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CG | BCMR | OER and or Failure of Selection | 1999-077
Original file (1999-077.pdf) Auto-classification: Denied
DEPARTMENT OF TRANSPORTATION 

BOARD FOR CORRECTION OF MILITARY RECORDS 

 
Application for Correction of 
the Coast Guard Record of: 
 
                                                                                     BCMR Docket No. 1999-077 
 
 
   

 

 
 

FINAL DECISION 

 
ANDREWS, Xxxx-Advisor: 
 
 
This is a proceeding under the provisions of section 1552 of title 10 and section 
425 of title 14 of the United States Code.  It was docketed on March 16, 1999, upon the 
BCMR’s receipt of the applicant’s completed application. 
 
 
members who were designated to serve as the Board in this xxxxx. 

This final decision, dated April 27, 2000, is signed by the three duly appointed 

APPLICANT’S REQUEST FOR RELIEF 

 

 
 
The applicant, an xxxxxxxxxx in the Coast Guard, asked the Board to correct her 
military record by removing three officer evaluations reports (OERs), correcting marks 
in other disputed OERs, removing her failures of selection for promotion to xxxxxx, and 
returning her to active duty.  
 
 
Specifically, the applicant asked that three marks of 41 in her OER for the evalua-
tion period March 26, 199x, to January 3, 199x (OER1), be corrected to marks of 5; that 
three OERs covering the periods January 4 to April 4, 199x (OER2), April 5 to May 31, 
199x (OER3), and December 1, 199x, to May 31, 199x (OER7), be removed and replaced 
with OERs marked “For Continuity Purposes Only”; that the marks on the comparison 
scales in all eleven of her OERs through May 31, 1998, be deleted (or, in the alternative, 
just  the  comparison  scale  marks  in  the  nine  OERs  she  received  while  on  active  duty 
from March 26, 199x, to March 25, 199x); that her failures of selection for promotion to 
xxxxxxx be removed; and that she be restored to active duty, receive back pay, and be 
considered for promotion by the next two xxxxxx active duty promotion list selection 
                                                 
1  In OERs, Coast Guard officers are evaluated on their performance in various categories, such as “Judg-
ment” and “Using Resources,” on a scale of 1 to 7, with 7 being the highest possible mark. 

boards.    As  an  alternative,  she  asked  the  Board  to  conduct  its  own  comparison  of 
records and consider promoting her to xxxxxxx or order the Coast Guard to convene a 
special board to do so. 
 

If the Board does not see fit to return her to active duty, she asked that she be 
returned to the inactive duty drilling Reserve, from which she was separated in June 
199x,  and  be  considered  for  promotion  by  the  next  two  xxxxxxx  inactive  duty 
promotion list selection boards.   

 
The  applicant  further  asked  that,  if  she  is  selected  for  promotion  by  the  first 
xxxxxx selection board to consider her record after it is corrected by the Board, her date 
of rank be back dated to the date of rank she would have had if she had been selected 
for promotion by the 199x selection board and that she be awarded the back pay and 
benefits  she  would  have  received  had  she  been  selected  for  promotion  by  the  199x 
selection board. 
 

SUMMARY OF APPLICANT'S ALLEGATIONS AND MILITARY CAREER 

The applicant alleged that after she received a direct commission as a xxxxxxxx 
in March 199x, her command, the xxxxxxxxxx  (XXX) “set [her] up for failure, poisoned 
the  well  with  [her]  supervisors,  and  ilxxxly  interfered  with  [her]  rating  chain’s 
independent performance of duty.”2  She alleged that the XXX negatively “prejudged” 

 

                                                 
2  The following military members and employees are referred to in this final decision: 
 
Coast Guard Personnel at xxx 
Mr.  X  =  Chief  of  the  xxx  at  xxx,  a  civilian  xxxxxx  who  supervised  the  applicant’s  work  prior  to  her 

enrollment at xxx and served as the supervisor for OER1 (see statement). 

Ms. X = Chief of the Xxxxxx at XXX and the supervisor for OER5 and OER6. 
Ms. XX = New chief of the Xxxxxx at XXX, who served as the supervisor for OER7. 
CAPT X = Chief of XXX and the reviewer for OER1 through OER7 (see statement). 
CDR X = Assistant chief of XXX and the reporting officer for OER1, OER3, OER4, and OER5 (see state-

CDR XX = New assistant chief of XXX and the reporting officer for OER6 through OER9 (see statement). 
LCDR X = Chief of the XXX at XXX and the supervisor for OER3 and OER4, who allegedly maintained a 

ment). 

hostile work environment. 

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. 

LCDR Y = Xxxxxx who allegedly was originally named as the xxxxxxxxxxx to help the applicant with the 

XXX and XXX xxxxxs. 

LT  X  =  Junior  xxxxxx  who  served  as  xxxxxxxxx  for  the  XXX  and  XXX  xxxxxs,  who  reported  on  the 

applicant’s performance to XXX, and who replaced her as xxxxxxxxxxx in the xxxxxs. 

LT Y = Junior xxxxxx assigned to XXXX after the applicant was removed. 
YN X = A yeoman and xxxxxx for the XXX and XXX xxxxxs who later worked in the Xxxxxx under Ms. 

Ms.  Y  =  Volunteer  xxxxxxx  and  then  an  xxxxxx  who  assisted  the  applicant  with  an  xxxx  xxxxx  in  the 

XX (see statement). 

Xxxxxx under Ms. XX (see statement). 

her very early in her Coast Guard career and that the resulting bias adversely affected 
the remainder of her service on active duty and inactive duty. 

 
Regarding her pre-service education and training, the applicant stated that she 
graduated from xxxxxxxx in 198x, worked as a xxxxxxx at a bank for three years, and 
graduated from xxxxxx in 199x, where she studied xxxxxxx and received honors for a 
xxxxxxxxx.    After  graduating  from  xxxxxxx,  she  gained  experience  in  xxxxxxx  while 
working as an associate for an xxxxxxxxx for almost two years. 

 
The applicant alleged that she left xxxxx in 199x to accept her commission in the 
Coast Guard with the understanding that she would gain xxxxxxxx in several practice 
areas relatively quickly.  Specifically, she understood that junior xxxxxxx at XXX were 
habitually assigned to the xxxxxxxxxxx (XXXX) xxxxx for nine months to gain xxxxxxx.3 

Allegations Regarding OER1 (March 26, 199x-January 3, 199x)4  

 
Upon receiving her direct commission and participating in a Direct Commission 
Officer Indoctrination class, the applicant stated, she was assigned to the XXXX of XXX 
in May 199x, where she advised field units regarding xxxxxxxxx issues, xxxxxxx, and 
requests under the xxxxxxxxxx.  A civilian xxxxxxx, Mr. X, was her supervisor.   

 

 

                                                                                                                                                             
Ms.  YY  =  A  civilian  xxxxxx  who  worked  in  LCDR  X’s  office  and  supported  the  applicant’s  allegations 

concerning the hostile work environment (see statement). 

 
Navy Personnel at XXXX 
CAPT XX = Commanding officer of XXXX and the reporting officer for OER2. 
CDR Y = Executive officer of XXXX and the supervisor for OER2. 
LCDR  YY  =  Senior  xxxxxx  at  XXXX  who  supervised  the  applicant’s  work  and  was  informed  of  XXX’s 

concerns by LCDR XX (see statement).  (footnote continues on next page) 

 
(footnote 2 continued from page 2) 
LCDR Z = Navy department head at XXXX who apparently submitted LCDR YY’s and his own sugges-

tions for OER2 to CDR Y, the supervisor for OER2. 

 
Others Who Submitted Statements 
LT Z = Classmate of the applicant at XXX (see statement). 
LT XX = Xxxxxx and friend of the applicant who served at XXXX East in Virginia (see statement). 
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). 

LCDR ZZ = Navy xxx who visited the applicant at the XXX (see statement). 
 
3  The Coast Guard and the Navy have a Memorandum of Understanding under which junior xxxxxxs 
work at XXXX or xxx for approximately nine months, either xxxxxx or xxxxxxx Coast Guard and Navy 
members, to gain experience in xxxxxxxxxxx. 
 
4  The rating chain for OER1 included Mr. X, chief of the Xxxxxx, as supervisor; CDR X, assistant chief of 
XXX, as reporting officer; and CAPT X, chief of XXX, as reviewer. 

In October 199x, she received temporary active duty orders to attend a xxxxxxx 
at the xxxxxxxx (XXX) for 10 weeks.  She completed the course in December 199x and 
was  certified  as  xxxxxxxxxxxxxxxxxxxxxxxxxxx.    However,  the  applicant  alleged,  she 
was the only student in her class at XXX to fail a xxxxxxx, although her performance 
was  no  worse  than  that  of  other  students.    She  alleged  that  one  student  whose 
“problems [were] at least as severe” as hers did not fail the xxxxxxxx. 

 
The applicant alleged that when she received OER1, she telephoned her supervi-
sor,  Mr.  X,  in  the  XXX  XXXX.    She  alleged  that  Mr.  X  told  her  that  he  had  been 
instructed by the reporting officer for OER1, CDR X, to lower some of the marks he had 
originally assigned her in OER1.  As a result, she alleged, he lowered the marks he had 
assigned her in blocks 3.b. (Using Resources), 3.d. (Responsiveness), and 5.a. (Looking 
Out for Others) from 5s to 4s.  The applicant submitted a copy of a telephone message 
pad on which, she alleged, she noted the changes Mr. X told her he had made during 
the phone call.  Her writing indicates that he told her he had originally assigned her 
marks of 5 in blocks 3.b., 3.d., and 5.a.  Therefore, the applicant asked the Board to raise 
those three marks in OER1 from 4s to 5s.  (All marks for OER1 appear in the table on 
page 11, below.) 

 
The  rating  chain’s  written  comments  in  OER1  are  quite  positive  but  stress  her 

need to “adapt to military life” and improve her military bearing and professionalism. 
 
Allegations Regarding OER2 (January 4, 199x-April 4, 199x)5 

 
After completing the course at XXX, the applicant was sent to XXXX in January 
199x.  However, she alleged, XXX “poisoned the well” for her at XXXX by informing her 
superiors there that she had failed the xxxxxxxx at XXX.  She alleged that the chief of 
XXX’s  Command  and  XXX,  LCDR  XX,  called  XXXX  to  check  on  her  progress  and 
expressed concern over her “performance at XXX.”   

 
As  evidence  that  she  was  “set  up  to  fail”  at  XXXX,  the  applicant  cited  her 
assignment in February 199x as  xxxxxxxx for “two complex ‘out-of-town’ Coast Guard 
xxxxxxxxxxxx.    The  applicant  alleged  that  this  was  unfair  because  other  junior, 
inexperienced  xxxxs  are  normally  assigned  to  serve  as xxxxxxxxx or xxxxxxxx before 
being appointed xxxxxxxx.  She cited the experiences of an XXX classmate, who served 
as assistant xxxxxxxx in XXX, and LT Y, the xxxx who ultimately replaced her at XXXX, 
as examples of junior xxxxs who were assigned as xxxxxxxxx to a xxxxx before being 
assigned  as  xxxxxxxx.    In  contrast,  the  applicant  alleged,  she  was  never  assigned  as 
xxxxxxxxx for a xxxxx that went to xxxxx. 

 

                                                 
5  The rating chain for OER2 included CDR Y, executive officer of XXXX, as supervisor; CAPT XX, com-
manding officer of XXXX, as reporting officer; and CAPT X, chief of XXX, as reviewer. 

Moreover,  the  applicant  alleged,  although  appointed  xxxxxxx  for  these  two 
xxxxxx,  she  was  not  given  control  over  them  and  was  not  even  given  the  complete 
xxxxx.  She alleged that she was assigned a relatively inexperienced xxxxxxxxx, LT X, 
who attempted to sabotage her efforts at every opportunity.  She stated that initially she 
was told that she would have an experienced xxxx, LCDR Y, as her xxxxxxxxx, but was 
instead  assigned  LT  X,  who  had  worked  at  XXXX  on  the  xxxxxxx  side  for  only  six 
months and had “little, if any experience as a xxxxxxx.” 

 
The applicant alleged that she was not given sufficient time to prepare the two 
xxxxxs even though they were complex and delaying the xxx dates beyond mid March 
199x    would  not  have  prejudiced  the  government.    LCDR  XX  told  her  she  could  not 
delay the xxx dates because the xxxxxs had to go to xxx as soon as possible.  She alleged 
that the xxxxx xxxxs in both xxxxxs were quite experienced, and yet even one of them 
“expressed concern over the limited preparation time” for the xxxxxx.  The applicant 
also cited as evidence that her assignment as xxx xxxxx for these xxxxxs was unfair the 
fact that one of her classmates at XXX served as assistant xxx xxxx for the xxxxxx and 
“was not expected to, nor did he play any visible role.” 

 
The applicant stated that she did not have the complete xxxxx because they were 
given to her assistant, LT X, who failed to show her all of them.  She did not know that 
there  were  other  relevant  documents  in  the  record  until  after  she  interviewed  the 
xxxxxxxxxx in late February 199x.  Moreover, she said, she was required to research and 
xxxxx a xxxxxxxx to protect the xxxxxx of an xxxxxxx when she herself was not permit-
ted to know his xxxxxxx or see his statement.  The applicant further alleged that both 
LCDR XX and LT X avoided consulting with her on the xxxxxs, though they regularly 
discussed the xxxxxs with each other, and LT X was given a portable phone to take to 
the xxx so that she could call LCDR XX whenever necessary.  The applicant stated that 
the only direction she received on the xxxxxs was from her supervisors at XXXX. 

 
The applicant alleged that while she and LT X were in xxxxx for one of the xxxs, 
LT X called her one evening and asked her if she liked xxx work and if she thought she 
was good at it.  When the applicant replied that it was too early to make that judgment, 
LT  X  asked  her  if  she  “could  afford  to  wait  that  long.”    The  next  day,  the  applicant 
alleged, LT X called for a xxxxxxx in the xxx and initiated the applicant’s removal from 
the xxxxx after the applicant “encountered some difficulty xxxxxxxxxxxxxx.”  Later that 
day, in a conference call between herself, LT X, CAPT X, LCDR XX, and CDR X, she was 
told that henceforth she would only observe the XXX xxxxxxx. 

 
After the XXX and XXX xxxs ended, on March 23, 199x, the applicant alleged, 
CAPT X told her that she was being removed from XXXX.  She alleged that CAPT X 
cited “reports from school” as one of the reasons for her removal and also indicated that 
“there were concerns” about her performance at the XXX XXXX prior to her attendance 
at XXX.  Therefore, the applicant argued, she was removed from XXXX before she could 

even demonstrate her abilities or develop her potential, which was part of the purpose 
of sending junior xxxxs to XXXX.  Moreover, she alleged, she was removed even though 
LCDR YY, who directly supervised her work, thought that her work was satisfactory 
and no different than that of other junior xxxxs.  As a result of her premature removal 
from XXXX, the applicant stated, she was deprived of six months of xxx experience and 
the chance to have a positive OER for her work there.  

 
The applicant alleged that XXX improperly influenced her rating chain to lower 
her marks in OER2 (see the table below).  She also alleged that the marks and comments 
in OER2 are unjust as a whole because of the unfair expectations and working condi-
tions  imposed  upon  her.    Therefore,  she  asked  the  Board  to  remove  OER2  from  her 
record in its entirety.  The low marks in OER2 are supported by the following negative 
comments: 

 
A  young,  eager  xxxx,  [the  applicant]  has  plenty  of  energy  and  desire  but  limited 
xxxxxxxx  experience.      With  only  3  months  experience  as  a  Xxx  xxxxx,  several  funda-
mental skills have not been developed yet.  Occasionally had difficulty recognizing and 
responding appropriately to xxxxx developments ….  However, of approximately 25 first 
tour xxxx with her level of experience, I would rate her at the bottom in terms of xxxxx 
expertise. 
 
Written xxxxx were easy to understand, concise, and impeccable in grammar and format.  
Verbal skills are somewhat immature; in discussing matters with supervisors [the appli-
cant’s] facial expressions and body language conveyed impression of not comprehending 
significance  of  information  being  passed.    Discussions  left  supervisors  with  sense  of 
unease and engendered a lack of confidence. 
 
…    [The  applicant]  has  the  potential  to  become  a  competent  xxxxx  but  she  must  first 
become  proficient  in  the  fundamentals  of  xxxxxx,  and  increase  her  knowledge  of 
substantive xxxxx and the xxxxxxx aspects of xxxxxxxx.  All marks and comments on this 
OER are based on my understanding of USCG directives. 
 
While enthusiastic and eager to face new challenges, [the applicant] sometimes failed to 
initiate appropriate actions … and did not always grasp the significance of xxx issues and 
the importance of matters brought to her attention by her supervisors.  Does not hesitate 
to work long hours but not yet proficient under the stress of xxxxxxxxx situations. 
 
…    Her  below  average  xxxxxxxx  skills,  however,  did  not  inspire  confidence  from  her 
superiors and impacted on her professional image. 
 
[The applicant] abounds with enthusiasm.  However, her lack of experience in the xxxxxx 
profession makes it difficult to assess her full potential and leadership at this time. 
 
The reviewer of OER2, CAPT X, appended a page of comments to it supporting 
the  marks  and  comments  of  her  supervisor  and  reporting  officer  and  indicating  that 
both officers were very familiar with the rating standards and had rated many Coast 
Guard xxxxs assigned to XXXX.  He also specifically concurred with the assignment of 
the mark of 2 on the comparison scale. 

 
The  applicant  submitted  a  reply  to  OER2.    In  the  reply,  she  stated  that  it  was 
unfair for her to be removed from XXXX after only three months.  She stated that the 
comments in the OER show that she was caught in a “Catch-22” because she was criti-
cized for lack of knowledge and experience but not given the chance to get it by con-
tinuing at XXXX.  She also made the allegations that appear in her application to the 
BCMR.    In  addition,  she  stated  that  she  received  inadequate  feedback  on,  and  was 
unfairly surprised by, some of the criticisms in OER2. 

 
In  his  endorsement  forwarding  her  reply  to  the  Commandant,  her  supervisor, 
Navy CDR Y, reconfirmed his evaluation, stating that the applicant was removed from 
XXXX because she “lacked the basic xxxxx skills to perform as a xxxxxxxx” and “would 
not perform at an acceptable level, even if allowed to stay for nine months.”  He stated 
that of all first-tour xxxxs he had supervised, she was the “least prepared for a xxxxxx 
assignment.”    He  also  indicated  that  she  had  been  given  “remedial  instruction  and 
guidance in xxxxxx and handling her xxxxxs.”  CDR Y stated that “[n]o one at [XXX] 
ever tried to influence the substance of any OER prepared by me.”   

 
The reporting officer for OER2, CAPT XX, forwarded her reply and reiterated his 

determination that her skills were “lacking” and her potential was “limited.” 

 

Allegations Regarding OER3 (April 5, 199x-May 31, 199x)6 
 
 
The applicant alleged that CAPT X “poisoned the well” for her at her next unit, 
the XXX XXX, where she worked to xxxxxxxxxx and xxxxxxx to the Coast Guard.  She 
alleged that, at a March 23, 199x, meeting with her new supervisor, LCDR X, CAPT X 
told him that she had been a “disappointment,” that he would monitor her progress, 
and that there would be “serious consequences” if she showed no improvement.  The 
applicant  asked  to  be  transferred  from  the  Command  entirely,  but  this  request  was 
denied. 
 
 
The applicant alleged that CAPT X told her she would enjoy working with LCDR 
X because of his “droll sense of humor.”  However, she alleged, LCDR X kept a poster 
prominently  displayed  on  his  office  wall  with  the  caption  “President  of  the  He-Man 
Woman Haters Club.”7  She alleged that LCDR X often demonstrated hostility toward 
her and women in general and that he excluded her from conversations.  In addition, 
she  alleged  that,  when  he  was  out  of  the  office,  he  never  appointed  her  to  serve  as 

                                                 
6  The rating chain for OER3 included LCDR X, chief of the XXX, as supervisor; CDR X, assistant chief of 
XXX, as reporting officer; and CAPT X, chief of XXX, and reviewer. 
 
7  The “He-Man Woman Haters Club” was the name of the boys’ club in the Little Rascals.  Alfalfa was 
the club president.  The modern movie “The Little Rascals” was not released until 199x. 
 

acting branch chief.  Instead, he always chose one of the less experienced officers.8  She 
alleged  that  other  members  of  the  unit  also  showed  her  disrespect  and  that  she  was 
subject to a “hostile work environment” at the XXX. 
 
 
The applicant alleged that LCDR X told her he had been instructed to watch her 
“under a microscope” but he intended to be “totally objective.”  Therefore, he “subject-
ed her to reporting requirements which existed for no one else in the Branch.”  Initially, 
they met weekly, and later she was required to submit daily summaries of what she had 
accomplished.  LCDR X also prepared an officer support form (OSF) on her work, as 
ordered by CAPT X, but she alleged, he never informed her of any of the deficiencies in 
her work reported in OER3, which covered her first eight weeks at the XXX. 
 
 
The applicant also alleged that OER3 was prepared incorrectly because LCDR X 
assigned her marks by comparing her to other officers, whereas the rules require that he 
compare her to the printed standards.  Moreover, she alleged, she was held to a higher 
standard than others because once, when she told LCDR X that she was not the author 
of a draft letter he was criticizing her for, he crumpled it up and threw it away rather 
than save it to discuss with the author, another lieutenant in the office. 
 
 
The applicant also alleged that OER3 was unfair because it covered too short a 
period for her new rating chain to evaluate her performance properly.  She alleged that 
the decision to evaluate her after just eight weeks violated Article 10.A.3.a.(5)(e), which 
states that the “welfare of the Reported-on Officer should be paramount when deter-
mining the appropriate time to submit an OER,” because it was clearly not in her inter-
est to evaluate her work after just eight weeks.  She alleged that LCDR X’s statement 
that she chose the shorter period was inaccurate because she did not feel that she had 
any say in what happened, given CAPT X’s “promise of ‘serious consequences.’” 
 
 
entirety.  The low marks in OER3 are supported by the following negative comments: 
 

The  applicant  asked  the  Board  to  remove  OER3  (see  the  table  below)  in  its 

…  A little slow, at times, in responding to short-term tasking and requests for progress 
reports. … 
 
Effectively utilized various forms and standard letters for xxxxxxx purposes.  Departures 
from  standard letters, however, often required revision for clarity or insufficient proof-
reading. 
 
[The applicant’s] professional development has been steady, although somewhat behind 
what  is  normally  expected  of  a  direct  commission  xxxx.   Works well in a highly struc-
tured environment.  As [the applicant] gains more experience in the Coast Guard’s  xxxxx 

                                                 
8    The  applicant  submitted  copies  of  several  e-mail  messages  indicating  that  two  other  xxxxxxs  in  the 
office,  whose  dates  of  rank  as  lieutenants  were  several  months  later  than  hers,  were  appointed  acting 
chief when LCDR X was out of the office. 

program, I hope to see a maturation of her professional skills, which is required prior to 
assignment to the Division’s more challenging junior xxxx positions. 

 

The applicant submitted a reply to OER3 as well.  The reply contains many of the 
same allegations included in her application to the BCMR.  In his letter forwarding her 
OER reply to the Commandant, her supervisor, LCDR X, stated that because she had 
been removed from XXXX at the Navy’s request, she was told her performance “would 
be subject to careful scrutiny.”  He stated that the decision to have an OER prepared 
after just eight weeks at the XXX was hers to make; she could have waited until the next 
semi-annual  marking  period.    However,  he  said,  she  chose  the  shorter  evaluation 
period  because  she  agreed  with  his  recommendation  that  “she  might  better  recover 
from  any  comments  in  the  Navy  OER  if  she  could  quickly  demonstrate  good 
performance in this Branch.”  He stated that he completed an OSF so that she would 
know exactly what was expected of her.  The assignment of the mark of 3 for “Respon-
siveness” in OER3, he stated, was due to her late submission of progress reports and 
lack of response to other specific requests.  The mark of 3 for “Writing” related to “the 
number of times her writing required revision as compared with that of other xxxxxx  I 
have observed.”  

 
In  his  letter  forwarding  the  applicant’s  OER  reply  to  the  Commandant,  her 
reporting officer, CDR X, stated that her welfare was of paramount importance in the 
choice  of  evaluation  period.    However,  the  decision  was  properly  made  at  the 
beginning  of  the  evaluation,  and  it  “could  not  be  foreseen  whether  her  performance 
during the period would indeed ‘advance’ her welfare.” 

 
In  his  letter  forwarding  the  applicant’s  OER  reply  to  the  Commandant,  her 
reviewer, CAPT X, stated that the meeting between the applicant, himself, and LCDR X 
was  intended  to  explain  the  applicant’s  departure  from  XXXX,  to advise her that her 
performance must improve, and to make both LCDR X and the applicant understand 
how carefully her work was to be monitored.  CAPT X stated that he also told them she 
should be given a “clean slate” and not prejudged based on her removal from XXXX. 

 
The  applicant  continued  to  work  in  the  XXX  until  February  199x,  and  then 
worked  in  the  XXXX,  providing  xxxxx  on  xxxxx  issues,  until  November  199x.    She 
received three OERs for this work (OER4, covering June 1 to November 30, 199x; OER5, 
covering December 1, 199x, to May 31, 199x; and OER6, covering June 1 to November 
30,  199x),  which  she  did  not  dispute  (see the table below), except for the comparison 
scale marks.9 
                                                 
9  The rating chain for OER4 was identical to the rating chain for OER3:  LCDR X, chief of the XXX, was 
the supervisor; CDR X, assistant chief of XXX, was the reporting officer; and CAPT X, chief of XXX, was 
the reviewer.  The rating chain for OER5 was the same except that Ms. X, chief of the Xxxxxx, served as 
the supervisor.  The rating chain for OER6 included Ms. X as supervisor, CDR XX, the new assistant chief 
of XXX, as reporting officer; and CAPT X, as reviewer. 
 

 In  November  199x,  the  applicant  was  transferred  from  the  XXXX  to  the 
Command and XXX.  She alleged that this transfer was contrary to policy because junior 
xxxxs  were  supposed  to  have  nine  months  of  XXXX  experience  as  a  prerequisite  to 
working at the branch.11  She alleged that once again, the well was poisoned because the 
branch  chief  told  her  that  he  had  heard  derogatory  things  about  her  performance  at 
XXXX.    She  stated  that  she  asked  to  be  returned  to  the  XXXX,  where  she  felt  fairly 
treated, but this request was denied.  However, she was transferred to the XXXX. 

 
The applicant further alleged that a new chief of the XXXX, Ms. XX, who served 
as the supervisor for OER7, arrived with a preconceived negative opinion of her that 
continued  and  was  evident  in  their  daily  interactions.    As  a  result  of  this  bias,  the 
applicant alleged, OER7 contains inaccurate comments.  The low marks in OER 7 (see 
the table below) are supported by the following negative comments: 

 
Allegations Regarding OER7 (December 1, 199x-May 31, 199x)10 
 

 
Primary xx assignment was to xxx in xxxxxxxxxxxxxxx.  Required prompting and never 
competently  completed  this  assignment  despite  substantial  advice  and  guidance  from 
supervisor.    Requested  transfer  to  another  branch  because  uncomfortable  with  role  of 
xxxxxxx xxxx.  Upon assignment to XXXX, assumed control of complex XXX xxxxx. … 
 
Interpersonal relations generally satisfactory.  However, did not carry her share of Com-
mand and XXX’s xxxxx. … 
 
… xxxxxx letters on xxxxxxxx and xxxxxx issues for CG members generally competent; 
XXX motions required substantial input/correction from supervisor. 
 
…    Substantial  supervisor  participation  required  in  XXX  xxxxx.    Decision  to  request 
reassignment after only weeks in the Command and XXX raises concern with judgment 
and  responsibility.    Reassignment  accommodated  with  some  inconvenience  to  other 
xxxxs and despite contrary policy. 
 
[The applicant] has shown herself capable of handling a complex xxxxx in the XXX area. 
…  However, a Coast Guard xxxxxxx cannot escape xxxxxxx duties. …  [Her] inability or 
unwillingness  to  take  on  and  carry  out  the  responsibilities  of  a  xxxxxing  xxxx 
significantly limits her potential as an effective Coast Guard xxxxxxx. 
 
The  applicant  alleged  that  the  comment  “substantial  supervisor  participation 
required in XXX xxxxx” was inaccurate because the branch chief had little XXX experi-
                                                 
10  The rating chain for OER7 included Ms. XX, the new chief of the Xxxxxx, as supervisor; CDR XX, as 
reporting officer; and CAPT X, as reviewer. 
 
11  The applicant submitted a copy of an e-mail message from CDR X, with the subject line “Junior Xxxxxx 
Intra-Office Dream Sheet.”  The message stated that “to the greatest extent possible every ‘junior xxxxxx’ 
will spend at least 9 months” in the various branches, including XXXX,  xxxxx, xxxxx , and xxxxx.  It also 
stated that “XXXX experience” was a prerequisite to assignment to the Command and XXX. 

ence,  so  the  applicant  was  obliged  to  seek  help  from  commands  with  XXX  expertise, 
such  as  the  xxx  school,  MCLANT,  and  Headquarters.    Moreover,  she  alleged,  the 
branch  chief  tried  to  force  her  “to  behave  in  an  unethical  manner”  by  withholding 
responsive documents from discovery.  She alleged that she had to go over the chief’s 
head to have the documents released. 
  
 
The applicant further alleged that she tried to file a reply to OER7 but that it was 
rejected  by  Headquarters  because  it  contained  criticisms  of  Ms. XX.  She submitted a 
copy of her reply with her application.  In it, she alleged that OER7 unfairly criticized 
her for transferring out of the Command and XXX because she should not have been 
assigned there since she did not have the prerequisite xxxxxxx experience since she was 
removed  from  XXXX.    She  also  alleged  that  the  marks  and  comments  in  OER7  were 
inconsistent and that they did not fairly characterize her work.  She also alleged that she 
had  received  little  supervision  and  that  some  of  the  supervision  she  did  receive  was 
misguided. 
 
Allegations Regarding Comparison Scale Marks 

 
The  applicant  alleged  that  because  she  was  never  permitted  a  fresh  start  but 
remained  at  the  same  command  where  the  well  had  been  poisoned  throughout  her 
Coast Guard career, she continued to receive low marks of 3 on the comparison scale on 
her OERs, even though her marks in the performance categories improved.  She alleged 
that if she had been transferred to a new command where the well was not poisoned for 
her,  she  would  have  received  higher  marks  on  the  comparison  scale.    Therefore,  she 
asked the Board to remove all of the comparison scale marks on all eleven of her OERs 
through May 31, 1998, or at least those from March 26, 199x, through March 25, 199x 
(OER1 through OER9), when she left active duty (see the table below).12 

 
The  applicant  was  discharged  from  active  duty  in  199x  after  twice  failing  of 
selection for promotion to lieutenant commander.  She went into the Reserves but was 
discharged on July 1, 199x, having again twice failed of selection for promotion to xxxx. 

                                                 
12    The  applicant’s  rating  chains  for  OER8  through  OER11  were  all  new  except  that  CDR  XX,  the  new 
assistant chief of XXX after CDR X left, continued to serve as her reporting officer for OER8 and OER9. 

 
Mr.  X,  a  civilian  xxxx  who  served  as  chief  of  the  XXXX  at  XXX  and  as  the 
applicant’s supervisor for OER1, submitted a statement on the applicant’s behalf.  He 
stated that, after he submitted his portion of OER1, “the Reporting Officer advised me 
to  reconsider  some  of  the  marks.    I  complied  with  the  direction  I  received,  which 
resulted  in  a  lower  grading  for  [the  applicant].    Due  to  the  amount  of  time  that  has 
passed,  I  do  not  specifically  recall  which  marks  were  involved  in  the  changes.    I  do 
recall  that  keeping  the  evaluation  as  originally  submitted  did  not  appear  to  be  an 
option.” 
 

Statement of Navy LCDR YY, Senior Xxx at XXXX 

 
LCDR YY stated that he supervised the work of the applicant and three other xxx 
xxx when she worked at XXXX from January through April 199x.  He explained that 
XXXX has “no formal training/orientation program for new xxx xxx, relying on hands-
on  supervision  and  on-the-job  experience  to  provide  a  bridge  from  xxxxxx  to  actual 
xxxxxx practice.”  XXXX, he stated, used a “five xxxxx rule,” under which all new xxx 
xxx were supposed to be assigned experienced assistant xxx xxx to help them with their 
first  two  xxxxxxx  xxxxxs,  their  first  two  contested  xxxxxs,  and  their  first  “members” 
xxxxx.  LCDR YY explained that for most XXXX xxxxxs, he was responsible for “initial 
xxxxx review and assignment, as well as daily supervision and follow up with other xxx 
xxx.”    However,  Coast  Guard  xxx  xxx  obtained  their  xxxxxs  and  initial  guidance 
directly from XXX. 

 
LCDR YY stated that soon after the applicant arrived at XXXX, he received two 
phone calls from LCDR XX, inquiring into her progress.  LCDR XX informed him that 
XXX  was  concerned  about  the  applicant’s  job  performance,  military  bearing,  and 
performance at XXX. 

SUMMARY OF STATEMENTS SUBMITTED BY THE APPLICANT 

 
Statement of Mr. X, the Applicant’s Supervisor for OER1 

 
In the winter of 199x, LCDR YY stated, “the volume of XXXX xxxxxs available for 
[the applicant] to learn on had dropped significantly.”  By mid February 199x, the appli-
cant had xxxx one xxxxx xxxxx, one contested xxxxx, and one xxxxx investigation, and 
her performance “was satisfactory and was consistent with her experience level at that 
time.    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 xxxxxxxxxx] xxxxx.” 

 
In  February,  LCDR  YY  stated,  he  was  told  that  XXX  had  two  xxxxxs  for  the 
applicant,  and  that  she  could  get  the  xxxxx  files  from  LT X, who would serve as her 
assistant xxx xxx.  LT X had previously worked at XXXX as a xxx xxx.  The applicant 

soon  “began  to  express  frustration  over  her  ability  to  properly  prepare  for  the  two 
Coast Guard xxxxxs she had been assigned in xxxxxx.”  She was concerned about how 
complex the xxxxxs were and the fact that LT X had retained the complete xxxxx xxxx 
and would not release them to her.  LCDR YY told her to “take as much time as she 
needed to work with [LT X] to prepare the xxxxxs over at Coast Guard xxxxxxx.” 

 
In March, while the two xxxs were in progress, LCDR YY stated, he received a 
phone call from LT X, who “expressed concern about [the applicant’s] ability to try the 
xxxxxxxxxxxxxxs  because  [the  applicant]  had encountered difficulty in entering some 
documentary evidence and she believed that [the applicant] seemed unconcerned about 
the  proceedings  because  she  had  gone  out  to  lunch  rather  than  stay  to  research  an 
issue.”  LT X told him she had thought her role was to be just observation and oversight 
but now “felt she had to intervene to correct what she believed were shortcomings in 
[the  applicant’s]  management  of  the  xxxxxs  by  taking  control  completely  away  from 
her.”  He later learned that the applicant had been removed from the xxxxxs, except to 
sit as an observer, and that XXX had decided to remove the applicant from XXXX early 
“because of concern over reports to them regarding the xxxxxx xxxs.” 

 
LCDR  YY  stated  that,  because  he  was  the  only  xxxx  directly  supervising  the 
applicant  at  XXXX,  he  prepared  an  initial  draft  for  OER2  and  forwarded  it  to  the 
department head, LCDR Z.  The department head agreed with him that the applicant 
was  making  progress  and  had  satisfactorily  performed  the  work  assigned  to  her  by 
XXXX.    However,  the  department  head  was  concerned  that  she  “lacked  some  basic 
skills, such as xxx xxxxxxx, that were necessary for further development as a xxx xxxx, 
and that she needed additional experience and maturity to be successful.”  LCDR YY 
stated  that  he  also  discussed  the  OER  with  XXXX’s  executive  officer,  CDR  Y,  who 
served  as  the  supervisor  for  OER2.    It  was  apparent  to  LCDR  YY  that  CDR  Y  had 
discussed the applicant’s performance with XXX and that his opinion of her perform-
ance was “somewhat more negative.”  LCDR YY stated that he proposed retaining the 
applicant  at  XXXX  for  further  training  and  that  initially  the  department  head  and 
executive officer had agreed.  Later, however, he heard that XXX had decided to recall 
her. 

 
LCDR YY stated that, although the final version of OER2 contains many of the 
same comments he included in his original draft, “the overall tone and numerical marks 
are significantly more negative.”  He stated that in reviewing the applicant’s experience 
at XXXX, he is “left with the overall impression that she was essentially set up to fail.”  
Although she had performed the work assigned to her by XXXX satisfactorily, she was 
recalled after only three months.  While at XXXX, he stated, the applicant “researched 
and wrote an XXXX xxxxxxxx on command xxxxxxxx instructions, successfully xxxxxx 
the government at a complex xxxxxxxx investigation, and successfully handled two xxx 
xxxxxxxx, one of which involved responding to xxx xxxxxx.”  He stated that he found it 
inexplicable that she was “first thrown headlong by the Coast Guard into two complex 

members xxxxxs, and then abruptly removed without explanation.”  He suggested that 
the Coast Guard might have feared she would embarrass the Service, and further stated 
that “[n]o Navy xxxxxxxx in [the applicant’s] position would have been treated in the 
same way.” 
 
Statement of Lt. M, the Applicant’s Classmate at XXX 

 
LT Z, who attended XXX with the applicant, signed a statement indicating that 
she observed a xxxxx xxx at XXX in which the applicant acted as xxx xxx.  The xxx xxx 
was  supposed  to  begin  by  reciting  “the  convening  information  and  pertinent 
information about the xxxxxx and the xxxxxx.”  However, in their preparations, they 
had  skipped  over  this  material  and  focused  on  “questioning  and  objection  skills.”  
Therefore, the applicant skipped them during the xxx xxx and, when told by the xxxxxx 
to start over, had to do so haltingly “because she was clearly plugging administrative 
information  from  the  xxxxxx  into  the  xxxxxxx  guide  as  she  read,  rather  than  having 
filled in the blanks ahead of time.” 

 
LT Z stated that the xxxxxx became very irate when the applicant explained that 
she had not expected to have to do that part of the xxx and called the applicant and the 
xxx  xxx  aside  for  private  discussion.    Upon  resuming  the  xxx  xxx,  the  applicant  was 
“very  upset  and  flustered.”    She  “regained  some  of  her  composure,  but  was  always 
appearing to have difficulty concentrating after the initial meeting” with the xxxxx.  LT 
Z remembered that on at least one other occasion, the xxxxx again stopped the xxx xxx 
to lecture the applicant outside of the xxxxxxx. 

 
LT Z stated that the applicant’s performance at the xxx xxx was not spectacular 
but “no worse than several of the others I saw while at xxxxxxxx.  As far as I know, [the 
applicant] is the only person who failed a xxx xxx exercise in our class.”  She attributed 
the  applicant’s  failing  grade  for  the  xxx  xxx  to  a  personality  conflict  between  the 
applicant  and  the  xxxxxxx.    LT  Z  further  stated  that  she  had  witnessed  another 
classmate suffer much more severe problems while acting as xxx xxx at a xxx member’s 
xxx.  The xxx had been stopped and the student xxx xxx had been lectured many times.  
However, LT Z stated that “[t]o the best of my knowledge, she did not fail the exercise, 
however, and she did pass the class.” 

 

Statement of LT XX 

 
LT  XX,  a Coast Guard xxxx who received her direct commission in April 199x 
and attended XXX in the fall of 199x, submitted a statement in which she described her 
experience at the XXXX in xxxxx.  She stated that she spent her first two to three months 
at  the  XXXX  xxxxxing  “lower”  level  xxxxxs,  involving  matters  such  as  xxxxxxxxx 
xxxxxxxxxxxxxx.  “After a steady 2-3 month diet of these xxxxxs, [she] then assumed 
xxxxxs xxxxx xxxxxxx including much of the above with the addition of xxxxxx such as: 

xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx.”  Later, she was assigned xxxxxs involving 
xxxxxxxxxxxxxxxxxx, etc.  In addition, she stated that she “was detailed as an assistant 
xxx xxx for some of these xxxxxs, before acting as xxx xxx in these types of xxxxxs.”   

 
LT XX further stated that, since she now has xxxxxed over 100 xxxxxs, she men-
tors new xxx at XXXX, and she “would never expect someone who had just graduated 
from xxxxxxx to single-handedly assume responsibility of a complex xxxxx. …  There is 
no  excuse  for  thrusting  a  relatively  new  xxxx  into  a  complex  xxxxx  with  little  or  no 
guidance. …  [I]f it were necessary to assign a xxxxx in this manner, an ample amount 
of time should be allocated to the new xxxx, so that he or she could adequately prepare 
him  or  herself  not  only  for  the  xxx  of  the  xxxxx,  but  for  the  challenge  of  the  xxxxxx 
environment. …  Not to allow this is to purposely set up a new xxxx for failure, or at 
best shows the senior delegating xxxx to be merely incompetent.” 

 

Statement of the xxxxx in the XXX and XXX Xxxxxs 

 
The Coast Guard captain who served as the xxxxxx of the two complex xxxxxs 
assigned to the applicant stated that the xxxs lasted seven days and involved numerous 
xxxxxxxxxx.  He further stated as follows: 

 
It was apparent that [the applicant] did not have significant xxx experi-
4. 
ence at the time that I observed her in these two xxxxxxxxxx, and that of the two 
government xxx, LT X was the more experienced.  [The applicant] appeared ill-
prepared at one point during the xxxxxxxx, and later had difficulty xxxxx some 
xxxxxxx.  Although her shortcomings appeared greater than those I’ve seen in 
other  xxx  with  little  experience,  in  my  opinion,  more  xxxxxx  experience  and 
better xxxxx preparation would be expected to alleviate the kind of weaknesses I 
saw. 
 
5. 
During  the  course  of  these  xxxxxxx,  it  became  apparent  to  me  that  the 
[applicant] and [LT X] had not adequately communicated with each other prior 
to xxx;  I also observed minimal communication between [the applicant and LT 
X] at the xxxxxion table.  At the point where [the applicant] had difficulty xxxx 
xxxxxxxxxxx,  [LT  X]  initiated  the  removal  of  [the  applicant]  as  the  xxx  xxx, 
leaving [the applicant] with no visible role in the xxxxxion from then on. 
 
6. 
I have read the statement of [LCDR YY] dated 28 September 199x.  The 
circumstances described in his statement are consistent with what I observed in 
the above xxxxxxxxxxx. 
 
7. 
Shortly  after  these  xxxxxxx,  I  spoke  with  [CAPT X], the chief of [XXX], 
and gave him feedback on [the applicant’s] performance from the xxxxxxx view-
point.  He indicated that he was not surprised that I found shortcomings in [the 
applicant’s] performance. 
 

8. 
[CAPT X’s] comments, and other circumstances surrounding the xxxxxs 
discussed above, suggest to me that [the applicant] was prejudged by her com-
mand. 

 
Statement of Ms. YY, a Xxxx Assigned to the XXX under LCDR X 

 
Ms.  YY,  a civilian xxxx who served under LCDR X, stated that she “found his 
character  to  be  unprofessional  and  demeaning  towards  me  as  a  woman.”    The  xxxx 
described offensive posters displayed in LCDR X’s office, including one entitled “He-
Man Woman Haters Club” and another with women in bikinis.  She stated that working 
in his office was humiliating and she felt “surrounded by male chauvinism.”  She stated 
that  he  ignored  her  complaints  about  the  posters  but  finally  removed  them  when 
prompted by a superior officer.  She stated that he also used a sun shield for his car that 
showed women dressed in thongs and bikinis.  

 
Ms. YY also stated that she did not have an opportunity to observe how LCDR X 
interacted with the applicant because the applicant “was assigned to a small, dark, and 
windowless office in another part of the building,” whereas her colleagues had offices 
with windows located adjacent to LCDR X’s office. 

Statement of LCDR ZZ, xxx, U.S. Navy 

 
A xxx officer for the Navy stated that she visited the applicant at the XXX in May 
199x  and  witnessed  LCDR  X  discussing  promotions  with  his  staff.    She  stated  that 
LCDR X told two male lieutenants that they would be promoted some day and offered 
to give them parts of his uniform.  She stated that the comments were “clearly directed 
at  the  two  male  lieutenants  only  and  [LCDR  X]  made  no  attempt  to  include  [the 
applicant].  I was surprised at how blatant this officer’s actions appeared.”  She further 
stated that she is a long-time friend of the applicant, knows her to be “a most competent 
and  able  xxxx,”  and  “cannot  understand  why  this  officer  displayed  such  outright 
hostility toward [the applicant].” 
 
Statement of Yeoman X 

 
Yeoman X, who worked at XXX and served as the xxxx reporter for the XXX and 
XXX  xxxs,  stated  that  the  applicant  “was  subjected  to  numerous  instances  of  dis-
crimination by the command.”  She stated that, prior to the xxxs, she asked the appli-
cant for a copy of the xxxxxx, but was told the applicant had not received one.  When 
she requested a xxxxxxx from LT X, her request was denied, although it was usual for 
xxxxxxxx to receive them in advance.  The yeoman stated that the applicant “received 
little to no assistance” from LT X, and she feels the applicant “was set up for failure by 
the  [XXXX]  by  their  failure  to  provide  her  with  the  required  documentation  and 
assistance of her more experienced co-xxx.” 

 

 

Yeoman X stated that later on, soon after the applicant was assigned to the XXXX 
under Ms. XX, she overheard Ms. XX tell someone “Look what I’m stuck with now.”  
She stated that she is certain this remark concerned the applicant.  She also stated that 
Ms.  XX  often  yelled  at  the  applicant  and  treated  her  in  a  demeaning  manner.    In 
addition,  the  yeoman  supported  the  applicant’s  claim  that  Ms.  XX  had  attempted  to 
stop  the  applicant  from  releasing  a  xxxxxxxxxxxxxx.    The  yeoman  stated  that  other 
superior officers also contributed to the “general atmosphere of disrespect” toward the 
applicant.  She stated that there was no such discrimination against the applicant when 
she served in the XXXX. 

 

Statement of Ms. Y 

 
On May 32, 199x, Ms. Y, who served as a volunteer xxxxxxx at the XXXX under 
Ms. XX, stated that she had worked with the applicant on an XXX xxxxx.  As part of her 
work,  she  had  searched  files  xxxxxxxxxxx,  but  many  of  the  documents  she  selected 
were rejected by Ms. XX.  She stated that Ms. XX interpreted the xxxxxxx very narrowly 
and that the applicant tried to get Ms. XX to release the xxxxxxxx documents.  Later, 
after a xxxxxx referred to one of the xxxxxxx documents that had been withheld by Ms. 
XX, the xxxxxx required all the xxxxxx to be turned over.  Ms. Y stated that the Coast 
Guard was embarrassed. 

 
On February 15, 199x, Ms. Y, serving as a “volunteer xxxx” at the XXXX under 
Ms.  XX,  signed  a  statement  indicating  that  she  and  the  applicant  had  worked  very 
closely on the XXX xxxxx “with minimal supervision from” Ms. XX.  She stated that Ms. 
XX  requested  biweekly  updates  on  their  progress  and  reviewed  the  applicant’s  xxx 
notebook  to  make  suggestions.    Ms.  Y  further  stated  that  she  “disagree[s]  with  any 
suggestion that [the applicant] required substantial supervision” and that “due to their 
disagreement,”  Ms.  XX  “actually  gave  [the  applicant]  less  supervision  and  feedback” 
than she gave other xxxxs in the office. 

 
Ms.  Y  later  signed  another  statement  affirming  her  statements  of  February  16, 
199x, and May 23, 199x.  In this third statement, she indicated that Ms. XX disliked the 
applicant’s  “style  and  methods”  and  was  much  more  critical  of  the  applicant than of 
other xxxxs in the office.  She also stated that Ms. XX’s feedback often came late, after a 
project  was  completed.    For  instance,  she  stated  that  in  the  XXX  xxxxx,  “at  the  last 
minute  [Ms.  XX]  began  questioning  [the  applicant’s]  xxxxxxx  choices  and  suggesting 
things should have been done differently.  It was apparent that [Ms. XX’s] last minute 
criticisms unnerved [the applicant] and undermined her confidence.”  Ms. Y stated that 
she did not understand Ms. XX’s attitude toward the applicant, who was “a knowledge-
able xxxxx and diligent worker.”  The extra scrutiny, she stated, “simply created prob-
lems” for the applicant which neither she nor the other xxxxs in the office encountered. 
 

VIEWS OF THE COAST GUARD 

 
Advisory Opinion of the Chief Counsel 
 
On December 23, 1999, the Chief Counsel of the Coast Guard submitted an advi-
 
sory opinion in which he recommended that the Board grant partial relief in this xxxxx 
by removing OER3.  He alleged that no other relief is warranted.  The Chief Counsel 
did not elaborate on this recommendation himself but attached to his advisory opinion 
a memorandum prepared by the Coast Guard Personnel Command (CGPC). 
 
Memorandum of the Coast Guard Personnel Command 
 
 
CGPC submitted statements signed by the chief of XXX, CAPT X, who served as 
the reviewer of OER1 through OER7; by CDR X, the assistant chief of XXX who served 
as the reporting officer for OER1, OER3, OER4, and OER5; and by CDR XX, the second 
assistant chief of XXX who served as the reporting officer for OER6 though OER9 (see 
summaries of statements below).  CGPC alleged that these officers’ statements “clearly 
indicate that Applicant was afforded opportunities to succeed and that she was not a 
strong  performer.”    CGPC  argued  that  the  applicant  “provides  no  evidence  that  the 
multitude of officials who served as OER Supervisors, Reporting Officers, and Review-
ers during her assignment at [XXX] were joined in a conspiracy to doom Applicant to 
failure.” 
 
 
Regarding OER1, CGPC alleged that it was properly prepared.  CGPC stated that 
the regulations require reporting officers to return OERs to supervisors for revision if 
the  reporting  officer  finds  that  the  marks  assigned  by  the  supervisor  are  inconsistent 
with the evaluee’s performance or are unsupported by the narrative comments.  CGPC 
argued that the statement of the supervisor, Mr. X, concerning the return of OER1 to 
him by the reporting officer, CDR X, does not state that CDR X directed Mr. X to lower 
specific marks, which would have been impermissible under the rules.  CGPC also pro-
vided a copy of the memorandum sent by the CDR X to Mr. X concerning OER1 (see 
below).  CGPC alleged that the memorandum shows that CDR X did not improperly 
influence Mr. X’s evaluation of the applicant. 
 
 
Regarding  OER2,  CGPC  alleged  that  the  applicant  has  not  proved  that  XXX 
either “poisoned the well” for her or “set her up to fail” at XXXX.  CAPT X’s statement, 
CGPC argued, shows that the applicant was sent to XXXX somewhat early in her XXX 
rotation to remove her from ”the effect of the poor leadership abilities” of Mr. X.  Thus, 
she could get a “fresh start” and immediately apply the xxx skills she learned at XXX at 
XXXX.  In addition, CGPC pointed out that the supervisor for OER2, CDR Y, stated in 
his endorsement to her reply to the OER, that no one at XXX had ever tried to influence 
the substance of the OERs he prepared.  CGPC also argued that it is immaterial who 
initiated the applicant’s removal from XXXX. 
 

CGPC  further  alleged  that  as  the  supervisor  for  OER2,  CDR  Y  was  entitled  to 
seek input from other officers who supervised the applicant, such as LCDR YY, but was 
not required to use such input without exercising his own judgment if the applicant did 
not meet his expectations.  Therefore, CGPC argued, the statement by LCDR YY con-
cerning  his  input  to  the  OER  is  irrelevant.    Furthermore,  CGPC  stated,  the  applicant 
failed “to provide any evidence to show that any specific mark or comment in [OER2] 
was in error” or “to show that the specific circumstances surrounding [the XXX] xxxxx 
were reflected in [OER2].” 

 
Regarding  OER3,  CGPC  stated  that  the  reporting  period  was  unusually  short, 
though permissible under the rules and agreed to at the time by the applicant.  More-
over, CGPC stated, “it is not a generally accepted practice to shorten an OER reporting 
period in order to help a Reported-on Officer ‘recover.’ …  Although it is not possible to 
know if an extended OER reporting period [for OER3] would have provided a better 
measure of Applicant’s performance, Applicant had provided evidence to show that the 
short reporting period, while not in error, was unusually short and not in her best wel-
fare.”    Therefore,  CGPC  argued  that  OER3  should  be  removed  from  the  applicant’s 
record. 
 
Regarding OER7, CGPC alleged that the fact that CAPT X, the chief of XXX, per-
mitted her to transfer out of the Command and XXX shows that “he was willing to help 
her  succeed.”    CGPC further alleged that the applicant did not prove that any of the 
statements in OER7 are inaccurate.  CGPC argued that the statement about substantial 
supervision in OER7 “clearly applied to her failure to xxxxx xxxxx in a pending xxxxxxx 
xxxxx while she was assigned to the Command and XXX during the beginning of the 
reporting  period,”  and  did  not  apply  to  her  performance  in  the  XXX  xxxxx.    CGPC 
alleged that the applicant’s XXX xxxxx work was favorably evaluated in the OER, and 
the  supervisor’s  apparent  lack  of  expertise  in  this  area  is  therefore  irrelevant.   CGPC 
argued  that  while  it  is  apparent  that  the  applicant  and  her  supervisor  “did  not  get 
along, a review of this OER reveals that the Supervisor provided generally positive and 
complimentary  comments  regarding  Applicant’s  performance  in  the  XXXX.”    CGPC 
stated that “the only less than favorable comment in the Supervisor’s section of the OER 
referred to [the applicant’s] initial work in the Command and XXX” rather than to her 
work in the XXXX under Ms. XX.  Therefore, CGPC concluded, the applicant did not 
prove that OER7 was in error or that Ms. XX did not fairly evaluate her work.  
 

 
Regarding the applicant’s comparison scale marks in all her OERs, CGPC alleged 
that she has not provided any justification for raising those marks or removing them.  
CGPC stated that the statements by her reporting officers, CDR X and CDR XX, show 
that  “there  was  no  ‘cloud’  created  by  Applicant’s  original  Division  Chief  [CAPT  X].”  
Furthermore, CGPC alleged, the reporting officers had sufficient opportunities to judge 
her overall performance and they properly “compared Applicant to other officers they 
had known of her rank throughout their careers.” 

 
In conclusion, CGPC recommended that only OER3 be removed from the appli-
cant’s record.  CGPC further recommended that the Board not remove the applicant’s 
failures  of  selection  for  promotion  to  lieutenant  commander.    CGPC  argued  that  the 
applicant’s remaining record is so poor that the applicant would not have been selected 
for promotion even if OER3 had not been in her record.  

 
SUMMARY OF STATEMENTS SUBMITTED BY THE COAST GUARD 
 

Statement by CAPT X, Chief of XXX 

 
CAPT X, who served as the reviewer for OER1 through OER7, stated that while 
that  applicant  was  at  XXX,  “someone  from  the  School  advised  me  that  [her] 
performance  was  below  standard  and  that  she  might  not  graduate.”    CAPT  X  stated 
that he discussed this with the assistant chief of XXX, CDR X, but they agreed that if she 
did  graduate,  “this  information  would  be  ignored  and  she  would  be  given  the  same 
opportunities that all other direct commission xxxxs were afforded.”  He further alleged 
that all further personnel decisions and evaluations were based on her actual job per-
formance and not on the information he received from the school. 

 
CAPT X further stated that the applicant was “routinely assigned” to XXXX.  Her 
“initial duties there, as was the custom for most of our xxxxs, were as a xxx xxx.  After a 
period of time as a xxx xxx it was the usual practice that our CG xxxxs would move 
over to the xxxxxion side.”  However, he received a phone call from either the executive 
officer,  CDR  Y,  or  the  commanding  officer,  CAPT  XX,  stating  that  “they  were  not 
satisfied with [the applicant’s] performance and that they did not want her to xxxxxe 
xxxxxs  for  them.    Since  they  were  unwilling  to  provide  her  with  experience  as  a 
xxxxxor,  we  agreed  to  terminate  her  rotation  at  XXXX.”    CAPT  X  also  stated  that  he 
“was  very  surprised  that  both  the  comments  and  marks  [in  OER2]  were  so  negative.  
This was especially true because we typically felt that XXXX OERs were ‘inflated.’ …  I 
believe , during the review process for [OER2], I attempted to ameliorate some of the 
initial negative comments that came from the XXXX.”  

 
Regarding the applicant’s appointment as xxx xxx xxx in the XXX xxxxx, CAPT 
X  alleged  that,  as  a  graduate  of  XXX,  she  should  have  been  qualified  to  xxxxxe  a 
xxxxxxxxxxx  and  that  he  did  not  think  the  xxxxx  was  particularly  difficult.    He 
“believed it a good opportunity for her to succeed at what was a relatively straight for-
ward xxx proceeding that an xxxx with her experience should be able to handle. …  I 
would not have made such an assignment had I thought that she was not qualified.” 

 
Regarding the remainder of her service at XXX, CAPT X stated that like all first 
tour  xxxxs,  the  applicant  was  “rotated  among  several  xxx  specialty  areas  to  provide 
training and experience.”  He recalled that “generally her supervisors were not pleased 

 

Statement and Memorandum Submitted by CDR X, Assistant Chief of XXX 

with her performance.  I believe she eventually did her best work in the XXXX and we 
may  have  extended  her  stay  there  longer  because  of  that  performance.”    CAPT  X 
further stated that, as the reviewer for her OERs, he considered them to be “an accurate 
reflection of her performance as I had observed it and as it had been reported to me.” 

 
CDR X, who served as the reporting officer for OER1, OER3, OER4, and OER5, 
stated that his initial impressions of the applicant had been very positive, and he had 
relayed that those impressions to both CAPT X and Mr. X, her first supervisor at XXX.  
However,  he  alleged,  during  her  first  few  months  at  XXX  prior  to  her  departure  for 
XXX,  the  applicant  “established  a  reputation  for  having  a  distinctly  non-military 
demeanor.”  He hoped that her experience at XXX and an accelerated rotation out of the 
XXXX,  where  her  supervisor  was  a  civilian,  would  improve  her  military  bearing.  
Therefore, by sending her to XXXX, he “specifically intended to give her a fresh start at 
a new unit away from [XXX] and to give her a chance to utilize her XXX training at the 
[XXXX]  immediately  upon  her  return  from  XXX.”    CDR  X  stated  that  he  does  not 
remember receiving any negative reports about her performance at XXX.  Nor does he 
“remember having any concerns about her ability to perform as a xxx xxxx and xxxxxor 
at  the  XXXX,  other  than  her  still  overly  casual  (non-military)  demeanor.”    CDR  X 
further stated that, “[f]ar from trying to set up [the applicant] for failure, I believe that 
[CAPT  X]  and  I  went  to  extraordinary  lengths  to  provide  her  with  opportunities  to 
excel,  particularly  in  light  of  our  recognition  of  the  weaknesses  of  her  civilian 
supervisor” in the XXXX. 

 
Regarding  OER1,  CDR  X  stated  that  the  initial  draft  submitted  by  Mr.  X  had 
“numerous administrative errors.”  He submitted a copy of a memorandum he sent to 
Mr. X explaining how the OER needed to be improved.  The memorandum points out 
that Mr. X had used the wrong OER form, written in several incorrect dates, and failed 
to supply a numerical mark for block 5.d.  The memorandum also states that Mr. X’s 
written comments do not support the marks assigned in blocks 3.b., 3.d., 4.a., 4.b., and 
5.a.    In  addition,  with  respect  to  the  mark  assigned  in  block  5.a.  and  corresponding 
comments, CDR X wrote that “[t]his is a hard mark for any staff xxxx to get more than a 
‘4’ in because they don’t supervise anyone.  Merely doing xxx assistance is not enough.  
Your use of the term ‘unique’ in the fifth sentence seems inappropriate.”  CDR X stated 
that, in response to this memorandum, Mr. X chose to add comments supporting the 
marks of 5 he had assigned the applicant in blocks 4.a. and 4.b., as required by regu-
lation, but chose to lower the other marks of 5 he had assigned to marks of 4, rather 
than add comments supporting the marks of 5.  CDR X alleged that the “decision on 
how to respond to the inconsistencies noted in my memo was left exclusively to Mr. X.”  
He never directed Mr. X or any other supervisor to assign particularly marks.  Regard-
ing the marks he assigned the applicant on the comparison scales of the disputed OERs, 
CDR X alleged that she “never measured up to what I believed to be an acceptable level 

of performance.”  He further alleged that for the OER1 reporting period, the description 
for a mark of 2, “good performer, but limited potential,” better described the applicant’s 
performance,  but  he  gave  her  a  “generous”  mark  of  3  because  he  recognized  the 
“leadership weakness” of the civilian chief of the XXXX. 

 
Regarding OER2, CDR X stated that the applicant was assigned to the xxxxx side 
of XXXX’s work and was assigned Coast Guard xxxxxs by CAPT X and Navy xxxxxs by 
XXXX staff.  He stated that after she went to XXXX in early January, he heard nothing 
“out  of  the  ordinary”  about  her  performance  until  March,  when  “XXXX  began  to 
informally raise questions and concerns as to whether she had really graduated from 
xxx.    To  say  the  least,  I  found  this  rather  shocking  and  quite  inconsistent  with  my 
impressions of her basic xxx skills (apart from her non-military demeanor).  After some 
discussion with the XXXX [executive officer], it turned out that the real concern dealt 
with her lack of ability to handle even simple xxxxx, or manage even a modest xxxxx 
xxx.”    CDR  X  stated  that  XXXX  proposed  to  reassign  her  to  XXXX’s  Xxx  Assistance 
Branch because they lacked confidence in her as a xxxxxor.  However, because such an 
assignment was outside the terms of the Memorandum of Understanding between the 
Coast Guard and the Navy regarding XXXX appointments, XXX removed the applicant 
from XXXX. 

 

 
Regarding the assignment of the XXX and XXX xxxxxs to the applicant, CDR X 
stated that when the applicant worked at XXXX, it was “standard practice to detail the 
one  Coast  Guard  xxxx in the Xxx Xxxxxion shop [at XXXX] to be the xxxxxor in any 
pending Coast Guard xxxxxs.  I have no recollection of there being any discussion, at 
the time of detailing, of [the applicant’s] ability to handle any xxxxx to which se was 
detailed.”  Later, he stated, he was “told, without any advance notice, that the Govern-
ment  was  in  danger  of  losing  [the  XXX]  xxxxx  because  of  [the  applicant’s]  poor 
performance, and that it was imperative that new xxx be detailed immediately.”  As a 
result, he alleged, LT X went to xxxx “on very short notice” and “eventually found it 
necessary to essentially take over the xxxxx.” 

 
Regarding the short evaluation period for OER3, CDR X alleged that the appli-
cant chose the short period, and he referred to his explanation in his endorsement to the 
applicant’s  reply  to  the  OER  (see  above).    Once  she  had  elected  the  short  evaluation 
period, CDR X stated, he “viewed that decision as immutable.”  He also alleged that the 
XXX “was an ideal location to evaluate xxx abilities over a short time period” because 
the work is highly documented and the volume of xxxxxs is high while the complexity 
of  xxxxxs  is  relatively  low.    Therefore,  he  alleged,  in  the  XXX,  an  xxxx  can  quickly 
demonstrate xxxxx xxx management abilities.  He alleged that although she chose the 
short evaluation period, “there were more than adequate opportunities for [the appli-
cant] to perform during this short period.” 

Regarding the marks he assigned the applicant on the comparison scales of the 
disputed OERs, CDR X stated that he kept a spreadsheet to track the marks he assigned 
to  the  xxxxs  he  supervised.13    He  stated  that  the  spreadsheet  helped  him  take  into 
account  various  factors, such as whether it was the officer’s first tour as an xxxx, the 
officer’s rank, and whether the officer was at the end or beginning of his or her tour.  
CDR X stated that, in writing his statement for the BCMR, he reviewed the spreadsheet 
and noticed that the last comparison mark he gave the applicant (in OER5) was compa-
rable to the mark he gave most xxxxs on their first OERs.  CDR X concluded by stating 
that his “lasting recollection” of the applicant is that she “developed much more slowly 
than any other CG xxxx that I had ever known.” 

 

 

Statement by CDR XX, Subsequent Assistant Chief of XXX 

 
 CDR  XX,  who  served  as  the  reporting  officer  for  OER6  through  OER9,  stated 
that his “general recollection … is that [the applicant’s] performance overall was below 
average  for  an  xxxx  and  officer  of  her  training  and  experience.”    He  alleged  that  he 
cannot  recall  any  unfair  treatment  of  her  and  that  they  tried  to  accommodate  her  by 
transferring her out of the Command and XXX at her request, although they counseled 
her that it was not good for her career to refuse to take on xxxxxxx duties. 

 
Regarding OER7, CDR XX stated that he did not remember the specifics of any 
XXX xxxxx but does remember that Ms. XX “was extensively involved in an XXX xxxxx 
assigned to [the applicant].”  He further stated that his evaluation of the applicant’s per-
formance declined over time “as it became apparent to me she performed adequately at 
assignments  she  was  interested  in  performing  but  was  unwilling  to  perform  other 
assignments.”  His comparison scale marks were his “best assessment of her leadership 
and potential as an officer and xxxx” and were “not the result of any unfair or inap-
propriate influence from any other person.” 

                                                 
13    The  paragraph  in  CDR  X’s  statement  discussing  the  spreadsheet  was  blacked  out  when  the  Chief 
Counsel  first  forwarded  it  to  the  BCMR  on  December  23,  1999.    However,  on  January  4,  2000,  upon 
inquiry  by  the  BCMR  and  the  applicant,  the  Chief  Counsel’s  office  agreed  that  the  language  in  the 
paragraph was not protected from discovery and forwarded a complete copy of CDR X’s statement.  On 
January 12, 2000, the applicant submitted a request under the Freedom of Information Act (FOIA) for a 
copy  of  CDR  X’s  spreadsheet.    On  February  8,  2000,  the  Coast  Guard  informed  the  applicant  that  the 
spreadsheet was not subject to FOIA because it was “not an agency record.”  The Coast Guard stated that 
the spreadsheet was “not part of any government system of records and was not created or stored on a 
government owned computer system.”  The applicant appealed the Coast Guard’s decision and asked the 
BCMR  to  “direct  the  Coast  Guard  to  produce  the  document(s)  at  issue  forthwith”  in  accordance  with 
33 C.F.R.  §  52.82(b).    The  BCMR  declined  to  do  so,  informing  the  applicant  that  while  the  Board  has 
authority to ask the Coast Guard to submit additional information not disclosed in an application if the 
Board deems the information relevant to an issue in a xxxxx, the Board “has no authority to order [CDR 
X] to hand over his private documents.”  The applicant did not agree with the BCMR’s statements and 
asked the Board to draw from the Coast Guard’s refusal to produce the spreadsheet “the usual adverse 
inference” that the spreadsheet would support her allegations. 

APPLICANT’S RESPONSE TO THE VIEWS OF THE COAST GUARD 

 
 
On  March  31,  2000,  the  applicant  responded  to  the  Chief  Counsel’s  advisory 
opinion.  The applicant stated that, because she was separated from the Reserve on June 
30,  1999,  she  must  supplement  her  request  for  relief  by  asking  the  Board  to  expunge 
from her record all references to her involuntary separation from the Coast Guard. 
 
 
In response to the Chief Counsel’s arguments, the applicant stated that she is due 
relief  because  she  has  demonstrated  “manifest  injustice  in  the  treatment  accorded  … 
her” in accordance with 33 C.F.R. § 52.12(a).  Contrary to CAPT X’s statement, the appli-
cant  argued,  she  has  proved  that  the  information  from  XXX  was  not  “ignored”  but 
related to XXXX officers by LCDR XX and cited by CAPT X as a reason to remove her 
from XXXX.  Moreover, the applicant alleged, CAPT X did not name the source at XXX 
who criticized her performance or independently verify the quality of her performance 
at XXX.  The applicant alleged that if CAPT X had attempted to verify the quality of her 
performance  at  XXX,  he  might  have  learned  that  it  was  no  worse  than  that  of  some 
other students, as indicated by her classmate, LT Z. 
 

Regarding OER1, the applicant stated that CDR X’s memorandum to Mr. X was 
“negative  in  tone”  and  “question[ed]  every  mark  higher  than  a  4  which  [Mr.  X] 
intended  to  give  [her].”    Moreover,  she  stated,  the  memorandum  shows  that  CDR  X 
objected to the mark of 5 she received in block 5.a., “Looking Out for Others.”  Yet later 
he signed OER5, in which she received a mark of 6 in block 5.a. although she did not 
supervise any member during that reporting period either.  Therefore, she argued, it is 
clear that CDR X’s bias against Mr. X unfairly harmed the applicant.  She further argued 
that  the  comments  in  OER1  are  much  more  positive  than  and  therefore  inconsistent 
with the marks, proving that OER1 should be corrected. 

 
Regarding OER2, the applicant reiterated her arguments as they appeared in her 
application and in her reply to that OER, emphasizing her lack of control over the xxx 
dates and xxxxx xxx.  She also pointed to several inaccuracies in CDR X’s statement con-
cerning LT X’s involvement in the XXX and XXX xxxxxs and argued that these inaccu-
racies  show  XXX’s  predisposition  against  the  applicant  and  willingness to blame her, 
rather than the more experienced LT X, for the problems that arose.  The applicant fur-
ther argued that the record proves that she was not given sufficient experience to serve 
as xxx xxx in the two xxxxxs by serving as assistant xxx xxx in other xxxxxs and that LT 
X sabotaged her work on the two xxxxxs.  She also argued that, contrary to the Coast 
Guard’s  assertion,  her  handling  of  the  XXX  xxxxx  was  referred  to  in  OER2,  which 
mentions a “serious xxxxxxx xxxxx” and discusses her “xxxxxxx skills.” 

 
The applicant alleged that LCDR XX’s telephone calls to XXXX “served no appar-
ent purpose other than to invite closer scrutiny of the Applicant than of others.”  She 
argued that, had the Coast Guard not “maligned” her reputation at XXXX and had it 

not  assigned  her  as  xxx  xxx  xxx  for  two  complex  xxxxxs  with  insufficient  experience 
and  an  assistant  who  sabotaged  her  efforts,  she  would  have  completed  her  tour  at 
XXXX and developed to her full potential as a xxx xxxx with positive OERs. 

 
In addition, the applicant argued that the Coast Guard erred in designating CDR 
Y, rather than LCDR YY, to act as her supervisor for OER2.  The applicant argued that 
Article 10A-2.d.(1)(a) requires that the supervisor be the “individual to whom the appli-
cant answered on a daily or frequent basis and from whom the Applicant received the 
majority of directives and requirements.”  The applicant alleged that she did not receive 
a single directive from CDR Y or answer to him on a daily basis.  The applicant pointed 
to CDR Y’s comments “in discussing matters with supervisors” and “[d]iscussions with 
supervisors” as evidence that he did not consider himself to be her supervisor and that 
an “unidentified multitude of persons” unfairly provided input for OER2 without any 
accountability. 

 
The applicant also alleged that CAPT X’s and CDR X’s statements contain many 
inaccuracies  that  render  them  generally  untrustworthy.    For  example,  she  stated  that 
she  never  served  as  xxx  xxx  at  XXXX;  she  was  not  given  “every  opportunity  to 
succeed”; she did not complete the indoctrination course on May 11, 199x, but on May 
1, 199x; she did not take a week’s leave after the course concluded; and LT X was not 
assigned as assistant xxx xxx “on very short notice” but on February 10, 199x, around 
the time the applicant was appointed xxx xxx xxx. 

 
Regarding  OER7,  the  applicant  argued  that  those  marks  and  comments  that 
reflect her performance in the Command and XXX are unfair because she did not have 
the  prerequisite  experience,  which  she  alleged  included  nine  months  at  XXXX.    Her 
assignment to the branch, she alleged shows that her superiors were not interested in 
helping her succeed.  Other junior xxxxs in her year group, she alleged, served at least 
nine months at XXXX and then were immediately afterward assigned to the Command 
and XXX so that the xxxxxxx experience they gained at XXXX was still “fresh.” 
  
 
 
Moreover, the applicant argued, OER7 faults her for not xxxxxxxxx in a xxxxx 
xxxxx even though she only served in the branch for six weeks before being transferred.  
She  alleged  that  her  successor  in  the  job,  who  had  more  experience,  did  not  xxxxx 
xxxxxxin the xxxxx until two months after she left.  Therefore, she argued, it was unfair 
to  criticize her for not completing this assignment.  In addition, the applicant argued 
that because her assignment to the branch was unfair to begin with, it was unjust for 
OER7 to criticize her for requesting a transfer out of the branch. 

 
The applicant reiterated her allegation that OER7 unfairly criticized her work in 
the XXXX by stating that her “XXX motions required substantial input/corrections from 
supervisor”  and  “[s]ubstantial  supervisor  participation  required  in  XXX  xxxxx.”    The 
applicant alleged that the statement submitted by Ms. Y and her supervisor’s proven 

lack of knowledge in the XXX area show that she received misguided supervision in the 
XXXX, not that she required too much supervision. 

 
Regarding her marks on the comparison scales of her eleven OERs, the applicant 
argued that they are unjust because she was not competing on a level playing field since 
she was prematurely removed from XXXX and not given the same professional oppor-
tunities  as  other  junior  xxxxs.    Furthermore,  she  argued,  because  comparison  scale 
marks are not required, removal of the marks “is justified, permissible, and fair.” 

 
Finally,  she  argued,  because  the  disputed  OERs  are  unjust  and  inaccurate,  her 
failures of selection for promotion in the Coast Guard and the Reserve are also unjust 
and should be removed from her record.  She stated that “it is impossible to know how 
she  would  fare  before  a  promotion  board  with  the  adverse  OERs  removed  without 
affording [her] an opportunity to be considered on a corrected record.”  She asked the 
BCMR to give her the chance to compete before future Reserve promotion boards with 
a corrected record. 

 
Article 10-A-2.d.(1) of the Personnel Manual (COMDTINST M1000.6A) in effect 
in 199x states that “[t]he Supervisor [for an OER] is normally that 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 directives and requirements.”  It also states 
that civilian employees and officers of other armed services can serve as OER supervi-
sors. 

 
Article 10-A-2.d.(1)(d) provides that “[w]hen an officer responds to more than a 
single individual for different functions, the commanding officer will appoint one indi-
vidual to the position of Supervisor (to whom all secondary supervisors will provide 
evaluation input).” 

 
Article 10-A-2.e.(1)(a) states that “[t]he Reporting Officer is normally the supervi-
sor of the [OER] Supervisor.”  However, Article 10-A-2.e.(1)(h) states that “[t]he Report-
ing  Officer  of  an  officer  assigned  to  a  staff  or  mission  of  another  Service  will  be  the 
commanding  officer  of  the  mission  or  the  senior  officer  of  the  staff  to  which  the 
Reported-on Officer is assigned.” 

 
Article 10-A-2.f.(1)(g) states that “[o]nly Coast Guard commissioned officers may 

serve as Reviewers.” 

 
Selecting the Rating Chain 

RELEVANT REGULATIONS 

 

 

Selecting a Reporting Period 

 
Article 10-A-3 provides that lieutenants shall receive regular, semiannual OERs 
at the end of each May and November.  However, the officer’s command may choose 
not to submit a semiannual OER if the officer has served at the unit for fewer than 92 
days; has received an OER within the past 92 days; or will receive an OER for another 
reason, such as a transfer, within the next 92 days.  In addition, an OER may be pre-
pared whenever an officer is detached from a unit or when there is a change of report-
ing officers.  The article also states that “[t]he welfare of the Reported-on Officer should 
be paramount when determining the appropriate time to submit the OER.” 

 

 

Preparing an Officer Support Form (OSF) 

 
Article 10-A-5 contains instructions for OSFs.  Article 10-A-5.a. states that an OSF 
is  “an  aid  to  establishing  a  clear  understanding  of  job  expectations  and  to  assist  the 
Supervisor  in  providing  constructive  performance  feedback  and  in  preparing  proper 
evaluations.”  A lieutenant’s supervisor may use an OSF at his discretion but must use 
it “when a senior member of the rating chain directs its use.”  The OSF “[s]erves as a 
vehicle for clarifying the Reported-on Officer’s job responsibilities and areas of the job 
which either the Reported-on Officer and/or Supervisor feel should receive emphasis 
during the reporting period.”  The duration of the period covered by the OSF, which is 
normally but need not be the same as the reporting period, is noted on the OSF when it 
is prepared.  Article 10-A-5.d.(1)(c). 

Duties of the Rating Chain 
 
 
Article  10-A-1.b.(1)  states  that  “[e]ach  commanding  officer  must  ensure  that 
accurate,  fair,  and  objective  evaluations  are  provided  to  all  officers  under  their  com-
mand.” 
 

Article 10-A-2(d)(2) states that the supervisor “[e]valuates the performance of the 
Reported-on  Officer  in  the  execution  of  his/her  duties”  and  “[p]rovides  performance 
feedback to the Reported-on Officer upon that officer’s request during the period or at 
such other times as the Supervisor deems appropriate.”  In addition, “[a]t the request of 
the Reported-on Officer, or when deemed necessary, [the supervisor] discusses duties 
and areas of emphasis on the job with the Reported-on Officer at the beginning of the 
reporting period.  The optional OSF worksheet, or other format specified by the Super-
visor, may be used as an aid.” 

 
Article 10-A-2.e.(2)(d) states that the reporting officer must “[e]nsure[] the Super-
visor fully meets responsibilities for administration of [the evaluation system]. …  If a 
Supervisor submits evaluations that are inconsistent with actual performance or unsub-
stantiated  by  narrative  comments,  the  Reporting  Officer  shall  return  the  report  for 

correction or reconsideration, counsel the Supervisor, and consider this when reporting 
on the performance of the Supervisor.  The Reporting Officer may not direct in what 
manner  an  evaluation  mark  or  comments  is  to  be  changed  (unless  the  comment  is 
prohibited …).” 

 
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.” 

 

Instructions for Preparing an OER 
 

Article 10-A-4.d.(4) instructs supervisors to prepare blocks 3 through 7 of an OER 
as  follows  (virtually  identical  instructions  are  provided  in  Article  10-A-4.d.(7)  for 
reporting officers, who complete blocks 8 through 11): 
 

(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  Officer’s  performance  to  the  level  of  performance 
described by the standards.  The Supervisor shall take care to compare the officer’s per-
formance 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 Supervi-
sor fills in the appropriate circle on the form in ink. 

• • • 

(d) 
In the “Comments” sections following each evaluation area, the Supervisor shall 
include  comments  citing  specific  aspects  of  the  Reported-on  Officer’s  performance  and 
behavior  for  each  mark  that  deviates  from  a  “4.”.  .  .    The  Supervisor  shall  draw  on 
his/her  own  observations,  from  those  of  any  secondary  supervisors,  and  from  other 
information accumulated during the reporting period.    
 
(e)    Comments  should amplify and be consistent with the numerical evaluations in the 
evaluation area.  They should identify specific strengths and weaknesses in performance 
or qualities.  Well-written comments must be sufficiently specific to paint a picture of the 
officer’s performance and qualities which compares reasonably with the picture defined 
by the standards marked on the performance dimensions in the evaluation area. . . . 

 

Article 10-A-4.d.(9) contains instructions for completing the comparison scale: 
 
The Reporting Officer shall fill in the circle that most closely reflects the Reporting Offi-
cer’s ranking of the Reported-on Officer relative to all other officers of the same grade the 
Reporting  Officer  has  known.  …    No  mark  need  be  entered  if  there  were  insufficient 
opportunities to make a judgment.  In this xxxxx the Reporting Officer should indicate so 
with a short statement in Section 11. 
 

Replies to OERs 
 
 
Article 10-A-4.h. allows the Reported-on Officer to file a reply to any to “express 
a  view  of  performance  which  may  differ  from  that  of  a  rating  official.”    However, 

“[c]omments pertaining strictly to interpersonal relations or a personal opinion of the 
abilities or qualities of a rating chain member serve no purpose and are not permitted.” 
 

FINDINGS AND CONCLUSIONS 

1. 

2. 

3. 

The Board has jurisdiction concerning this matter pursuant to section 1552 

 
 
The  Board  makes  the  following  findings  and  conclusions  on  the  basis  of  the 
applicant's military record and submissions, the Coast Guard's submission, and appli-
cable law: 
 
 
of title 10, United States Code.  The application was timely. 
 
 
The applicant requested an oral hearing before the Board.  The Chairman, 
acting pursuant to 33 C.F.R. § 52.31, denied the request and recommended disposition 
of the case without a hearing.  The Board concurs in that recommendation. 
 
 
The applicant asked the Board to raise certain marks in OER1 because, she 
alleged, the reporting officer, CDR X, improperly influenced her supervisor, Mr. X, to 
lower them.  However, in their signed statements, the applicant’s supervisor did not say 
that he had been directed to lower specific marks in violation of Article 10-A-2.e.(2)(d) 
of the Personnel Manual, and the reporting officer denied having directed the supervi-
sor to lower specific marks.  In addition, the reporting officer submitted a copy of the 
memorandum he apparently sent to the supervisor requiring corrections to OER1.  The 
Board finds that the reporting officer’s memorandum to the supervisor complied with 
both the letter and the spirit of Article 10-A-2.e.(2)(d).  The supervisor responded to the 
memorandum by lowering certain marks, but he could have chosen to justify his higher 
marks  with  supporting  comments.    Therefore,  the  applicant  has  failed  to  prove  by  a 
preponderance of the evidence that any of the marks or comments in OER1 are inaccu-
rate or unjust or that the reporting officer exercised improper influence over the super-
visor’s evaluation of her performance. 
 

4. 

The  applicant  asked  the  Board  to  remove  OER2  in  its  entirety  based  on 
multiple allegations detailed above.  The applicant proved that a branch chief at XXX 
called XXXX to check on her progress and to communicate concerns about her profes-
sional capabilities raised during the previous reporting period.  Although a fellow stu-
dent at XXX stated that other students encountered problems in their xxx xxxs at least 
as severe as those of the applicant, the chief of XXX received a report from the school 
indicating that her performance at school was poor enough to jeopardize her gradua-
tion.  Therefore, the applicant has failed to prove that the branch chief’s concerns were 
false or groundless.  Furthermore, the applicant has failed to prove that it was improper 
for the officer to make such calls to XXXX.  Any xxxx whose professional abilities are 
unproved  and  have  been  called  into  question  should  expect  such  concerns  to  be 
communicated to her superiors and should expect extra scrutiny when transferred to a 

5. 

new,  responsible  position.    Although  the  applicant  characterized  the  branch  chief’s 
communication  as  “poisoning  the  well,”  the  Board  finds  that  the  calls  fell  within  the 
bounds  of  responsible  xxxx  supervision  by  her  command.    Moreover,  the  applicant 
failed  to  prove  that  the  calls  from  the  branch  chief  improperly  influenced  her  rating 
chain’s evaluation of her professional abilities. 
 
 
The applicant also alleged that she was “set up to fail” during the report-
ing period for OER2 by being assigned two complex xxxxxs with a relatively inexperi-
enced xxxx as assistant xxx xxx who “sabotaged” the applicant’s efforts.  The statement 
of LCDR YY, a senior xxxx at XXXX who assigned her XXXX xxxxxs, indicates that the 
volume of XXXX xxxxxs the applicant could help xxxxxe was unusually low at the time, 
so she had less xxxxxorial and xxxxxxx experience than she otherwise might have had 
when  she  was  assigned  the  XXX  and  XXX  xxxxxs  by  the  Coast  Guard  on  or  about 
February 10, 199x.  LCDR YY’s statement also indicates that, perhaps because of the low 
volume, she was told she could “take as much time as she needed” to work the xxxxxs, 
although she was not permitted to defer the xxxs dates set for mid March.  Thus, the 
record reflects that the applicant had just a month to prepare for the xxxxxs and had to 
do  so  while  lacking  access  to  some  of  the  records  and  with  the  help  of  a  relatively 
inexperienced  assistant  xxx  xxx.    However,  the  applicant  has  not  proved  that  the 
obstacles she faced in xxxxxing XXX and XXX were maliciously created to sabotage her 
performance.  In addition, the record reflects that the applicant made these difficulties 
known to at least one of her superiors, and she has not proved that they were unknown 
to her rating chain and were not taken into account when they evaluated her perform-
ance  in  OER2.    In  her  reply  to  OER2,  the  applicant  described  the  obstacles  she  faced 
during the reporting period, but the endorsements of her supervisor and reporting offi-
cer  forwarding  her  reply  to  the  Commandant  reconfirmed  their  assessments  of  her 
abilities and potential. 
 
 
The applicant also alleged that the rating chain for OER2 was improperly 
composed  because  the  XXXX  xxxx  who  assigned  her  work  did  not  serve  as  the 
supervisor for OER2.  While at XXXX, the applicant performed work assigned both by 
the Navy and by the Coast Guard.  Article 10-A-2.d.(1)(d) provides that “[w]hen an offi-
cer responds to more than a single individual for different functions, the commanding 
officer will appoint one individual to the position of Supervisor (to whom all secondary 
supervisors will provide evaluation input).”  Therefore, although LCDR YY may have 
assigned  her  xxxxxs  on  behalf  of  XXXX,  the  applicant  has  not  proved  that  it  was  an 
error or unjust for CDR Y to serve as the supervisor for OER2.  Moreover, the record 
reflects  that,  as  one  of  her  supervisors,  CDR  Y  had  opportunities  to  observe her per-
formance and that he properly received input from others who supervised her work. 
 

Although the xxxx’s statement indicates that the reviewer for OER2 was 
“not  surprised” by the xxxx’s negative report on her performance, and the xxxx con-
cluded  that  she  had  been  “prejudged,”  the  applicant  has  not  proved  that  the  rating 

6. 

7. 

8. 

9. 

chain for OER2 was unfairly biased against her.  The xxxx’s statement indicates that the 
reviewer was not surprised by her poor performance in the xxxxxxx.  This indicates that 
the reviewer knew of previous instances of poor performance on her part or had heard 
through LT X about the problems she encountered in the xxxs; it does not prove that he 
was  biased  against  her  or  that  he  unfairly  evaluated  her  performance  in  OER2.  
Likewise,  the  statement  of  LCDR  YY  indicating  that  he  evaluated  the  applicant’s 
performance more favorably than did the members of her rating chain does not prove 
that their evaluations were in error or unjust.  
 
 
The applicant also alleged that OER2 was unfair because she was unjustly 
removed  from  XXXX  after  just  three  months’  experience.    The  record  indicates  that, 
despite  LCDR  YY’s assessment of her abilities, the XXXX command was unwilling to 
allow the applicant to xxxxxe Navy xxxxxs and wanted to assign her to other duties.  
Under  the  Memorandum  of  Understanding  between  the  Coast  Guard  and  the  Navy, 
junior Coast Guard xxxxs were assigned to XXXX to gain experience in xxxxxxx xxxxxs.  
In light of that purpose and given the Navy’s determination that it would not continue 
to entrust her with xxxxxxx work, the Board finds that the Coast Guard did not err or 
commit any injustice when it removed her from XXXX.  Furthermore, under Article 10-
A-3 of the Personnel Manual, it is appropriate to prepare an OER when a member is 
removed from an assignment and the reporting officer changes.   
 
 
The applicant asked the Board to remove OER3 in its entirety because of 
the shortness of the reporting period, her rating chain’s alleged bias against her, and an 
alleged “hostile work environment” created by her supervisor, LCDR X, the chief of the 
XXX  at  XXX.    The  Chief  Counsel  of  the  Coast  Guard  recommended  that  the  Board 
remove OER3 from the applicant’s record due to the shortness of the reporting period.  
Under  Article  10-A-3  of  the  Personnel  Manual,  the  applicant’s  command  could  have 
skipped the semi-annual reporting period ending on May 31, 199x, and waited until the 
end  of  the  next semi-annual reporting period, November 30, 199x, to submit an OER 
evaluating her performance at the XXX.  The record indicates that the choice of the 57-
day reporting period, from April 5, 199x, to May 31, 199x, was made by the applicant at 
the  suggestion  of  LCDR  X.    The  record  indicates  that  the  choice  was  made  based  on 
their  mutual  hope  that  she  would  receive  a  good  OER  that  would  counteract  any 
negative effect of OER2.  In light of the nature of the work at the XXX, the Board finds 
that LCDR X’s expectation and the initial choice of the shorter reporting period were 
reasonable.   
 

CDR  X,  the  reporting  officer  for  OER3,  stated  that  once  the  applicant 
chose the shorter reporting period, he considered the choice “immutable.”  However, 
nothing in the regulations made the choice irrevocable.  The dates recorded on an OSF 
need not be the same as those of the reporting period.  Personnel Manual, Article 10-A-
5.d.(1)(c).    In  addition,  Article  10-A-3  of the Personnel Manual requires that the eval-
uee’s welfare be “paramount” in the choice of the reporting period.  Therefore, at the 

10. 

end of May 199x, the applicant’s rating chain was not required to submit a semi-annual 
OER  covering  her performance during the previous 57 days.  Moreover, she was not 
being detached from a unit, and her reporting officer was not leaving.  Given the nega-
tive nature of OER3, it clearly was not in her best interest to prepare it for inclusion in 
her  record.    Therefore,  although  the  submission  of  OER3  was  within  the  command’s 
prerogative,  the  Board  concludes  that  her  command  committed  an  injustice  when  it 
prepared  OER3  based  on  just  57  days’  observation  of  her  performance  at  the  XXX.  
OER3 should be removed from her record.  In light of this finding, it is unnecessary for 
the Board to address the applicant’s other allegations concerning OER3. 
 
 
The applicant asked the Board to remove OER7 in its entirety because, she 
alleged,  it  was  unfair  for  her  to  be  assigned  to  the  Command  and  XXX  without nine 
months’ experience at XXXX.  The “Junior Xxxx Intra-Office Dream Sheet,” which, the 
applicant alleged, described XXX policy regarding junior xxxx assignments, states that 
“to the greatest extent possible every ‘junior xxxx’ will spend at least 9 months” in each 
of  the  various  branches.    It  also  states  that  “XXXX  experience”  is  a  prerequisite  to 
assignment  to  the  Command  and  XXX.    Assuming  the  “Dream  Sheet”  accurately 
describes office policy, the Board finds that the applicant’s assignment to the Command 
and XXX in November and December 199x did not violate that policy.  She had “XXXX 
experience” which is cited as a prerequisite to assignment to the Command and XXX.  
Although it was not possible for the Coast Guard to give her nine months of experience 
xxxxxing xxxxxxx xxxxxs at XXXX because of the Navy’s decision, it was not therefore 
wrong for Coast Guard to try to give her nine months of experience in the Command 
and  XXX.    Nor  was  it  wrong  for  her  rating  chain  to  comment  negatively  upon  her 
unwillingness to complete the assignment in OER7. 
 
 
The applicant alleged that the comment in OER7 criticizing her failure to 
xxxxxxxxx  in  a  xxxxxx  xxxxx  during  her  six  weeks  at  the  Command  and  XXX  was 
unfair  because,  after  she  left  the  branch,  the  xxxxxx  were  not  xxxxx  for  another  two 
months.    However,  the  fact  that  the  xxxxx  were  not  xxxxx  immediately  upon  her 
leaving the branch does not prove that she was not at fault for failing to finish xxxxx 
them  while  she  was  there.    OER7  indicates  that  xxxxxx  the  xxxxxx  was  her  primary 
assignment. 
 
 
The applicant also alleged that OER7 was unfair because her supervisor in 
the XXXX was biased against her and lacked sufficient xxx knowledge to evaluate her 
performance.    The  evidence  suggests  that  her  supervisor  may  have  heard  negative 
reports  about  the  applicant’s  performance  prior  to  her  assignment  to  the  branch  and 
that her supervisor often vocally criticized the applicant’s performance.  The applicant 
submitted statements by a yeoman and a volunteer xxxxxx in the XXXX indicating that 
they thought the criticism was unfair.  She also submitted evidence indicating that she 
and  the  supervisor  strongly  disagreed  about  one  or  more  xxx  decisions  made  by  the 
supervisor that a xxxx determined were erroneous.  However, the Board finds that the 

12. 

11. 

13. 

15. 

evidence  does  not  prove  that  the  supervisor  was  prejudiced  against  the  applicant;  it 
merely  proves  that  she  had  heard  others  in  the  command  criticize  the  applicant’s 
performance,  that  she  herself  thought  poorly  of  some  of  the  applicant’s  work  and 
professional skills, and that she expressed that opinion to the applicant within others’ 
hearing.  In addition, the anecdotal evidence of two erroneous xxx determinations on 
the  part  of  the  supervisor  does  not  prove  that  the  supervisor  was  incompetent  to 
evaluate the applicant’s work and xxx skills. 
 
 
The applicant also alleged that OER7 was inaccurate because of her super-
visor’s  comment  that  her  “XXX  motions  required  substantial  input/correction  from 
supervisor” and her reporting officer’s comment that “[s]ubstantial supervisor partici-
pation  [was]  required  in  XXX  xxxxx.”    A  volunteer  xxxxx  who  helped  the  applicant 
prepare the XXX xxxxx stated that she strongly disagreed with this assessment of the 
amount  of  supervision  required  by  the  applicant  in  the  XXX  xxxxx.    However,  the 
Board  finds  that  the  evidence  does  not  prove  that  the  comments  are  erroneous.    The 
Board does not find the statement of the xxxxx more credible than the judgments of the 
applicant’s rating chain. 
 
 
The  applicant  asked  the  Board  to  remove  all  of  the  comparison  scale 
marks  on  her  OERs  through  her  date  of  discharge  from  the  Reserve  (OER1  through 
OER11)  or  through  her  date  of  release  from  active  duty  (OER1  through  OER9).    She 
alleged that all of the comparison scale marks were unfair because she was never trans-
ferred from XXX where the “well was poisoned” so that she could get a “fresh start,” 
and  because  she  was  not  given  the  same  chance  to  succeed  as  other  junior  xxxxs.  
Although  the  record  indicates  that  the  applicant  acquired  a  very  poor  professional 
reputation  at  XXX,  she  has  not  proved  that  it  was  inaccurate,  that  it  prevented  her 
reporting officers from comparing her properly in accordance with Article 10-A-4.d.(9) 
of the Personnel Manual at the end of each reporting period, or that she was entitled to 
a  “fresh  start”  at  another  command.    The  “Junior  Xxxx  Intra-Office  Dream  Sheet” 
indicates that junior xxxxs were expected to remain at XXX for several years, acquiring 
at  least  nine  months  of  experience  in  each  of  six  branches,  and  the  applicant  has  not 
proved  that  it  was  unjust  for  the  Coast  Guard  to  assign  her  in  accordance  with  this 
policy.  In addition, the applicant has not proved that she was denied the same chance 
to succeed as other junior xxxxs at XXX.  Although her poor performance at XXXX and 
early removal obviously hampered her professional development given the importance 
of xxxxxxx experience to the career of a military xxxx, the applicant has not proved by a 
preponderance  of  the  evidence  that  her  removal  from  XXXX  and  lack  of  xxxxxxx 
experience were the result of any error or injustice committed by the Coast Guard (see 
Findings 4 through 8, above). 
 
The  applicant  argued  that  the  Board  should  draw  an  adverse  inference 
 
from the Coast Guard’s failure to produce CDR X’s spreadsheet of the comparison scale 
marks he has assigned to the officers he has supervised.  The existence of the spread-

14. 

16. 

sheet  could  be  considered  evidence  that  CDR  X  properly  completed  the  comparison 
scales  in  the  applicant’s  OERs  by  comparing  her  against  other  officers  he  had  super-
vised, in accordance with Article 10-A-4.d.(9) of the Personnel Manual.  However, there 
is  no  evidence  in  the  record  indicating  that  CDR  X  misunderstood  or  purposefully 
failed  to  comply  with  the  instructions  in  Article  10-A-4.d.(9)  when  he  completed  the 
applicant’s OERs.  The Board cannot assume that CDR X failed to comply with Article 
10-A-4.d.(9)  merely  because  the  Coast  Guard  has  not  produced  the  spreadsheet  he 
allegedly  created  to  help  him  remember  his  evaluees’  comparison  scale  marks  and 
relative  experience.    In  the  absence  of  proof  that  CDR  X  either  complied  or  failed  to 
comply with the instructions in Article 10-A-4.d.(9), the Board presumes that he acted in 
good faith and in accordance with the regulation.  Arens v. United States, 969 F.2d 1034, 
1037 (199x); Sanders v. United States, 594 F.2d 804, 813 (Ct. Cl. 1979). 
 

18. 

19. 

17. 

The content of the spreadsheet allegedly shows that CDR X assigned the 
applicant lower comparison scale marks than he assigned to other xxxxs with her level 
of  experience.    However,  even  if  the  spreadsheet  showed  the  converse—that  the 
applicant’s  comparison  scale  marks  were  higher  than  those  of  other  xxxxs  of  similar 
experience—this  would  not  prove  that  her  comparison  scale  marks  were  inaccurate.  
Therefore, the Board finds that there is no reasonable significant adverse inference to be 
drawn  from  the  Coast  Guard’s  failure  to  produce  CDR  X’s  spreadsheet.    Moreover, 
neither  the  existence  nor  the  content  of  the  spreadsheet  are  material  to  the  Board’s 
decision in this xxxxx.  The applicant has failed to prove by a preponderance of the evi-
dence that the comparison scale marks in her OERs are unfair or inaccurate assessments 
of her performance in comparison with the performance of other officers of the same 
rank known to her reporting officers. 
 
 
The applicant made numerous allegations with respect to the actions and 
attitudes of her command, her rating chains, and other Coast Guard and Navy officers.  
Those allegations not specifically addressed above are considered to be without merit 
and/or not dispositive of the case.  
 

The only error or injustice the applicant has proved by a preponderance of 
the evidence with respect to her OERs is the inclusion of OER3 in her record.  The appli-
cant alleged that the errors in her record caused her to fail of selection for xxxxx, to be 
released from active duty, and to be discharged from the Reserve.  She asked the Board 
to remove her failures of selection and return her either to active duty or to the Reserve.  
To have her failures of selection removed from her record, the applicant must make a 
“prima facie showing of a substantial connection or causal nexus between the error and 
the promotion passover or release from active duty.”  Germano v. United States, 26 Cl. Ct. 
1446,  1461  (199x),  citing  Engels  v.  United  States,  678  F.2d  173,  175  (Ct. Cl.  1982).  
Determining whether a nexus exists requires answering two questions:  “First, was [the 
applicant’s] record prejudiced by the errors in the sense that the record appears worse 
than  it  would  in  the  absence  of  the  errors?    Second,  even  if  there  was  some  such 

20. 

prejudice, is it unlikely that [the applicant] would have been promoted in any event?”  
Engels, supra at 176. 
 
Judged  by  its marks, OER3 is the third worst of the eleven OERs in the 
 
applicant’s record.  Of the three OERs in her record with a comparison scale mark of 2, 
it has the highest average mark (4.0) for the performance categories.  The comments in 
OER3 are consistent with the marks and do not alter this assessment.  Although OER3 
covers  only  57  days  of  the  applicant’s  tenure  at  XXX,  the  Board  concludes  that  her 
record appears marginally better without OER3.  However, given the poor OERs and 
very  low  comparison  scale  marks  that  constitute  most  of  the  rest  of  the  applicant’s 
record, the Board concludes that it is very unlikely that the applicant would have been 
promoted either while on active duty or while drilling in the Reserve even if OER3 had 
never been prepared.  Therefore, the Board finds that the applicant’s failures of selec-
tion should not be removed from her record, and she should not be returned to active 
duty or to the Reserve. 
 
 
the remainder of her requests should be denied.  

21.  Accordingly,  OER3  should  be  removed  from  the  applicant’s  record,  but 

ORDER 

The  application  for  correction  of  the  military  record  of  former  XXXXXXXX, 

 
 
USCG, is hereby granted in part as follows: 
 
 
The officer evaluation report (OER) covering the period April 5, 199x, to May 31, 
199x,  shall  be  removed  from  her  record  and  replaced  with  an  OER  prepared  and 
marked “For Continuity Purposes Only.” 
 
 
 

All other relief is denied. 

 

 

 

 

 

 

 
 

 

 

 
 

 
 
 

 
 

 
 

 
 
 

 
 

 
 

 
 
 

 
 

 

 
Robert C. Ashby 

 

 

 
 
John A. Kern 

 

 
David M. Wiegand 

 

 

 

 

 

 

 

 

 

 

 

  

 
 
 

 
 
 
 

 
 
 
 

 
 
 
 
 



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