the  applicant’s  case  for  three 
months when the notification of delay of promotion was sent to the applicant on May 2, 2007.  
Therefore, the mere fact that the notification was signed by a lieutenant within CGPC-opm rather 
than  Commander  (CGPC-opm)  does  not  persuade  the  Board  that  the  delay  of  the  applicant’s 
promotion was unauthorized. 
 

 Title 14 U.S.C. § 271(f) states the “promotion of an officer who is under investi-
gation or against whom proceedings of a court-martial or a board of officers are pending may be 
delayed without prejudice by the Secretary until completion of the investigation or proceedings.”  
The applicant alleged that he should have been promoted on May 21, 2007, as scheduled and that 
his promotion was illegally delayed because no board of officers was “pending” against him and 
he was not “under investigation.”  He pointed out that in United States v. Law, 11 F.3d 1061, 
1065-66 (Fed. Cir. 1993), the court rejected the plaintiff’s argument that a special board was not 
“pending” until the officers for the board were selected and found that “selection of officers for 
the Special Board thereafter was merely ministerial.  We conclude that the interpretation of § 
                                                 
9 33 C.F.R. § 52.24(b).  
10  U.S.  COAST  GUARD,  COMDTINST  M5000.3B,  UNITED  STATES  COAST  GUARD  REGULATIONS,  Chap.  4-1-2.A. 
(Change 2, 1994) (“At a commanding officer’s discretion, portions of [his] authority may be delegated to subordi-
nates for the execution of details, but such delegation of authority shall in no way relieve the commanding officer of 
continued responsibility … ”). 

5. 

 
6. 

271(f) that matters were ‘pending’ from the date the board was authorized does not conflict with 
any  provision  of  any  applicable  statute  and  is  reasonable.    By  analogy,  court  proceedings  are 
‘pending’ before a case is assigned to a particular judge or judges.”  In the instant case, Com-
mander, CGPC notified the applicant that the special board would be convened on June 14, 2007, 
and the applicant contends that he should have been promoted because the special board was not 
“pending” until that date.   
 

In  the  advisory  opinion,  the  JAG  ignored  the  question  of  the  date  the  special 
board  began  to  pend.    “Pending”  means  “[b]egun,  but  not  yet  completed;  during;  before  the 
conclusion of; prior to the completion of; unsettled; undetermined; in process of settlement or 
adjustment.  Thus, an action or suit is ‘pending’ from its inception until the rendition of a final 
judgment.”11  In Law, the court held that “the interpretation of § 271(f) that matters were ‘pend-
ing’ from the date the board was authorized does not conflict with any provision of any applica-
ble statute and is reasonable.”  The court did not expressly state that it was unreasonable for a 
special board to be considered “pending” before the officer is notified that it has been initiated.  
In this regard, the Board notes that by June 14, 2007, the Officer Boards Section in CGPC-opm 
had been aware of and working on the applicant’s case for more than four months when Com-
mander, CGPC officially notified the applicant that special board proceedings had been initiated.  
In addition, the delay of promotion notification dated May 2, 2007, cited the article of the Per-
sonnel Manual which authorizes the Commandant to convene a special board of officers when 
adverse information is received that casts doubt on the qualification of an officer on a promotion 
list.12 

The Board need not decide, however, whether a special board was “pending” for 
the applicant on May 21, 2007, because the Board agrees with the JAG that the applicant was, in 
fact, the subject of an investigation by CGPC at that time.  The applicant argues that he was not 
“under investigation” pursuant to 14 U.S.C. § 271(f) because the investigation that resulted in his 
NJP on February 28, 2007, had been completed, and his chain of command had not convened an 
administrative investigation under the Administrative Investigations Manual.  The Board is not 
persuaded, however, that Congress intended such a narrow definition of “investigation.”  As indi-
cated in the declaration of the Chief of the Officer Boards Section and in Article 5.A.13.f. of the 
Personnel Manual, the decision of whether to authorize a special board is based on a review of 
the officer’s record.  Therefore, after an officer’s chain of command first makes CGPC aware of 
“adverse information” that casts doubt on the officer’s qualification and before the decision to 
convene a special board is made, CGPC-opm must gather the adverse information in the appli-
cant’s record in accordance with regulation.  In this case, under Articles 10.A.3.c.1 and 10.A.4.h. 
of  the  Personnel  Manual,  the  applicant’s  NJP  and  RFC  required  preparation  of  two  special 
OERs—OER1  and  OER2—and  on  May  21,  2007,  OER2  was  not  yet  complete  because  the 
                                                 
11 BLACK’S LAW DICTIONARY 1291 (4th ed. 1968). 
12  PERSONNEL  MANUAL,  supra  note  6,  Art.  5.A.13.f.  states,  “1.  Each  officer  in  the  chain  of  command  or  Com-
mander, (CGPC-opm) is responsible for delaying a promotion if he or she knows the appointee has disqualified him 
or herself after being placed on a promotion list.  Disqualification here means any circumstance which casts doubt 
on the moral or professional qualifications of the officer concerned, including pending action by a board of officers, 
courts-martial, or investigative proceedings (14 U.S.C. 271(f)). … 3.  If Commander (CGPC-opm) initiates delaying 
a promotion, he or she shall advise the officer concerned in writing of the reasons for so doing and require acknowl-
edgment of receipt.  4.  The Commandant shall refer the case to a board of officers to recommend to the President 
whether to remove the selectee from the promotion list.” 

applicant had not yet submitted his addendum.  Moreover, CGPC had not finished reviewing his 
record.  Therefore, the Board finds that on May 21, 2007, the record was incomplete, and CGPC-
opm was still gathering the information about the applicant needed to complete the record so that 
it could be fairly and properly reviewed to determine whether a special board was needed.  Thus, 
he was still under investigation for the purposes of 14 U.S.C. § 271(f) and Article 5.A.13.f. of the 
Personnel Manual on May 21, 2007.  Moreover, the applicant had been notified of this fact on 
May 2, 2007. 

The applicant argued that it is nonsense to consider CGPC’s collection of special 
OERs from the applicant’s chain of command and “record read” an investigation of the applicant 
for the purposes of 14 U.S.C. § 271(1) and that the JAG is defending procedures that are not 
compliant with that statute.  The Board finds, however, that the applicant’s proposed interpreta-
tion of the statute is not reasonable.  According to the applicant’s interpretation, if the investiga-
tion that resulted in his NJP had ended on May 20, 2007, the Coast Guard would have had to 
promote him the next day as scheduled unless Commander, CGPC had immediately authorized 
and initiated a special board or convened one of the types of investigation authorized under the 
Administrative  Investigations  Manual.   The  fact  that  CGPC’s  procedure  of  gathering  properly 
documented information (special OERs) and conducting a “record read” is not one of the types 
of investigations authorized under the Administrative Investigations Manual does not persuade 
the Board that CGPC’s procedure is not, in fact, a type of investigation of an officer regularly 
conducted whenever a chain of command informs CGPC that there is adverse information that 
casts doubt on that officer’s qualification for promotion, in accordance with Article 5.A.13.f.1. of 
the  Personnel  Manual.    Therefore,  the  Board  finds  that  the  applicant  has  not  proved  that  the 
Coast Guard violated 14 U.S.C. § 271(f) by not promoting him to LT on May 21, 2007. 

 
7. 

 
8. 

The  applicant  asked  the  Board  to  expunge  OER1  and  OER2  from  his  record 
because they contain misstatements of fact and were not prepared by his designated rating chain.  
He  also  argued  that  the  written  comments  in  OER1  are  insufficiently  specific  under  Article 
10.A.4.c.4.e. of the Personnel Manual. Absent specific evidence to the contrary, the Board pre-
sumes  that  the  members  of  an  applicant’s  rating  chain  have  acted  “correctly,  lawfully,  and  in 
good faith” in preparing their evaluations.13  Once an applicant has rebutted the presumption of 
regularity14 by presenting at least some evidence that “specifically and convincingly contradicts 
his  rating  officials’  marks  and  comments,”15  the  Board  weighs  the  evidence  in  the  record  to 
determine  whether  the  applicant  has  met  her  burden  of  proof—the  preponderance  of  the  evi-
dence—with respect to the challenged OER.16  To be entitled to relief, the applicant must prove 

                                                 
13 Arens v. United States, 969 F.2d 1034, 1037 (Fed. Cir. 1992); Sanders v. United States, 594 F.2d 804, 813 (Ct. Cl. 
1979). 
14 33 C.F.R. § 52.24(b); see Final Decision, BCMR Docket No. 2000-194, at 35-40 (DOT BCMR, Apr. 25, 2002, 
approved by the Deputy General Counsel, May 29, 2002) (rejecting the “clear and convincing” evidence standard 
recommended by the Coast Guard and adopting the “preponderance of the evidence” standard for all cases prior to 
the promulgation of the latter standard in 2003 in 33 C.F.R.§ 52.24(b)). 
15  Final  Decision,  BCMR  Docket  No.  2000-194,  at  40  (DOT  BCMR,  Apr.  25,  2002,  approved  by  the  Deputy 
General Counsel, May 29, 2002). 
16  33  C.F.R.  § 52.24(b).    In  determining  the  preponderance  of  the  evidence,  the  Board  continues  to  consider  the 
evidentiary  weight of the rating chain’s assessment even though the presumption of regularity  has been rebutted.  
See Texas Dep’t of Community Affairs v. Burdine, 450 U.S. 248, 256 n.10 (1981). 

by a preponderance of the evidence that the disputed OERs were adversely affected by a “mis-
statement of significant hard fact,” factors “which had no business being in the rating process,” 
or a prejudicial violation of a statute or regulation.17   Moreover, as stated in BCMR Docket No. 
151-87, the Board will not order an OER to be expunged in its entirety “unless the Board finds 
that the entire report is infected with the errors or injustices alleged; unless the Board finds that 
every significant comment in the report is incorrect or unjust; or unless the Board finds it impos-
sible or impractical to sever the incorrect/unjust material from the appropriate material.”   

 
9. 

 
10. 

 
11. 

With respect to the comments in OER1 and the attached Punitive Letter of Admo-
nition, the Board finds that the comments therein are sufficiently specific to provide the reader 
with a good understanding of how the  applicant’s conduct violated the  UCMJ and resulted in 
NJP.  OER1 states that the applicant was derelict in his duty, in violation of Article 92 of the 
UCMJ, by failing to leave the XXXX in command of a qualified individual.  OER1 further states 
that he failed to obey an order, in violation of Article 92, by delaying his return to the XXXX for 
more  than  28  hours  after  being  ordered  to  return.    The  Board  finds  that  these  comments  are 
sufficiently  specific  to  comply  with  Articles  10.A.4.c.  and  10.A.3.c.1.b(1)  of  the  Personnel 
Manual in that they succinctly explain to the reader how the applicant was derelict in his duty—
by  leaving  his  patrol  boat  without  leaving  a  qualified  member  in  command—and  how  he 
disobeyed an order—by failing to return to his patrol boat timely when ordered to return.  The 
Punitive Letter of Admonition provides substantially the same information about the applicant’s 
dereliction of duty and failure to obey an order and conforms to the requirements for such letters 
shown in Enclosure 6 of the Military Justice Manual.  Therefore, the Board finds that the appli-
cant has not proved that either OER1 or the attached Punitive Letter of Admonition violates any 
applicable regulation or is unfair because of an alleged lack of specificity. 

The applicant alleged that the disputed OERs contain many misstatements of fact, 
but he failed to submit substantial evidence to support his allegations.  For example, with respect 
to  the  comments  in  OER2,  he  did  not  prove  that  his  chain  of  command  was  unreasonable  in 
expecting  him  to  have  renewed  his  DWO  certification  during  the  approximately  six  weeks 
between his return stateside and his assumption of command of the XXXX; that he failed to take 
his  superiors’  advice  regarding  the  fuel  level  of  the  XXXX;  that  he  failed  to  show  “prudent 
seamanship in near miss with commercial [vessel]”; that he improperly invited media aboard the 
XXXX for a mission; or that he did not send argumentative or insubordinate emails to his chain 
of command.  The Board finds that the applicant has not proved that either disputed OER con-
tains any “significant misstatement of hard fact.”18 

The applicant alleged that the disputed OERs should be expunged because they 
were not prepared by his published, designated rating chain.  Article 10.A.2.b.2.b. of the Person-
nel Manual requires that the designated rating chain of each officer be published.  The applicant 
submitted SECXXXINST 1611.1, dated February 8, 2006, which designates the rating chain of 
the CO of the XXXX (the applicant) as follows:  Supervisor: the Chief of the Sector Response 
Department; Reporting Officer: the Sector Commander; and Reviewer: the xxxxxx District Chief 
of  Response.    The  disputed  OERs,  however,  are  signed  by  the  Chief  of  the  Sector  Response 
                                                 
17  Hary v. United States, 618 F.2d 704, 708 (Ct. Cl. 1980), cited in Lindsay v. United States, 295 F.3d 1252, 1259 
(Fed. Cir. 2002). 
18 Id. 

Department as Supervisor, the Deputy Sector Commander as Reporting Officer, and the Sector 
Commander as Reviewer.  Roughly speaking, instead of the first, third, and fourth officers in the 
applicant’s chain of command preparing the OERs as designated in SECXXXINST 1611.1, the 
first,  second,  and  third  officers  in  his  chain  of  command  prepared  the  OERs.    The  signature 
blocks on the OERs indicate that the Deputy Sector Commander served as the Reporting Officer 
for both OERs even though he was not a designated member of the applicant’s rating chain.  In 
addition,  the  Sector  Commander,  who  was  the  applicant’s  CO,  served  as  the  OER  Reviewer, 
even though in SECXXXINST 1611.1, he was designated as the Reporting Officer.  The Coast 
Guard did not deny that the rating chain published in the SECXXXINST 1611.1 dated February 
8, 2006, was the applicant’s designated rating chain in 2007.  Therefore, the Board finds that the 
applicant has proved by a preponderance of the evidence that the Coast Guard violated Article 
10.A.2.b.2.b.  of  the  Personnel  Manual  when  CGPC  entered  two  special  OERs  in  his  record 
prepared at least in part by an unpublished rating chain. 

In the advisory opinion for this case, the JAG argued that “[a]ssuming arguendo 
that failure to follow the Sector Instruction is a violation of regulation, the applicant fails to show 
prejudice.”  In so arguing, the JAG contradicts findings made in several advisory opinions that 
the JAG has submitted in prior BCMR cases.  In the past, when applicants have proved that they 
were evaluated by the wrong rating chain or an improperly designated rating chain, the Coast 
Guard has consistently admitted that the failure to use a published rating chain was a violation of 
the Personnel Manual,19 though not necessarily a prejudicial one. 

 
12. 

 
13. 

Only prejudicial violations of the regulations justify correction of an OER.20  The 
applicant alleged that the insertion of the Deputy Sector Commander into his rating chain was 
prejudicial but submitted nothing to show that the Deputy Sector Commander  was prejudiced 
against him or that the disputed OERs would have been better had they been prepared by the 
published rating chain.  Both special OERs were required by the Personnel Manual because of 
the applicant’s NJP and RFC.  Therefore, their existence and the negative comments therein do 
not prove that the  erroneous composition of the rating chain per se  prejudiced the  applicant’s 
record.    No  matter  which  officers  in  the  applicant’s  chain  of  command  prepared  them,  under 
Articles 10.A.3.c.1.b. and 10.A.4.h. of the Personnel Manual, two special OERs with low marks 
and negative comments reflecting and explaining his NJP and RFC had to be entered in his per-
sonnel record. 
 

The Supervisor’s section of each disputed OER was properly prepared and signed 
by the designated Supervisor—the Chief of the Sector’s Response Department.  However, the 
Reporting Officer’s section of each disputed OER was prepared by the wrong officer, as was the 
“Reviewer Comments” page of OER2, since the Sector Commander who signed that page was 
supposed to serve as the Reporting Officer.  Therefore, the Board must determine whether the 
applicant’s record was prejudiced by these errors in the rating chain, especially whether either or 
both of the disputed OERs would likely have been less critical of the applicant’s conduct, per-
formance, and leadership had the Sector Commander served correctly as the Reporting Officer, 
instead of the Reviewer.  In this regard, the Board notes that the Sector Commander, as the appli-

14. 

                                                 
19  See e.g., Final Decisions, BCMR Docket Nos. 2006-085; 2006-036; 2003-011; and 2002-101. 
20 Hary, 618 F.2d at 708. 

cant’s  commanding  officer,  punished  the  applicant  at  mast  and  recommended  to  the  District 
Commander that the applicant be relieved for cause.  In addition, the Sector Commander signed 
both  disputed  OERs  as  the  Reviewer,  which  indicates  that  he  found  no  “errors,  omissions,  or 
inconsistencies between the numerical evaluation and written comments,” as required by Article 
10.A.2.f.2.c. of the Personnel Manual.  Moreover, because OER2 was a derogatory OER pre-
pared under Article 10.A.4.h., in signing OER2 as the Reviewer, the Sector Commander had to 
find that the derogatory information in the Supervisor’s and Reporting Officer’s sections of the 
OER was “substantiated.”21   

 
15. 

 
16. 

The  Sector  Commander’s  signature  as  Reviewer  does  not  prove  that  he  would 
have assigned exactly the same low marks and comments that were provided by the Deputy Sec-
tor Commander.  However, because the Sector Commander took the applicant to mast; signed the 
Punitive Letter of Admonition; recommended the applicant’s relief for cause; served as Reviewer 
for both disputed OERs; and found that the derogatory information entered by the Supervisor and 
Deputy Sector Commander in OER2 was substantiated even after reading the applicant’s adden-
dum, the Board is not persuaded that the Sector Commander would have assigned the applicant 
better marks and comments in the disputed OERs than those signed by the Deputy Sector Com-
mander.  The Board notes that on the “Reviewer Comments” page for OER2, the Sector Com-
mander attempted to explain some of the applicant’s poor performance, or put it in perspective, 
by describing not only his “short-comings” but also the unusual operational requirements of his 
prior position as the Executive Officer of patrol boat in a combat zone and the unusually unfor-
giving requirements of a CO.  The Sector Commander noted that the applicant’s short-comings 
“could have been overcome in almost any other O2 [LTJG] position that allowed more leeway 
for professional growth.”  Moreover, he wrote that the applicant “should be given every chance 
to continue CG career, and to be promoted to O3.” 

Given  the  Sector  Commander’s  comments  on  the  “Reviewer  Comments”  page, 
the  Board  is  not  persuaded  that  he  actually  disagreed  with  any  of  the  marks  or  comments 
assigned by the Supervisor or by the Deputy Sector Commander in the Reporting Officer’s sec-
tions of the disputed OERs, which the Sector Commander should have signed as the designated 
Reporting  Officer.    In  this  regard,  the  Board  notes  that  the  Sector  Commander  added  the 
“Reviewer Comments” knowing that the Reporting Officer’s marks and comments were highly 
critical of the applicant’s performance and leadership, and yet he did not actually disagree with 
or contradict any of those marks and comments.  Under Article 10.A.2.f.2. of the Personnel Man-
ual, the purpose of a “Reviewer Comments” page is to “[a]dd[] comments as necessary … that 
further address the performance and/or potential of the Reported-on Officer not otherwise pro-
vided by the Supervisor or Reporting Officer.”  If the Sector Commander had disagreed with the 
Deputy  Sector  Commander’s  marks  and  comments,  the  Board  is  persuaded  that  the  Sector 
Commander would have done so on a “Reviewer Comments” page or, with respect to OER2, 
would have found that the derogatory information was not substantiated and returned the OER 
for  revision  to  the  Supervisor  and  Deputy  Sector  Commander,  as  required  under  Article 
10.A.4.h. of the Personnel Manual.  Instead, he summarized the applicant’s short-comings and 
                                                 
21  PERSONNEL  MANUAL,  supra  note  6,  Art.  10.A.4.h.2.d.  (“The  Reviewer  shall  ensure  that  the  evaluation  of  the 
Reported-on  Officer  is  consistent  and  that  the  derogatory  information  is  substantiated.  If  the  Reviewer  finds 
otherwise,  he  or  she  shall  return  the  report  to  the  Reporting  Officer  for  additional  information  and/or  clarifying 
comments.”). 

added  comments  that  put  the  applicant’s  poor  performance  and  RFC  in  perspective  by  high-
lighting the tremendous challenge faced by any LTJG appointed to command afloat and the “low 
tolerance for failure and associated high career risk tat comes with assignment as CO.”  In light 
of the fact that it was the Sector command that initiated the delay of the applicant’s promotion 
under  Article  5.A.13.f.  of  the  Personnel  Manual,  the  Sector  Commander’s  comment  that  the 
applicant should have “every chance” to be promoted does not persuade the Board that the Sec-
tor Commander actually disagreed with any of the marks or comments in the disputed OERs.  
The Board finds insufficient evidence in the record to conclude that the alteration of the appli-
cant’s rating chain prejudiced the content of  either disputed OER or the content of his record 
when  it  was  reviewed  by  CGPC  and  by  the  special  board  of  officers,  which  resulted  in  his 
removal from the promotion list. 

Although the applicant has proved that the Coast Guard committed an error with 
regard  to  the  composition  of  his  rating  chain,  he  has  not  proved  that  the  violation  of  Article 
10.A.2.b.2.b. of the Personnel Manual was prejudicial to his record.  As stated above, the com-
mand was required to prepare a special OER because of the applicant’s violations of the UCMJ 
and  NJP  and  another  special,  derogatory  OER  because  of  his  RFC.      The  applicant  has  not 
proved that his command committed any error or injustice with regards to the NJP or RFC.  Nor 
has the applicant proved that any of the comments in the special OERs are misstatements of fact.  
The Board is not persuaded that the marks and comments in either special OER would have been 
significantly  better  had  all  of  the  officers  on  the  applicant’s  designated  rating  chain  served  in 
their designated capacities.  Therefore, the Board finds that under the circumstances of this case, 
the use of a rating chain in 2007 different from that which was designated in writing in 2006 was 
a harmless error.22  In addition, because on May 21, 2007, CGPC was still conducting its own 
investigation by gathering information to complete the applicant’s record in preparation for the 
“record read” and in light of the NJP and RFC in his record, the Board finds that the Coast Guard 
committed no error or injustice in refusing to promote the applicant.  The Board finds no basis in 
the record for removing or altering either disputed OER, for disturbing the decision of CGPC or 
the outcome of the special board proceedings, or for promoting the applicant to LT. 

 
17. 

 
18. 
 
 
 

Accordingly, the applicant’s requests should be denied.  

 

                                                 
22 See FED. R. CIV. P. 61 (“Harmless Error: … At every stage of the proceeding, the court must disregard all errors 
and defects that do not affect any party’s substantial rights.”); Texas v. Lesage, 528 U.S. 18, 21 (1999) (“[W]here a 
plaintiff challenges a discrete governmental decision as being based on an impermissible criterion and it is undis-
puted that the government would have made the same decision regardless, there is no cognizable injury warranting 
relief”); Quinton v. United States, 64 Fed. Cl. 118, 125 (2005) (finding that harmlessness requires that there be “no 
substantial nexus or connection” between the proven error and the prejudicial record that the applicant wants the 
Board to remove or correct); Engels v. United States, 678 F.2d 173, 175 (Ct. Cl. 1982) (finding that an error in an 
officer’s military record is harmless unless the error is “causally linked with” the record the officer wants corrected); 
Hary, 618 F.2d at 707-09 (finding that  the plaintiff  had to show that  the proven error “substantially affected the 
decision to separate him” because “harmless error … will not warrant judicial relief.”). 

The  application  of  former  LTJG  xxxxxxxxxxxxxxxxxxxx,  USCG,  for  correction  of  his 

ORDER 

 

 
 

 
 

 
 

 
 

 
 

 
 

 

 
 Vicki J. Ray 

 

 

 
 George A. Weller 

 

 

 

 

 
 
 Janice Williams-Jones 

 

 

 

 

 

 

 

 

 

 

 
 

 
 

 
 

military record is denied. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

 
 

 
 

 
 

 
 

 
 

 
 



Similar Decisions

  • CG | BCMR | OER and or Failure of Selection | 1998-043

    Original file (1998-043.pdf) Auto-classification: Denied

    (2)(c) states that “[f]or any officer whose Reporting Officer is not a Coast Guard commissioned officer, the Reviewer shall describe on a separate sheet of paper the officer’s ‘Leadership and Potential’ and include an additional ‘Comparison Scale’ mark.” Article 10.A.1.a. Three of the four OERs he received while at the Xxxx are the disputed OERs. Upon review of the [applicant’s] 07 June 199x OER, I felt the marks and comments by both the Supervisor and the Reporting Officer merited...

  • CG | BCMR | OER and or Failure of Selection | 1998-073

    Original file (1998-073.pdf) Auto-classification: Denied

    APPLICANT'S ALLEGATIONS The applicant alleged that he received two negative and inaccurate OERs as a student engineer because his supervisor, the Engineer Officer on the cutter xxxx, incor- rectly administered his qualification process for the Student Engineering Program (SEP). Allegations Regarding the Second Reporting Period Aboard the xxxx The applicant also alleged that his supervisor failed to counsel him monthly, as required by the SEP Instruction, after April 199x. The record...

  • CG | BCMR | OER and or Failure of Selection | 1999-077

    Original file (1999-077.pdf) Auto-classification: Denied

    LCDR XX = Chief of the Command and XXX at XXX who allegedly informed the XXXX command that XXX was concerned about her performance at XXX. Xxxxx = Coast Guard xxxxx who served as xxxxx in the XXX and XXX xxxxxs and is now the xxxxxxx of the Coast Guard (see statement). However, the only complex xxxxx [the applicant] had been assigned to as an assistant [xxx xxx] in order to gain experience had been dismissed prior to xxx, and she had not yet been in xxxxx on anything other than [the...

  • CG | BCMR | OER and or Failure of Selection | 2007-138

    Original file (2007-138.pdf) Auto-classification: Denied

    This final decision, dated March 13, 2008, is approved and signed by the three duly APPLICANT’S REQUEST The applicant, a lieutenant commander (LCDR) in the Coast Guard Reserve, asked the Board to correct his officer evaluation report (OER) for the period June 1, 2005, to May 31, 2006, by • adding his days of active duty and number of inactive duty drills performed during the reporting period to the “Description of Duties” in the disputed OER; removing four derogatory sentences in block 5 of...

  • CG | BCMR | OER and or Failure of Selection | 2003-040

    Original file (2003-040.pdf) Auto-classification: Denied

    states that “[t]he Reported-on Officer may reply to any OER regardless of its content and have this reply filed with the OER,” allowing a member the opportunity to “express a view of performance which may differ from that of a rating official.” submitted: Article 10.A.4.g.8. of the Personnel Manual, a reporting officer is permitted to base his or her evaluation of the ROO’s performance on “…other reliable reports or records.” The applicant has submitted no evidence beyond his own affidavit...

  • CG | BCMR | OER and or Failure of Selection | 2007-027

    Original file (2007-027.pdf) Auto-classification: Denied

    CGPC stated that the applicant did not submit his OER input to his rating chain within 21 days of the end of the evaluation period as required by Article 10.A.2.c.2.f. states that it is the responsibility of each commanding officer to “[e]ncourage supervisors and reporting officers to properly counsel subordinates by providing them timely feedback at the end of each reporting period and providing copies of completed OERs to them prior to submission to the OER administrator.” Article...

  • CG | BCMR | OER and or Failure of Selection | 2002-134

    Original file (2002-134.pdf) Auto-classification: Denied

    This final decision, dated April 8, 2003, is signed by the three duly appointed APPLICANT’S REQUEST AND ALLEGATIONS The applicant asked the Board to correct three officer evaluation reports (OERs) in his record by including recommendations for promotion in block 11, where the reporting officer (RO) makes comments about an officer’s leadership and potential. In lieu of a recommendation for 2 Coast Guard officers are evaluated by a “rating chain” of three officers: the “supervisor,” who...

  • CG | BCMR | Discharge and Reenlistment Codes | 2002-110

    Original file (2002-110.pdf) Auto-classification: Denied

    Clearly the Coast Guard committed no error in taking the course of action it did at the time it did.” However, the Chief Counsel stated, in light of the xxxxxxxx xxxxxxxxxx recantation and the decision of the State to dismiss the charges, “the Coast Guard agrees that the results of the Boards of Inquiry and Review, as well as the OERs in question and the Applicant’s eligibility to gain a security clearance, should be revisited and the Applicant’s BCMR petition for relief should be favorably...

  • CG | BCMR | OER and or Failure of Selection | 2008-106

    Original file (2008-106.pdf) Auto-classification: Denied

    In support of this allegation, he submitted a statement from the commanding officer (CO) of the Training Center, who signed the 2003 OER as the Reporting Officer, even though he was not a designated member of the applicant’s rating chain: After reviewing the statements of personnel directly involved with [the applicant’s] performance during the marking period, I do not feel that the marks and comments in [his] OER for the above period accurately reflect his accomplishments during the period....

  • CG | BCMR | Advancement and Promotion | 2005-126

    Original file (2005-126.pdf) Auto-classification: Denied

    In recommending that the applicant's name be removed from the promotion list the board stated the following: [The applicant] . The Coast Guard's action was well within its authority. The special OER, the negative page 7, the investigation, the applicant's performance record, and his statement were available to the special board when it recommended the applicant's removal from the RPA captain promotion list.