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CG | BCMR | OER and or Failure of Selection | 2001-017
Original file (2001-017.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. 2001-017 
 
Xxxxxxxxxxxxxxxxxx 
Xxxxxxxxxxxxxxxxxx 

 

 
 

FINAL DECISION 

 
ANDREWS, Deputy Chair: 
 
 
This is a proceeding under the provisions of section 1552 of title 10 of the United 
States Code.  It was docketed on April 4, 2001, upon the applicant’s completion of the 
application with additional significant evidence.1   
 
 
appointed members who were designated to serve as the Board in this case. 

This  final  decision,  dated  November  26,  2002,  is  signed  by  the  three  duly 

APPLICANT’S REQUEST FOR RELIEF 

 

 
 
The applicant, a retired chief warrant officer (CWO3), asked the Board to correct 
her record by expunging an officer evaluation report (disputed OER) she received for 
the period July 1, 19xx, to July 31, 19xx, and by altering comments in a concurrent OER 
she  received  for  a  temporary  assignment  writing  contingency  plans  from  March  3  to 
August 24, 19xx.  She also asked the Board to expunge her retirement and her failures of 
selection  for  promotion  by  the  PY  (promotion  year)  xxxx  and  xxxx  selection  boards 
from her record, return her to active duty, and award her back pay and allowances.2  
 

SUMMARY OF THE APPLICANT'S ALLEGATIONS AND EVIDENCE 

                                                 
1    The  applicant  first  submitted  her  application  on  January  11,  2001.    On  April  4,  2001,  she  submitted 
significant new evidence, causing her application to be newly completed.  She later received extensions of 
the time to respond to the advisor opinion totaling more than five months.  
2  The applicant was not selected for promotion in 19xx and 19xx and was slated to retire on November 1, 
19xx.    However,  on  August  19,  19xx,  in  Docket No. 1998-048, the BCMR ordered the removal of those 
failures of selection because the Coast Guard had not obeyed the Board’s order in Docket No. 124-92 to 
remove an OER from her record.  In Docket No. 1998-048, the Board found that the erroneous continued 
presence of that OER in her record when it was reviewed by the selection boards in 19xx and 19xx could 
have  caused  her  failures  of  selection.    However,  after her record was properly corrected, the applicant 
failed of selection again in xxxx and xxxx by the PY xxxx and xxxx boards and was retired on July 1, xxxx. 

 
 
The applicant stated that the disputed OER, the third she received while serving 
as an administrative officer at a xxxxxxxxxxxxxxxxxxxx (XXX), is “filled with violations 
of the Personnel Manual, lies, half-truths, and distortions of fact.”  She stated that her 
first two OERs as the Administrative Officer at the XXX from October 1, 19xx, through 
June 30, 19xx, more accurately reflect her performance.  She pointed out that nothing in 
those first two OERs suggests that her performance at the XXX was lacking.  She alleged 
that after a new commanding officer (CO) arrived at the office at the  beginning of her 
third evaluation period at the XXX, she was not given a “fresh start” and was removed 
from her position as Administrative Officer within a few weeks.  The numerical marks 
(on  a  scale  of  1  to  7,  with  7  being  best)  and  comments  in  the  disputed  OER  are  as 
follows: 
 

MARKS AND COMMENTS IN DISPUTED OER 

(The bold letters inserted in the text refer to correspondingly lettered allegations and supporting evidence below.) 
# 
3a  Being Prepared/ 

MARK  WRITTEN COMMENTS BY SUPERVISOR 

4 

CATEGORY 

Planning 

3b  Using Resources 
3c  Getting Results 
3d  Adaptability 
3e  Professional 
Competence 

4a  Speaking and 

Listening 

4b  Writing 

5a 

Looking Out for 
Others 

5b  Developing 

Others 

5c  Directing Others 
5d  Teamwork 
5e  Workplace 

Climate 

3 
4 
4 
3 

5 

4 

4 

4 

4 
3 
3 

“Continued with process improvement through assisting in departmental goals. 
Consolidated unit instructions & migrated to SWS III. Provided positive support in 
preparation of upcoming MLC compliance audit.  Updated unit reserve personnel 
roster on SWS III data base; result - 98% success rate in contacting reserve mem-
bers during OPERATION POSITIVE RESPONSE exercise.  [A1] With some resis-
tance eventually agreed to provide weekend admin support to reservists; support 
resulted in greater reserve satisfaction & increased development of reserve YN 
skills.  Identified shortcomings of new Tricare health care, developed survey to 
measure customer satisfaction.  [B] Administrative credibility at times in question, 
professional competence supplemented by very capable YN1.  As Mutual Assis-
tance Officer did not always follow program & command guidelines; recommended 
loan approvals without informing cmd that they were outside prgm parameters; 
failed to provide reference material w/ loan packages even after requested by XO; 
[C] refused to learn computerized check-issuing system resulting in unfair delays to 
applicants.  Strong commitment to members as alcohol/substance abuse counselor 
[D1] but failed to follow CG prgm guidelines & failed to inform/update XO on per-
sonnel problems & rehab recommendations; e.g. applied inappropriate & unrealistic 
standard in selecting counselor, unnecessarily delaying essential patient 
counseling.”  
“Confident & articulate speaker; gave informative presentation on sensitive topics to 
unit utilizing creative attention tactics, held all hands interest for duration of 
program; received kudos from many attendees.  Written material often superb, 
demands higher standards from subordinates.  Showed improvements on 
proofreading through submission of migrated unit instructions resulting in a product 
close to completion.  Excellent vocabulary; written materials logically prepared & 
required minimal correction.” 
“Demonstrated concerned response to unit members in need of counseling for both 
alcohol screening and mutual assistance requests; arranged counseling for mem-
bers at local military treatment facility, prepared request for member seeking 
funding for relative’s funeral.  Supported flex time arrangement for subordinate with 
extensive commute.  Compassionate towards needs of single parent requiring 
special consideration.  As CDAR, effectively provided alcohol-abuse training to all 
hands.  Supported decision to update unit instructions in preparation for MLC 
compliance audit.  Recognized need to send unit HS TAD to larger medical unit to 
increase skill level.  [A2] Resistant to full support to & from reservists.  Created 

5f 

Evaluations 

3 

stressful workplace environment; e.g. [E] reprimanded senior POs in presence of 
nonrates; e.g. displayed anxiety that POs were conspiring against her; e.g. [F] gave 
poor advice about their low marks to two marginally performing POs; result: 
subordinates involved CEA, XO in seeking relief fm her.  [G] Her poor interaction w/ 
subords & failed leadership resulted in emergency meetings of CPO Mess, CEA, & 
XO.  Evaluations of subordinates on time & accurate.  Rcvd no personal OER input 
despite numerous requests.”  

END OF SUPERVISOR’S SECTION/BEGINNING OF REPORTING OFFICER’S SECTION 

“Concur w/ supervisor. [H] At beginning of the period, served as Admin Dept Chief which included F&S2 and 
SKs.  Dept was dysfuctional & Supply Branch was broken out as separate dept to allow [the applicant] to focus 
on YNs & admin issues & regain leadership credibility.  [I] Admin Dept cont’d to be dysfunctional despite 
numerous command counseling sessions.  Acted unprofessionally during counseling.  Relieved as dept head 
on 9/18/xx due to loss of command confidence in leadership abilities.  She took initiative to request TAD to 
XXXXX which was approved.” 
Initiative 

 

7 

Judgment 

8a 
8b 
8c  Responsibility 
8d  Professional 

Presence 

8e  Health &      
Well-Being 

9 

Comparison 
Scale 

10  Potential 

4 
4 
2 
3 

3 

2 

“Recognized & sought opportunity for personal growth in volunteering for TAD 
assignment.  Upon migrating to SWS III, aggressively sought knowledge & trng on 
new applications resulting in new databases for personnel.  Resourcefully ID’d & 
utilized new application to run spreadsheet in response to D5 data call.  Judgment 
at times in question; requires supervision due to own interpretation of 
regulation/policy; results in time wasted.  More often finds roadblocks than solutions 
when queried for advice by seniors.  [D2] Held off on required counseling of 
member involved in alcohol incident – requesting specific counselor – increasing 
anxiety of member in need of counseling.  [J] Took advantage of position; e.g. 
refused to submit to direct-subordinate HS1’s repeated request for mandatory 
weigh-in prior to TAD; XO led to believe weigh-in accomplished; e.g. [K] wrongly & 
surreptitiously had orders for training issued by HQ, bypassed normal process 
including Supervisor, Training Officer & XO; result – kept eligible member from 
attending school.[3]  Caused others, including subordinates, great emotional stress.  
Occasionally showed pride as member; has potential to reflect positively upon CG.” 
The Comparison Scale is not actually numbered.  The reporting officer is instructed 
to compare the evaluee with other officers of the same rank whom he has known 
and assign one of seven possible marks.  The second mark indicates that the 
evaluee is merely “qualified,” which is better than “unsatisfactory” (the first mark) but 
lower than “competent” (the third mark). 

“Though technically a ‘qualified’ officer, overall performance, attitude and leadership was 
unsatisfactory to marginal this period.  Exhibits great difficulty working with others.  
[L] Professional skills/position often used to “work the system” to own purposes/advantage, 
adversely impacting subordinates and command good order; [she] lost credibility within this 
command.  Not recommended for promotion or leadership positions.” 

 
The disputed OER was signed by the applicant’s supervisor—a lieutenant who 
 
was assigned to serve as Administrative Officer after the applicant was removed from 
that position—on August 4, 19xx; by her reporting officer, the executive officer (XO) of 
the XXX, on November 3, 19xx; and by the reviewer, the CO of the XXX, on November 
5, 19xx.  The applicant submitted the following allegations and evidence concerning the 
disputed comments marked [A1] through [L] in the OER: 
 
COMMENTS [A1] & [A2]: “With some resistance eventually agreed to provide week-
end admin support to reservists.” & “Resistant to full support to & from reservists.” 
 

The applicant alleged that she provided as much support to the reservists as she 
could  “under  the  circumstances.”    She  alleged  that  during  the  19xx  summer  transfer 
                                                 
3  This shaded phrase was deleted from the OER by the Personnel Records Review Board (PRRB). 

season, when she had just two active duty yeoman and one reserve yeoman, her prior-
ity  was  to  process  transferring active duty members.  She alleged that both her com-
mand  and  the  reserve  command  master  chief  were  aware  of  her  office’s  personnel 
shortage.  She alleged that as soon as the transfer season was over, she arranged for the 
active duty yeomen and another reserve yeoman to support the reservists on weekends. 

 
In support of her allegations, the applicant submitted a copy of an email message 
dated  August  15,  19xx,  from  the  reserve  command  master  chief,  who  commented  on 
upcoming retirements and expressed frustration over the lack of administrative support 
for reservists on weekends.  She also submitted copies of email messages she sent to her 
command  in  which  she  asked  that  the  yeoman,  YN1  Y,  whom  she  had  previously 
“loaned” to the housing office be returned to the personnel office since the billet in the 
housing office had recently been filled by another petty officer.  In an email message 
dated September 21, 19xx, she told her command that another reserve yeoman would 
be assisting her office one day a week and that two active duty yeomen in her office had 
agreed to work one Saturday a month each in exchange for the following Monday. 
 
COMMENT [B]:  “Administrative credibility at times in question, professional com-
petence supplemented by very capable YN1.” 
 
 
The applicant alleged that the yeoman referred to in this comment, YN1 X, was 
not  “capable.”    She  stated  that  she  was  not  impressed  with  his  abilities  when  she 
arrived at the XXX, but organized the office so that each yeoman would “have an area 
of expertise or an opportunity to shine.”  She alleged that YN1 X would do only what 
was  necessary  to  get  by,  and  when  she  asked  him  to  conduct  some  training  at  an 
upcoming all hands meeting, he forgot.  She alleged that YN1 X’s replacement in Octo-
ber 19xx complained to her about how badly the work was being done. 
 
COMMENT [C]: “[R]efused to learn computerized check-issuing system resulting in 
unfair delays to applicants.” 
 
 
The applicant alleged that she knew the computerized check-writing system for 
issuing mutual assistance checks.  In support of this allegation, she submitted a state-
ment from the office’s current mutual assistance clerk, who stated that between January 
19xx and March 19xx, the applicant processed 37 checks totaling $24,510.86, whereas all 
other persons in the office had together issued 12 checks totaling $16,675.54.  The appli-
cant alleged that delays in the system occurred because of “micro-management by the 
command” and because, after new work stations were installed, the only work station 
that could handle the check-writing software was in a different department and could 
not be quickly accessed.  She alleged that “there were no delays for checks that were 
considered to be an emergency” and only short delays of a few days for other checks.  
She alleged that her command was not actually dissatisfied with her performance at this 
task but criticized it without justification in the OER to try to justify the low marks. 
 

COMMENTS [D1] & [D2]:  “[B]ut failed to follow CG prgm guidelines & failed to 
inform/update  XO  on  personnel  problems  &  rehab  recommendations;  e.g.  applied 
inappropriate  &  unrealistic  standard  in  selecting  counselor,  unnecessarily  delaying 
essential  patient  counseling.”  &  “Held  off  on  required  counseling  of  member 
involved in alcohol incident – requesting specific counselor – increasing anxiety of 
member in need of counseling.” 
 
 
The applicant denied this comment.  She alleged that she followed the program 
 
guidelines and did not unnecessarily delay anyone’s treatment or cause anyone to be 
“exceptionally  anxious.”    She  stated  that  she  had  been  a  Collateral  Duty  Addictions 
Representative (CDAR) for more than ten years.  She alleged that anyone involved in an 
“alcohol incident” is anxious and that no one had ever complained about her treatment 
recommendations.    She  alleged  that  the  comments  in  the  OER reveal her command’s 
lack of understanding of how the treatment program works.  Treatment for these mem-
bers was “not held up by [her] unrealistic treatment recommendations but by the multi 
levels of bureaucracy the paperwork had to move through and by the command’s own 
delay in adjudicating NJP [nonjudicial punishment].” 
 
 
The applicant also alleged that after she was demoted on September 18, 19xx, the 
XO had a “closed door policy” for her and would not meet with her without someone 
else present.  Therefore, it was impossible for her to communicate with him on sensitive 
issues, such as scheduling a member’s treatment. 
 
 
The applicant stated that she had five CDAR cases during the evaluation period.  
Two were easily resolved by sending the members to a Navy alcohol awareness pro-
gram; two had “other issues” that had to be resolved before treatment could start, and 
the fifth member needed Level II Treatment, but the Navy required that the command 
complete his NJP before he could attend.  After his NJP, she recommended that he be 
sent to a counseling center where there was someone trained to differentiate between 
alcohol abuse and post traumatic stress disorder.  However, her command rejected her 
recommendation  because  of  a  scheduling  problem.    Therefore,  she  located  a  private 
counselor  with  the  necessary  training  and  immediately  notified  the  Maintenance  and 
Logistics Command (MLC).  Unfortunately, there was some delay in MLC’s response. 
 
 
tions Program Representative for MLC, who stated that he found her to be  
 

In support of her allegations, the applicant submitted a statement by the Addic-

professional, truly caring, and [to] have extensive knowledge in the field of addictions.  
[She] continually made extra efforts to find members at [the XXX] the best care possible.  
She  understood that often issues not directly related to chemical dependency, e.g. sup-
port of family, could have a profound effect on treatment success.  With that understand-
ing she worked for approval of local care when appropriate, which was unfortunately a 
lengthier process.  One case in particular ended up “parked” on a Medical Officer’s desk 
at MLC, while he was on temporary assignment, and was inordinately delayed through 
no fault of [the applicant].  In my view she was an excellent … CDAR … . 

 

COMMENT [E]:  “[R]eprimanded senior POs in presence of nonrates.” 
 

The applicant alleged that this accusation was made by YN1 X in a meeting on 
September 17, 19xx (when she was not present), at which he defended himself for using 
foul language and blamed her for his stress.  She stated that, while she may have repri-
manded  senior  POs  in  the  presence  of  nonrates during a previous evaluation period, 
she never did so in the evaluation period for the disputed OER.  She also alleged that 
she herself was reprimanded in front of junior personnel when she was ordered by her 
supervisor  in  September  19xx  to  “work  for”  YN1  X.    She  alleged  that  her  supervisor 
“continued to humiliate” her until she left the XXX on March 1, 19xx, for a temporary 
active duty (TAD) assignment in the xxxxxxxxxxxxxxxxxxxxxxxx (XXXXX).  
 
COMMENT [F]:  “[G]ave poor advice about their low marks to two marginally per-
forming POs; result: subordinates involved CEA, XO in seeking relief fm her.” 
 

 
The  applicant  alleged  that  the  only  “marginally  performing”  petty  officer  she 
supervised was an HS1 (health services technician).  She alleged that she thought the 
HS1 was nevertheless “a capable caring professional and … evaluated her as such and 
… recommended her for promotion.”  However, the applicant’s supervisor, who acted 
as  the  marking  official  for  the  HS1,  did  not  recommend  her  for  advancement.    She 
alleged  that  his  decision  was  made  based  on  only  six  weeks  of  observation,  during 
which the HS1 made a few mistakes.  The applicant stated that she advised the HS1 to 
appeal his decision, but after talking to a career counselor, the HS1 chose to retire. 
 
COMMENT  [G]:  “Her  poor  interaction  w/  subords  &  failed  leadership  resulted  in 
emergency meetings of CPO Mess, CEA, & XO.” 
 
 
 
The applicant alleged that this comment refers to the incident on September 17, 
19xx, when YN1 X used “foul and aggressive language” that was overheard by a master 
chief.  When called on it, YN1 X cried and blamed the applicant for not being “there for 
him.”  A meeting was called but her side of the story was never requested, and the com-
mand did not consider or investigate the yeoman’s background, which she alleged was 
very  troubled  with  continued  drinking  despite  Level  III  treatment  for  alcohol  abuse.  
She  stated  that, based on the yeoman’s story, her command “turned its back” on her 
and  “convicted  and  executed”  her  without  allowing  her  to  defend  herself.    She  was 
removed from her position as Administrative Officer the next day. 
 
COMMENT  [H]:  “At  beginning  of  the  period,  served  as  Admin  Dept  Chief  which 
included F&S2 and SKs.  Dept was dysfuctional & Supply Branch was broken out as 
separate dept to allow [the applicant] to focus on YNs & admin issues & regain lead-
ership credibility.” 
 
 
 
The  applicant  alleged  that  the  Supply  Branch  was  “broken  out”  as  a  separate 
department only to avoid having one CWO (her) supervise another CWO.  She alleged 
that no one ever counseled her about the matter or suggested that the division was nec-

essary  because  she  lacked  “leadership  credibility.”    She  alleged  that  the  comment  is 
inconsistent  with  her  previous  OER  and  with  the  fact  that  the  command  later  reor-
ganized the whole Administrative Department into a Support Services Branch headed 
by a lieutenant commander. 
 
COMMENT  [I]:    “Admin  Dept  cont’d  to  be  dysfunctional  despite  numerous  com-
mand counseling sessions.  Acted unprofessionally during counseling.” 
 
 
The  applicant  alleged  that  the  only  command  counseling  session  she  received 
occurred  in  August  19xx,  a  few  weeks  into  the  evaluation  period,  when  the  new  CO 
arrived.  She alleged that the actual purpose of the session was for her to brief the new 
CO.  She alleged that she later requested additional meetings to no avail.  She alleged 
that during their one session, she told the CO that she was short-staffed because it was 
the  height  of  transfer  season  and  because,  before  the  division  of  the  department,  she 
had “loaned” two petty officers to other branches assuming that, as department head, 
she would be able to move them back.  However, since the division, she could no longer 
move them back to her office.  She alleged that her explanations “fell on deaf ears.” 
 
 
The applicant further alleged that during the briefing, she realized that the out-
going  CO  had  told  the  new  CO  about  a  memorandum  she  had  written  in  June  19xx 
describing three situations in which African-American petty officers in her department 
had threatened white subordinates with physical violence.  She stated that the outgoing 
CO had not taken her allegations seriously and had told her to get counseling because 
she was “hyper-sensitive to racial issues.”  She stated that she was a trained civil rights 
counselor  and  had  graduated  from  the  Defense  Equal  Opportunity  and  Management 
Institute and could therefore recognize “situations that affect productivity in the work 
place.”  
 
 
In support of her allegations, the applicant submitted a memorandum she pre-
pared on her office’s organization.  It indicates that of four yeoman (YN) positions, two 
were filled, one was vacant because a YN1 was “on loan” to the housing office, and a 
second was vacant because the member had transferred.  It also indicates that a seaman 
was getting on-the-job training to fill the second vacancy, but the applicant alleged that 
other duties left the seaman little time for his training. 
 
 
The applicant submitted a copy of the memorandum she wrote to the previous 
CO  on  June  25,  19xx,  about  a  “hostile  and  intimidating  work  environment”  in  her 
department.  It indicates that she had recently witnessed three incidences in which Afri-
can-American petty officers had “utter[ed] threats of violence to junior white memers.”  
She stated that both supervisors and subordinates were tolerating the threats out of fear 
of being “labeled racist.”  She also stated that supervisors were assigning a dispropor-
tionate amount of work to white male subordinates “out of fear of reprisals” by women 
and minorities.  She indicated that African-American subordinates were challenging her 
authority and asking to talk to the XO or CO.  

 
 
The  applicant  submitted  a  statement  by  a  fellow  CWO  who  had  served  as  the 
Operations  Officer  of  the  XXX  until  July  19xx.    The  CWO  stated  that  the  previous 
Administrative Officer at the XXX had been transferred early due to conflicts with the 
XO.  He stated that because the applicant had no prior experience as an Administrative 
Officer, he “spent many sessions with [her] trying to provide guidance.”  He stated that 
she cried in his office many times after having frustrating meetings with the XO, whom 
she believed had prejudged her “based on the way they felt toward the previous Admin 
Officer.”  She told him that “she could not get guidance or support from the command.”  
The CWO stated that he did witness one occasion when the CO embarrassed the appli-
cant  at  an  “All  Hands  Meeting”  by  commenting  on  her  not  being  prepared  to  brief 
them.  He stated that in response to this “environment” she “went into a shell.”  The 
CWO stated that he sometimes felt frustrated with her because she and her staff seemed 
unresponsive.  He stated that her staff would go over her head to the XO, who would 
then “call[] [her] on the carpet.”  The CWO stated that he believes that after he left the 
XXX, in August 19xx, the outgoing CO and XO briefed the new CO and XO about the 
applicant’s “situation and thereby prejudiced her getting a fair chance to prove herself.”   
 
 
The applicant also submitted a copy of an email message she received from the 
new  XO  on  August  12,  19xx,  in  which  he  stated  that,  before  she  discussed  “the  YN 
situation” with the new CO, he wanted to meet with her to discuss it.  He stated that 
her office was supposed to have three yeomen—a YN1, a YN2, and a YN3—and that 
she  currently  had  a  YN1,  a  YN2,  and  a  seaman  “striking”  for  YN3,  so  he  did  not 
understand her problem.  He stated that she herself had let the previous YN3 leave.  He 
stated, “I want to know how you can adapt and make it work to the best of your ability 
and what compromises you will need to make, not just that it can’t work.”  He further 
stated,  regarding  “performance  perceptions,”  that  the  CO  had  been  briefed  on  past 
problems but had said that she would start with a “clean slate with him” and be judged 
only on “the performance he observes on HIS watch.”  He stated that she could meet 
with  the  new  CO  but  should  present  several  alternative  solutions  to  any  problem, 
instead of just one solution.  He also stated that she should be ready to discuss the “pros 
and cons” of each alternative, but he stressed that she should not argue with the CO. 
 
COMMENT [J]: “Took advantage of position; e.g. refused to submit to direct-subor-
dinate  HS1’s  repeated  request  for  mandatory  weigh-in  prior  to  TAD;  XO  led  to 
believe weigh-in accomplished.” 
 
 
 
The applicant denied this comment.  She alleged that she was weighed prior to 
going on TAD and met the Coast Guard’s weight standards.  She submitted a copy of 
an email message in which the HS1 stated that the applicant was weighed but that the 
HS1 “was never able to get the percent body fat so it was not adequate for the official 
weight check.”  The applicant pointed out that COMDTINST M1020.8C provides that, if 
a  member  fails  the  weight  standard  but  meets  the  percentage  body  fat  test,  an  entry 
must be made in their record noting that fact.  She alleged that the absence of such an 

entry in her record supports her claim that she met the weight standard since her “very 
precise” supervisor was also the HS1’s supervisor.  The applicant further alleged that 
she does not “know who misled the XO as [she] never had direct contact with him after 
18 Sept xx 
 
COMMENT [K]: “[W]rongly & surreptitiously had orders for training issued by HQ, 
bypassed normal process including Supervisor, Training Officer & XO; result – kept 
eligible member from attending school. ”4 
 
 
 
The applicant denied this comment.  She stated that in January 19xx, when she 
received  the  TAD  orders  to  XXXXX,  she  learned  that  her  job  would  be  to  write  two 
contingency  plans.    She  then  called  Mr.  X  of  xxxxxxxxxxxxxxxx  to  see  if  he  had  any 
sample plans.  Mr. X offered her a seat in a 12-day Contingency Plans Writing Class that 
was to begin on March 28, 19xx.  He stated that he would send a message to her Group, 
which could either cut the orders for her to attend the class or forward the message to 
XXXXX.  The applicant alleged that she told her supervisor about the class.  When the 
message about the class arrived on February 24, 19xx, her last day at the XXX before 
going on TAD, both her name and that of her supervisor appeared on the class list.  She 
stated that since her supervisor was aware of the message well in advance of the class, 
there was plenty of time for another member from her Group to attend.   
 

The applicant alleged that when she arrived at XXXXX on March 1, 19xx, she was 
told  that  her  orders  to  the  class  had  been  canceled  so  that  someone  with  a  “higher 
operational need” could attend.  However, she alleged, no one else from her Group was 
ever enrolled in the class, the class was never filled, and she was not allowed to attend.  
She alleged that the statement that she kept someone else from attending is false and 
that her Group “set [her] up for failure at XXXXX by preventing [her] from attending 
training  necessary  to  do  [her]  job  and  by  causing  [her] to get off on the ‘wrong foot’ 
with the command at XXXXX.” 
 

In support of her allegations, the applicant submitted a copy of the February 24, 
19xx, message showing that both she and her supervisor were enrolled in the 20-mem-
ber class.  She also submitted a copy of Mr. X’s class list and a letter from Mr. X, who 
stated that after she contacted him, he had suggested she attend the class and included 
her name on his “quota submissions to Commandant.”  Mr. X further stated that, when 
the  XXX  received  the  quota  message,  “they  decided  to  send  [her  supervisor]  to  the 
course  instead  of  [the  applicant].    However,  since  there  were  unused  quotas  for  the 
course, I decided to keep [the applicant’s] name on the list with the hope that XXXXX 
would allow [her] to attend.”  He also stated that the fact that the applicant’s name was 
on the class list “did not prevent another person from attending the training.” 
 

The  applicant  also  submitted  a  copy  of  a  letter  she  wrote  to  her  command  at 
XXXXX dated March 25, 19xx, in which she asked to be allowed to attend the class.  In 
                                                 
4 The shaded phrase was deleted from the OER by the PRRB. 

it, she stated that although the XO of XXXXX, LCDR M, had told her she was bumped 
from  the  class  for  someone  with  “higher  operational  need,”  Mr.  X  had  told  her  that 
there was room for her in the class.  She stated that, when she again asked LCDR M 
about  attending  the  class,  he  said  she  could  not  because  her “housing situation” was 
unresolved.  She resolved it quickly, but then he told her that she could attend the next 
class.  However, when Mr. X told her that the next class would not occur until the fall, 
she asked LCDR M again, and he said that she had “sold” herself to him as being able to 
do the work and that she “should just do the job that [she] came down here to do.”  The 
applicant also stated in the letter that her attendance at the class would not cost XXXXX 
anything, and she could not understand why she was not allowed to attend after she 
had “taken the initiative to get the training.” 
 

The applicant’s letter was forwarded to the Deputy Commander by the Opera-
tions Officer (OO), who stated that he “did not concur with the assertions made” in the 
letter.  He stated that LCDR M recollected the events differently.  The OO stated that, 
when she was first being considered for the TAD assignment, the applicant mentioned 
the class, and he told her he did not care whether she attended as long as he did not 
have  to  pay  for  it.    Soon  after  that  conversation,  someone  from  her  Group  asked  if 
someone from the Group with a compelling, higher priority could be substituted, and 
LCDR M agreed.  The OO stated that he did not see the applicant’s attendance at the 
class as “critical,” but would not object to her attending, although it might be an “inap-
propriate expenditure” of scarce funds. 
 
COMMENT [L]: “Professional skills/position often used to ‘work the system’ to own 
purposes/advantage, adversely impacting subordinates and command good order … 
.” 
 
 
The applicant alleged that this comment by the reporting officer in block 10 of 
the disputed OER refers to her filing civil rights complaints and, as such, is a prohibited 
comment in Article 10.A.4.f. of the Personnel Manual.  She submitted a copy of a rough 
draft for the disputed OER, in which her supervisor originally commented in block 5 of 
the OER that she “[e]xhibits discriminatory tendencies; stirs the pot by creating gender 
& racial issues where none exist.  Uses civil rights issues as scare tactics towards super-
visor.    Invited  outside  agency  civil  rights  investigator  to  question  command  on  CG 
trends.”  She alleged that, although these comments do not appear in the final version 
of the disputed OER, the reporting officer’s negative comment on her ability to “work 
the system” is a direct if veiled reference to her civil rights complaints.  
 
Summary of Applicant’s Allegations and Evidence Concerning the Concurrent OER 
 
 
The applicant asked the Board to alter two comments in the concurrent OER that 
she received for her TAD assignment to XXXXX from March 1 to August 24, 19xx.  The 
concurrent OER contains many positive comments and has 12 marks of 4, 6 marks of 5, 
and a comparison scale mark of 4. 
 

The applicant pointed out that there is only one comment in the concurrent OER 
 
about her work on the hurricane plan, which was her primary assignment.  The com-
ment is that, upon her arrival at XXXXX, the applicant “[i]mmediately began work on 
updating the hurricane plan … .”  She alleged that because of her own command’s bias 
against her, she was not allowed to attend the plan-writing class.  Therefore, instead of 
being assigned to write the plan alone, she was assigned to work on the project with a 
lieutenant,  who  wasted  time  and  effort  writing  the  plan  in  the  wrong  format.    The 
applicant  did  not,  however,  request  any  specific  correction  to  the  concurrent  OER  to 
address the lack of commentary on her work on the plan.  The comments that she wants 
corrected in the concurrent OER appear below.5 
 
COMMENT [1]:  “This officer also seemed to be dedicated to the CG.” 
 
 
The  applicant  alleged  that  this  comment  is  prejudicial  because  it  suggests  that 
she was not actually dedicated to the service.  She alleged that she was very dedicated 
and  that  nothing  in  her  performance  at  XXXXX  would  have  led  anyone  to  believe 
otherwise.  She asked the Board to change the phrase “seemed to be” to “is.” 
 
COMMENT [2]:  “This officer is considered qualified for promotion to CWO4.” 
 
 
The  applicant  alleged  that  her  performance  at  XXXXX  justified  an  unqualified 
recommendation for promotion.  She asked the Board to change the phrase “considered 
qualified” to “recommended.”  She alleged that only the bias against her by her rating 
chain at the XXX could have caused her XXXXX rating chain to use the phrase “con-
sidered qualified” instead of outright recommending her for promotion. 
 

SUMMARIES OF OTHER EVIDENCE SUBMITTED BY THE APPLICANT 

 
Applicant’s Civil Rights Complaint 
 

On July 9, 19xx, before the disputed OER was completed, the applicant filed a 
civil rights complaint against her rating chain at the XXX.6  She alleged that her com-
mand had removed her as Administrative Officer in September 19xx in reprisal for the 
memorandum she wrote her previous CO in June 19xx about a hostile work environ-
ment.  She stated that she was concerned about possible reprisal in her next OER and 
that “[w]hat I mean by that is that I expect that my OER be the same or better than the 
two previous OERs[;] any thing less I would consider to be still another form of repri-
sal.”  
                                                 
5  One comment in the concurrent OER has already been deleted by the PRRB: “However, external issues 
seem to have impacted on fullest utilization & most effective performance.”  The PRRB reasoned that it 
should be removed because it “encompasses a matter outside the purview of XXXXX’s OER Rating Chain 
and, while probably objective, it would serve to create an injustice if left undisturbed.” 
6  The  Department’s  Office  of  Civil  Rights  responded  to  the  applicant’s  complaint  by  initiating  an 
investigation.    However,  in  2001,  it  notified  the  applicant  that  it  would  not  issue  a  decision  on  her 
complaint because she had chosen to submit an application to the BCMR on the same matter. 

 
In the complaint, the applicant alleged that before leaving the XXX in February 
19xx, she asked her supervisor about her OER.  He told her that her only hope for a 
good one was to get a separate (concurrent) OER from the XXXXX command or to get 
good input from that command for her OER from the XXX command.  He told her that 
the XXX command would not give her a good OER.  She alleged that this was unfair 
because, after she was removed from her position as the Administrative Officer, she had 
asked what she needed to do to get a good OER, and she had done “exactly what he 
asked  of  me.”    She  alleged  that  the  disputed  OER  must  therefore  be  a  result  of  the 
memorandum she wrote to the previous CO in June 19xx. 

 
The applicant alleged that, after she submitted her memorandum about the hos-
tile work environment, her previous CO told her she needed psychological counseling 
because  she  was “hypersensitive” to racial issues and told the incoming CO about it.  
Therefore, she did not have a “fresh start” with her new rating chain.  She alleged that 
on September 17, 19xx, YN1 X began crying after he was heard using foul language, but 
he  blamed  her  and  she  was  immediately  relieved  of  duty  as  Administrative  Officer 
without being allowed to state her case.  She stated that, if her command had checked 
his  record,  it  would  have found that YN1 X had a “long history of not getting along 
with his supervisors.” 

 
The applicant alleged that the XO and CO of the XXX had separate standards for 
men and women.  She was “given one strike” and was relieved of her duties without 
being given a chance to present her side.  She also alleged that she was not given any 
recognition  for  her  efforts  and  that  she  had witnessed “extremely hard treatment” of 
herself and four of the other eight women at the XXX. 
 
Statement of the CO at the XXX Regarding the Civil Rights Complaint 
 
 
On  December  17,  19xx,  the  CO  of  the  XXX  sent  a  letter  to  the  District  Com-
mander  regarding  the  applicant’s  complaint.    He  pointed  out  that  the  complaint was 
not filed within 45 days of the day she was relieved of duty as the Administrative Offi-
cer and that it was filed before the disputed OER existed. 
 
The CO stated that after the applicant was relieved of duty, she consulted with 
 
the Commandant’s Gender Polity Advisor, who found no basis for gender discrimina-
tion.  He stated that even after the applicant learned of a new process for filing a com-
plaint on May 6, 19xx, she waited 63 days to file the complaint.  He stated that, although 
the applicant’s complaint mentions the treatment of other women, no other women at 
the XXX had filed complaints, and neither the XO nor the CO had heard of any harsh 
treatment of women. 
 
Affidavit of the Applicant’s Supervisor at the XXX to the Investigator 
 

The  investigator  assigned  to  the  applicant’s  case  interviewed  her  rating  chain, 
 
and on October 5, 2000, received a signed statement from her supervisor.  The supervi-
sor stated that in September 19xx, the XO asked him to “try and clean up” the Adminis-
trative Department and appointed him to serve as the Administrative Officer in place of 
the applicant.  He stated that he kept the applicant as the supervisor for the yeomen in 
the personnel office.  He stated that at some point, she told him that she had filed a civil 
rights complaint against a previous supervisor and had an application pending at the 
BCMR.  He denied that any part of the disputed OER was based on her race, sex, or 
civil rights complaints. 
 
The investigator questioned the supervisor about the comments he wrote in the 
 
rough draft for the disputed OER about the applicant showing “discriminatory tenden-
cies,” “creating gender & racial issues where none exist,” using “civil rights issues as [a] 
scare tactic” against him, and inviting an “outside agency civil rights investigator” to 
question the command.  The investigator also asked him about the bases for comment 
[L] in the disputed OER, the mark of 2 on the comparison scale, and the lack of a rec-
ommendation for promotion.  In response, the supervisor alleged that the applicant had 
once unwisely delayed counseling for an African-American alcohol abuser because she 
thought he should have an African-American counselor and one was not available.  He 
alleged that the applicant had told someone that he himself had said that he did not like 
having women work for him.  He alleged that she brought a civil rights investigator to 
the  command  when  she  knew  he  was  preparing  the  disputed  OER.    In  addition,  the 
supervisor alleged that she caused XXXXX “a lot of difficulty” by taking her foster child 
and daycare provider with her, who both required housing.  He stated that he “had no 
trust”  in  the  applicant.    He  had  asked  for  results  in  a  compliance  inspection  and 
received nothing.  She came to work late or not at all and often in civilian attire. 
 
The supervisor told the investigator that his own name was already on the list to 
 
attend  the  plan-writing  class when the applicant made a request to attend it through 
Headquarters rather than through her chain of command at the XXX.  Later, the com-
mand was surprised to see that she was assigned to the class and to learn that XXXXX 
thought that the XXX had approved the training and would pay for the class.  When he 
saw the orders for the class with both his own and the applicant’s names, he inquired 
about  what  office  was  paying  for  her  attendance.    He  stated  that  the  XXX  was  not 
interested in paying for the training because it would not benefit the XXX.  In addition, 
he stated that attending the class was important for his own work at the XXX.  More-
over, he stated, attending the class would have required her to go on TAD to xxxxxx 
from her TAD at XXXXX, costing the XXX quite a bit for her airfare.  He also claimed 
that a member “can’t go TAD from TAD.”  The supervisor gave the investigator a copy 
of the official message dated March 2, 19xx, by which the applicant’s orders to attend 
the class were cancelled.  The message was sent to both Headquarters and XXXXX and 
it  states,  “request  can[cellation]  of  quota  for  [the  applicant]  for  29  March  class  and 
reassign as necessary.” 
 

The investigator asked the supervisor why the applicant had received good eval-
 
uations from her previous rating chain at the XXX.  The supervisor stated that the appli-
cant’s former supervisor was a “very nice guy” who might have avoided “rocking the 
boat.”  He also stated that her previous supervisors might have been afraid to hold her 
accountable for her performance. 
 

The investigator asked if the supervisor had requested input from the applicant 
for the disputed OER.  He stated that he had asked her for it before she left the XXX on 
TAD  and  she  had  stated  that  she  would  send  it  to  him  from  XXXXX.    However,  he 
never received any input from her. 
 

Affidavit of the XO of the XXX to the Investigator 
 
 
The investigator interviewed the XO of the XXX, who served as the applicant’s 
reporting  officer  for  the  disputed  OER.    The  XO  stated  that  he  did  not  sign  the  final 
draft of the disputed OER until November 19xx because he had asked the supervisor to 
correct some errors and because he was overseas on extended leave in August and Sep-
tember 19xx.  He stated that he did not believe that the disputed OER was affected by 
the applicant’s race, gender, or former civil rights complaints. 
 
 
The investigator asked the XO about the bases for comment [L] in the disputed 
OER,  the  mark  of  2  on  the  comparison  scale,  and  the  lack  of  a  recommendation  for 
promotion.  In response, the XO stated that the applicant “was a disaster in terms of 
leadership at this unit.”  He received many complaints about her and, at about the time 
he himself decided that “something needed to be done,” the chief petty officers held a 
meeting about her, after which the Command Enlisted Advisor came to him and “said 
something needed to be done.”  The XO stated that the head yeoman under the appli-
cant’s supervision, YN1 X, had been found crying in the hall because “he just couldn’t 
take it any more.” 
 
 
The XO further stated that because the applicant was so familiar with the person-
nel system, she was “very dangerous.”  He cited as an example the fact that, even after 
she had failed of selection for promotion twice and was slated for retirement, she got 
herself assigned to attend a class without her supervisor’s knowledge.  He stated that 
after members are slated for retirement, they are no longer eligible for such training and 
that the applicant knew this policy.  The XO also stated that, when going on TAD over-
seas, members are not allowed to take their dependents.  However, the applicant “had 
worked  the  system  and  gotten  someone  to  sign  off  on  taking  her  dependents  down 
there.  That caused a lot of headaches for me:  administratively coordinating with the 
other unit, finding out how that had happened and determining who was going to pay 
for  it.”    He  also  stated  that  he  had  once  discovered  she  was  married  when  she  had 
“made  representations  that  she  wasn’t  married,”  and  that  in  looking  at  the  “central 
computer data on her dependents … things didn’t add up.  It appeared to me that she 
was drawing additional pay for dependents … .”  The XO also stated that he believed 
that  the  applicant  delayed  her  separation  by  filing  civil  rights  complaints  so  that  she 
would be able to retire with 20 years of service. 
 

The investigator asked the XO why the applicant had received good evaluations 
from her previous rating chain at the XXX.  The XO stated that, when he first arrived at 
the XXX, he saw the applicant in her previous CO’s office “crying and carrying on and 
acting in a way that is totally inappropriate in front of a captain.”  The XO alleged that 
she was “negotiating” with the CO to have her previous OER upgraded. 

 
The XO further told the investigator that the applicant was “hypersensitive when 
it came to race and sex.”  He stated that YN1 Y, one of the two African-American yeo-

men in her office, complained to him that she would not let him and the other African-
American  yeoman  eat  lunch  together  in  an  office  with  the  door  closed  because  she 
thought they might be “conspiring against the white people.”  YN1 Y told him that the 
applicant “looks at everyone in terms of their race and their sex.  He gave me 4-6 exam-
ples for which I don’t recall the details.”  He stated that in one example, YN1 Y told him 
that the applicant had objected when a female petty officer was assigned to one of three 
desks out “on the floor” because the applicant said the woman would feel intimidated, 
but the woman “had no such feelings.” 

The XO also stated that the applicant never submitted input to the OER despite 

 
The  XO  stated  that  the  command  had  supported  the  applicant  when  she  was 
right.    As  an  example,  he  stated  that  when  she  wanted  to  transfer,  he  called  another 
XXX on her behalf but was told that the command “didn’t want her because they had 
fired her from the legal office many years ago.”  He also stated that, once when a bank 
canceled the applicant’s government credit card because the balance was too high, the 
XO directed the XXX’s finance and supply warrant officer to work on the matter for her 
and get the card working again. 
 
 
her supervisor’s request and never appealed the disputed OER. 
 
Affidavit of the Applicant’s CO at the XXX to the Investigator 
 
 
The CO, who served as the reviewer for the disputed OER told the investigator 
that because the evaluation period ended on July 31, 19xx, the OER should have been 
completed and submitted to Headquarters by September 15, 19xx.  However, the appli-
cant  would  not  provide  them  with  any  input  as  required  by  regulation  to help them 
write the OER.  He denied that the applicant’s race, gender, or civil rights complaints 
had  any  effect  on  the  disputed  OER  and  stated  that  he  encouraged  people  who  had 
complaints to “pursue their rights.” 
 
 
Regarding  the  negative  recommendation  for  promotion  in  the  OER,  the  CO 
stated that he had discussed it with the XO.  He stated that it resulted from the appli-
cant’s failure to comply with policies.  An audit of the CDAR and Mutual Assistance 
programs she headed had found “many inconsistencies” and failures to follow guide-
lines.  He stated that she made unilateral decisions for personnel and failed to inform 
the XO or CO about them.  He also stated that her subordinates complained about her 
leadership. 
 
 
When  asked  about  comment  [L],  the  CO  stated  that  the  XO  told  him  that  the 
applicant  had  become  involved  with  “various  inquiries  and  procedures”  without  the 
command’s  knowledge  when  she  should  have  been  working  through  the  chain  of 
command. 
 

The investigator also asked the CO why the applicant had received good evalua-
 
tions from her previous rating chain at the XXX.  The CO stated that he had discussed 
the applicant’s performance with the previous CO upon his arrival and had received a 
copy of her prior OER.  He stated that when he found that her performance “did not 
jive” with the prior OER, he called the previous CO, who told him that he had raised 
several of the marks on her last OER when she took exception to them in an “emotional 
and tearful” meeting.  He stated that he had “given her the benefit of the doubt” and 
raised the marks “against his better judgment.”  He apologized for leaving the new CO 
with a difficult situation. 
 
The CO further stated that neither he nor the XO had observed the applicant’s 
 
performance  on  a  daily  basis  but  that  the  applicant  had  never  complained  to  them 
about discrimination by her supervisor.  
 

The applicant alleged that her supervisor’s explanations to the investigator about 
his comments in the rough draft for the disputed OER were erroneous.  She alleged that 
an email in the investigator’s report from a lieutenant at XXXXX to her supervisor at the 
XXX shows that they were familiar with each other and that the command at XXXXX 
became prejudiced against her because of the bias at the XXX.  In that email, dated May 
28,  19xx,  the  lieutenant  at  XXXXX  told  her  XXX  supervisor—who  had  sent  him  a 
message  concerning  administrative  steps  the  applicant  needed  to  take  because  of  her 
upcoming retirement—that “[s]he has checked out cause she knows that she will not get 
what she needs on an OER, so now she does bills and reads the paper.” 

 
The applicant alleged that the XO’s affidavit is also full of errors and false infor-
mation.    She  stated  that,  contrary  to  the  rules,  he  used  examples  of  her  performance 

SUMMARY OF THE APPLICANT’S RESPONSE TO THE AFFIDAVITS 

 
 
In response to the affidavits by her rating chain to the investigator, the applicant 
alleged that their justifications for the disputed comments in the OER were erroneous.  
She  stated  that  her  supervisor’s  comment  in  block  3  of  the  disputed  OER  about  her 
support for the MLC compliance audit proves that his statement that he received “no 
results” from her on the project is false and cannot justify comment [L].  She alleged that 
his statements that her orders to attend the plan-writing class were canceled because he 
did not know who would pay for it and “you can’t go TAD from TAD” are both false.  
The copy of the orders for the class include a second page of accounting information, 
from which she alleged he should have known that her attendance would be paid for by 
Headquarters.    In  addition,  she  pointed  out  that  nothing  in  the  Joint  Federal  Travel 
Regulations or Coast Guard policy prevents a member from going on TAD from TAD.  
She  alleged  that,  because  the  command  at  XXXXX  thought  that  her  orders  were  can-
celed so that someone with a higher operational need could attend, it is clear that her 
supervisor has contradicted himself and must have canceled her orders because of his 
bias against her.   
 

outside the evaluation period to explain the disputed OER comments to the investiga-
tor, such as the complaint about her objections to the African-American yeomen lunch-
ing with the door closed; her prior work at a legal office; and the issue of her marriage 
and dependents, which she alleged arose in October 19xx, after the end of the period.  
Furthermore, she alleged that YN1 X was the only yeoman who ever complained about 
her  during  the  reporting  period  and  he  was  one  of  the  people  she  had  cited  in  her 
memorandum to the previous CO for using threatening language to a white subordi-
nate.    She  also  alleged  that  there  is  no  rule  against  someone  about  to  retire  taking  a 
class, and in any case she did not receive her mandatory retirement letter until after she 
enrolled in the class.  She also stated that there is no rule against taking one’s depend-
ents on TAD “as long as you pay their way out of your own pocket,” which she did.  
She  pointed  out  that  since  anyone  with  more  than  18  years  of  service  who  is  passed 
over for promotion is allowed to retire after 20 years, the XO’s argument about her fil-
ing civil rights complaints and BCMR applications to attain a retirement is clearly false.  
 
 
The applicant also alleged that the CO’s affidavit is full of errors and false infor-
mation.  She alleged that she did not violate any Coast Guard or unit policies and that 
her command may have thought she did only because they did not know the policies.  
She stated that an MLC compliance inspection report dated September 19xx shows that 
no discrepancies occurred in the Mutual Assistance program prior to her going on TAD 
and that many discrepancies occurred in the Administrative Department after she was 
relieved of duty as the Administrative Officer.  She alleged that her previous CO did 
not raise her marks in her prior OER as a result of their meeting.  Finally, the applicant 
argued that she did file a reply to the disputed OER (though none appears in her record 
and she did not submit a copy of one). 
 

DECISION OF THE PERSONNEL RECORDS REVIEW BOARD 

 
 
On January 30, 2001, the Personnel Records Review Board (PRRB) issued a deci-
sion  in  this  case.    In  addition  to  the  evidence  submitted  by  the  applicant,  the  PRRB 
sought  and  received  statements  from  the  applicant’s  supervisor  and  reporting  officer 
(the XO) at the XXX, which are summarized below. 
 
Declaration of the Applicant’s Supervisor at the XXX 
 
 
The  supervisor  stated  that  he  was  the  XXX’s  training  officer  and  the  applicant 
never gave him a training request form for the plan-writing class.  He stated that when 
she  initially  applied  for  the  TAD  assignment,  Headquarters  had  stated  that  she  was 
already  qualified  for  the  work  and  did  not  need  further  training.    When  he  saw  her 
name  on  the  orders  for  the  class,  he  called  XXXXX  and  was  told  that  that  command 
thought that the XXX was funding her attendance at the class.  Therefore, he had her 
name  removed  from  the  class  list.    He  indicated  that  no  one  from  the  XXX  was  pre-
vented from attending the class because of her actions, contrary to one comment in the 

disputed OER, although by removing her name from the class roster, her seat was made 
available to members of other units.  
 
 
The supervisor alleged that, before the applicant went on TAD, he had to sign a 
paper verifying that she met the Coast Guard’s weight standards.  When he asked the 
unit’s HS1 about it, he was told that the applicant had refused to be weighed.  He stated 
that later the XO ordered the applicant to weigh in and she did and passed the test, so 
no entry was made in her record. 
 
 
The supervisor alleged that after an African-American member had an alcohol-
related car accident, the applicant delayed treatment and, when asked for an explana-
tion, stated that the member “should be counseled by an African American counselor” 
because “only one from that member’s background would fully understand the issues 
accurately.”  No African-American counselor was available at the time. 
 
 
The supervisor alleged that well in advance of an annual all-hands weekend for 
the reservists, the applicant was asked to provide a CDAR presentation.  She asked to 
be exempt, but although her request was denied, she arrived late in civilian attire and 
did  not  participate  in  the  presentation.    He  also  alleged  that  he  received  many  com-
plaints  about  her  lack  of  support  from  reservists,  including  the  reserve  Command 
Enlisted Advisor, but he received compliments from the reservists about YN1 X. 
 
 
Finally,  regarding  the  applicant’s  allegations  with  respect  to  comment  [F],  the 
supervisor stated that the HS1 in question was not ready for promotion.  He stated that 
after he counseled the HS1, she agreed with his decision and signed the evaluation, but 
the applicant advised her to appeal.  The HS1 told him that she did not want to appeal, 
and she ultimately decided not to appeal. 
 
Declaration of the XO at the XXX 
 
 
The  XO,  who  served  as  the  reporting  officer  for  the  OER,  stated  that  the 
applicant  attempted  to  negotiate  the  contents  of  the  disputed  OER  after  it  was 
submitted, which is not permitted, and she did not file an OER reply.  He stated that the 
OER  was  submitted  late  because  she  did  not  respond  to  numerous  requests  for  OER 
input.  He stated that he believed she wrote the civil rights complaint on July 9, 19xx, 
before the disputed OER was even written “to lay the groundwork for having the OER 
ultimately set aside” because she knew that it would reflect the fact that she had been 
removed from her position as Administrative Officer. 
 
 
The  XO  alleged  that  the  applicant’s  command  at  the  XXX  would  not  have 
approved her request for training since she was expected to retire on November 1, 19xx.  
When the orders arrived, they investigated how she got them without the knowledge of 
her supervisor, who was the XXX’s training officer, or himself.  He stated that whether 

there was a seat for her in the class was not relevant to how she went about procuring 
it. 
 
 
The XO stated that he could not remember the specifics of the weigh-in issue, but 
he did remember there was some concern about whether she would present herself to 
be weighed in time. 
 
The XO denied that he had a “closed door policy” but stated that he does “not 
 
believe  it  is  prudent  for  any  male  supervisor  to  be  behind  closed  doors  alone  with  a 
female subordinate, especially under the trying circumstances in this case and I always 
made  sure  that  [the  applicant’s]  supervisor  was  present.    [She]  never  brought  to  my 
attention that it was necessary for her to discuss confidential CDAR matters alone with 
me.”    He  alleged  that  he  did  discover  that  she  was  not  keeping  him  informed  about 
CDAR matters and was making decisions that “were not hers to make.”  He alleged that 
her delaying a member’s counseling to wait for a “racially compatible counselor” was 
an example of her “hypersensitivity to race.” 
 
The  XO  alleged  that  because  of  the  applicant’s  poor  leadership,  the  Supply 
 
Branch was separated from the Administrative Department “to minimize the number of 
personnel  under  her  supervision.    The  conflict  was  not  that  one  CWO  worked  for 
another.  The problem was that no one could work for [her].”  He stated that at one time 
or another, almost all of her subordinates complained to him about her, as did a reserv-
ist, and that members of the Planning Department reported witnessing unprofessional 
behavior  on  her  part  and  interactions  “indicative  of  a  total  lack  of  leadership.”    He 
stated that, to his knowledge, her department was properly staffed. 
 
Findings and Conclusions of the PRRB 
 
 
Regarding comment [K] in the disputed OER, the PRRB found that the applicant 
had proved that her enrollment in the plan-writing class did not keep anyone else from 
attending the course.  Therefore, the PRRB recommended that the phrase be removed.  
However, it found that the statements of her rating chain support the remainder of the 
comment.  The PRRB stated that, while there is no regulation prohibiting retiring mem-
bers from attending classes, “it is the Command’s prerogative to decide whether or not 
training is critical and necessary for their members” and that the record indicates her 
command had previously concluded that no special training was necessary. 
 
 
Regarding  comments  [D1]  and  [D2],  the  PRRB  found  that  the  applicant  had 
blamed  her  difficulties  acting  as  CDAR  on  not  being  able  to  communicate  privately 
with the XO, but the XO stated that the applicant never told him she needed to speak to 
him privately about a CDAR matter.  It found that both the supervisor and reporting 
officer had fully supported the comments and that other causes of delay cited by the 
applicant did not excuse her failure to consult with the command before making impor-
tant decisions about members’ treatment. 

 
 
Regarding  comment  [H],  the  PRRB  found  that  the  reporting  officer  had  sup-
ported this comment in his declaration.  The PRRB also found that comments [A1] and 
[A2] were supported in the declarations.  It pointed out that, while the applicant alleged 
that she received only one counseling session from her command during the evaluation 
period,  Article  10.A.2.c.  of  the  Personnel  Manual  states  that  the  reported-on  officer 
should “seek performance feedback from the Supervisor during the period.” 
  
 
Regarding the concurrent OER, the PRRB found that, while one comment should 
be  removed  because  it  referred  to  matters  at  the  XXX  rather  than  at  XXXXX,7  the 
applicant had presented no “clear and convincing evidence” to show that comments [1] 
and [2] were erroneous or that they resulted from bias. 
 
 
The PRRB also held that the applicant’s failure to submit replies to the OERs was 
a “tacit indication” that she accepted their characterization of her performance.  It con-
cluded that aside from the removal of one phrase from the disputed OER and another 
from the concurrent OER, no further corrections should be made to her record because 
she  did  not  present  “clear  and  convincing  evidence”  that  the  other  comments  in  the 
OERs were in error or that she was evaluated unfairly.  
 

APPLICANT’S RESPONSE TO THE DECISION OF THE PRRB 

 
 
On April 4, 2001, the applicant sent the BCMR a response to the decision of the 
PRRB.  The applicant stated that her supervisor’s statement about her failing to make a 
CDAR presentation to the reserves is an “outright lie.”  She stated that the CDAR pres-
entation is the only one she ever made to a reserve all-hands meeting, and she submit-
ted  a  copy  of  an  email  message  from  the  reserve  command  master  chief,  who—in 
response to an email asking if she remembered the applicant giving CDAR training at a 
reserve all-hands meeting in November 19xx—replied simply “Yes, I do remember you 
giving training.” 
 
 
The applicant alleged that the XO lied when he said he had to remove personnel 
from her space because of her poor leadership.  In support of her allegation, she submit-
ted a copy of an email message from a chief warrant officer, who stated that he thought 
the Supply Department was moved because the Planning Department was growing and 
needed more space. 
 
 
The  applicant  argued  that  the  rating  chain’s  statements  about  her  weigh-in  do 
not actually support comment [J] in the OER, and she alleged that the HS1’s statement 
that she submitted proves that comment [J] is false. 
 
 
The applicant alleged that the PRRB ignored the fact that her supervisor “lied to 
the command at XXXXX by saying that they were canceling my seat because of a higher 
                                                 
7 See footnote 5. 

operational need,” and lied to the civil rights investigator by saying that she could not 
“go  TAD  from  TAD”  and  could  not  attend  class  because  she  was  retiring.    She  also 
stated that the PRRB ignored the supervisor’s lie about not knowing who was paying 
for  the  class,  when  the  information  was  contained  in  the  orders,  which  he  saw.    The 
applicant alleged that “the one person who could make the determination if I could use 
this  training”  was  Mr.  X,  who  clearly  thought  she  should  attend  the  class.    She  sub-
mitted a letter from him in which he stated that she would have benefited from taking 
the  course  and  that  her  pending  retirement  would  not  have  mattered.    She  further 
alleged that her supervisor set her up by not asking her for a training request form. 
 
Regarding  the  PRRB’s  discussion  of  comments  [D1]  and  [D2],  the  applicant 
 
alleged that it wrongly blamed her for not focusing on the delay of the African-Ameri-
can member’s counseling.  She alleged that her supervisor lied about this because the 
member “had not yet been diagnosed and there was no determination that he needed 
treatment.”    She  alleged  that  the  diagnosis  had  not  yet  occurred  because  the  Navy 
required  members  to  have  disciplinary  proceedings  resolved  before  entering  a  treat-
ment center for screening, and the member in question had to go to NJP.  In support of 
her allegations, she submitted another email from the Addictions Prevention Specialist, 
who stated that he could not remember her ever delaying treatment for a member and 
could not recall that she ever asked for a specific counselor for a member based on his 
race. 
 
 
The applicant argued that the PRRB ignored the fact that, when questioned by 
the  civil  rights  investigator,  the  XO  justified  comment  [L]  by  citing  incidents  that 
occurred outside the reporting period and by misrepresenting Coast Guard regulations.   
 
 
The applicant pointed out that other than the disputed OER, there were no nega-
tive entries in her record documenting her allegedly “atrocious performance and poor 
leadership.”  She alleged that if she had actually disobeyed an order to be weighed or to 
conduct training for the reserves, her supervisor would have noted it in her record or 
reported her for insubordination. 
 

VIEWS OF THE COAST GUARD 

 
On February 27, 2002, the Chief Counsel of the Coast Guard recommended that 
 
the Board deny the applicant’s request for lack of merit.  The Chief Counsel stated that 
in making his recommendation, he adopted the analyses, findings, and conclusions of 
the  PRRB  and  would  not  duplicate  them  in  his  advisory  opinion  but  would  address 
some other issues.  Prior to issuing the advisory opinion, the Chief Counsel sought and 
received new declarations from the applicant’s supervisor and XO at the XXX, as well as 
declarations from the applicant’s previous XO and CO at the XXX, YN1 X, a CWO who 
headed  the  Supply  Branch  at  the  XXX,  and  the  command  master  chief  at  the  XXX.  
These declarations are summarized below. 
 

Second Declaration of the Applicant’s Supervisor at the XXX 
 
 
The supervisor stated that the Chief Counsel had sent him a copy of the applica-
tion  and  that  none  of  the  evidence  in  it  changes  his  evaluation  of  her  performance, 
which was “both fair and objective.”  He stated that, in addition to the comments he 
made to the investigator of her civil rights complaint, he would add the following spe-
cific comments about her performance to explain disputed comments in the OER. 
 
 
Regarding YN1 X, the supervisor alleged that contrary to the applicant’s state-
ment, the petty officer’s performance was “outstanding,” and he received an Achieve-
ment Medal prior to leaving the unit.  Regarding the training for reserves, he alleged 
that the applicant resisted providing it and “arranged tasks for all yeomen so that she 
wouldn’t have to come in,” so he had to order her to provide the training.  Regarding 
the delay of treatment for an alcohol abuser, the supervisor stated that, when she told 
him she had not yet scheduled screening for a member because she wanted to wait until 
an  African-American  counselor  was  available,  he  reasonably  concluded  that  such  a 
delay was not in accordance with policy. 
 
 
Regarding the applicant’s allegation that the supervisor humiliated her in front 
of her subordinates, he stated that when she consistently came to work an hour late and 
would not get into uniform for several hours, he would call her into his office to ask 
why.  He stated that he did not close the door because he was afraid she would make a 
false allegation of harassment.  He stated that she may have felt humiliated, but he had 
to hold her accountable for her actions. 
 
 
The  supervisor  stated  that,  prior  to going on TAD, the applicant was assigned 
and expected to update and transfer the unit instructions from the SWII computer sys-
tem to the SWIII system, but she did not even come close to completing the work.  He 
stated that he himself counseled her to go on TAD to another unit so that she could get 
a better OER and improve her chance of promotion.  He alleged that he was not “out to 
get her.”  However, he alleged, she never told him that she had enrolled in the plan-
writing class through Headquarters before he received the orders.  He alleged that the 
applicant was qualified to write the plans without attending the class.  When he saw her 
name on the orders, he called XXXXX to see if XXXXX had approved her attendance at 
the  class,  and  the  response  was  “no.”    Then  he  called  the  program  manager  for  the 
course,  who  stated  that  the  applicant’s  supervisor  and  command  had  approved  her 
attendance, but he knew this not to be true.  Regarding funding for the class, he stated 
that while Headquarters would pay for the class itself, “it is well known that the unit 
incurs  the  expense  per-diem  and  travel.”    He  alleged  that  he  never  claimed  any par-
ticular  person  with  a  higher  operational  need  was  denied  enrollment  because  of  the 
applicant,  only  that  her  actions  would  keep  “any”  member  with  a  such  a  need  from 
enrolling.    He  stated  that  after  the  applicant  went  to  XXXXX,  a  lieutenant  from  that 
command whom he had known at a previous station contacted him and complained all 
she did was read the newspaper.  

 
 
Regarding  the  applicant’s  lack  of  input  in  the  disputed  OER,  the  supervisor 
alleged that she had “every opportunity” to provide input but would not answer his 
calls to her.  He alleged that he asked her supervisor at XXXXX to tell her to send him 
input but still received nothing. 
 
Second Declaration of the XO at the XXX 
 
 
The  XO,  who  is  now  retired,  stated  that  after  arriving  at  the  XXX  in  19xx,  he 
became  aware  of  the  odd  behavior  and  lack  of  leadership  of  the  applicant  “through 
direct  observation  as  well  as  being  informed  by  my  branch  chiefs  of  problems  my 
personnel  had  encountered.”    In  the  spring  of  19xx  when  he  learned  that  he  would 
become the XXX’s next XO, he spoke with the then current XO and CO, who “[b]oth 
assured [him] that they would handle and resolve the problem before [he] assumed the 
XO  position.”    Before  he  became  XO,  two  African-American  yeomen  told  him  that  it 
was hard to work for the applicant because she was hypersensitive about race and gen-
der and “looked at them as black petty officers instead of petty officers.”  They told him 
that she did not allow them to eat lunch together behind a closed door.   
 

The XO stated that after he became the XO on July 2, 19xx, he saw the memoran-
dum she had written, but he believed that the previous CO and XO had addressed the 
allegations.  He stated that he met with her and told her what his expectations were for 
her  performance.    However,  the  applicant  did  not  follow  his  instructions.    She  for-
warded correspondence for him to sign that was counter to policy.  She recommended 
that he approve mutual assistance requests that did not meet the guidelines and did not 
provide him with a copy of the guidelines even after he asked for them.  He stated that 
she  refused  to  learn  the  mutual  assistance  check-writing  system  and  so  checks  were 
often delayed because the assistance clerk who knew the system was frequently out of 
the  office  conducting  marine  inspections.  He  also  alleged  that  she  went  to  another 
command and “worked the system to get a very large mutual assistance loan,” which 
created an administrative nightmare for others.  In addition, the XO alleged that she set 
her own hours, which was contrary to command policy, and retained her original medi-
cal record despite command directives that it be filed in the medical department.  She 
was able to do this because she supervised the HS1 who ran the medical department.  
The XO stated that as a result of “a number of interactions and incidents, I began to lose 
confidence in her integrity.” 

 
The XO stated that after observing her performance, he discussed with the CO 
possible solutions “on numerous occasions prior to relieving her as department head.” 
After an “emergency meeting of the Chief’s Mess,” the command master chief came to 
him and told him that the applicant “did not have the respect of her subordinates, was 
causing  them  great  apprehension,  and  was  adversely  affecting  the  entire  command.”  
The XO stated that this was not news to him.  When the master chief reported finding 
YN1 X in tears because he “could no longer stand to come to work,” the XO decided to 

relieve the applicant of her position even though shifting another officer into the posi-
tion to be her supervisor would leave another important command position vacant. 

 
 
The XO concluded that the disputed OER was “fact-based and objective” and not 
in retaliation for the applicant’s civil rights complaint.  He alleged that in prior OERs, 
she “kept getting a free pass from her prior supervisors because, as I have now discov-
ered, it took too much time to deal with her.” 
 
Declaration of the Previous CO at the XXX 
 
 
The captain who served as the CO of the XXX until July 19xx and who signed her 
previous OERs from that unit as the reporting officer is now retired.  He stated that he 
believed the applicant was “a very capable officer” but “had the potential to do better 
and I generally gave her the benefit of the doubt in her evaluations.”  He alleged that 
she was “never happy with her OERs” and “often argued for higher numbers, although 
I thought the supervisor and I were generally quite generous.”  He believed that she 
had  several  personal  problems  and  that  those  might  have  negatively  affected  her  job 
performance and work relationships, causing “turmoil” in her department. 
 
 
The captain stated that when he became CO of the XXX, a junior officer was the 
Administrative Officer, supervising two CWOs who headed the storekeepers and yeo-
men.  However, he wanted to use the junior officer elsewhere, so he made one of the 
CWOs (the applicant) the Administrative Officer, supervising the other CWO.  Unfor-
tunately, he alleged, the applicant “interjected herself” into some situations among the 
storekeepers in a “less than helpful” way that caused a “downturn in attitude.”  There-
fore, he decided to divide the department.   
 
Regarding the applicant’s memorandum about a hostile work environment, the 
 
captain stated that in response he first asked her why she had reported the matter to 
him in such a formal manner since he “had always encouraged the staff to come for-
ward, directly to me if appropriate, to report any discriminating behavior.”  Then he 
personally  investigated  her  allegations  and  spoke  with  the  alleged  victims  but  found 
that the alleged threats of violence were either not serious or were made in jest.  The 
captain stated that he left a copy of the memorandum for the new CO and told him how 
he had addressed the allegations but avoided making any remarks about the applicant’s 
motives for writing it.  He also told the new CO that the Administrative Department 
was requiring too much of his attention and so “some reorganization was appropriate.” 
 
 
The captain stated that sometime after he left the XXX, the new CO called him 
about the applicant’s performance and her prior, positive OERs.  He told the CO that 
the applicant was “a capable officer with greater potential and, right or wrong, I tended 
to give her the benefit of the doubt.”  
 

Declaration of the Previous XO at the XXX 
 
 
The commander who served as the XO of the XXX until July 1, 19xx, stated that 
he remembers seeing the memorandum and briefing the incoming XO about it, but he 
was not involved in the investigation.  He alleged that, while he was at the XXX, the 
applicant’s performance was “severely” affected by personal problems, and she came 
late to work because of “family situations.”  He believed she had a “fragile personality” 
and sometimes thought she “was going to have a mental breakdown.” However, he and 
the  CO  spoke  about her almost daily and both of them “felt that we would do more 
harm than good by holding [the applicant] strictly accountable for her performance.”  
He chose not to deal with the problem because she had been passed over for promotion 
many times and would be required to retire soon.  He stated that the “department per-
formed well while she was the department head but it was not because of her leader-
ship  but  in  spite  of  it.”    The  commander  stated  that  he  told  the  new  XO  about  “the 
problem  he  was  inheriting”  and  was  not  surprised  when  he  heard  that  the  applicant 
had later been relieved as Administrative Officer. 
 

Declaration of YN1 X at the XXX 
 
 
YN1 X stated that the applicant became his direct supervisor in early 19xx, when 
YN1 Y was “loaned” to the Housing Branch.  At that point, YN1 X became the supervi-
sor for the YN2 in the office.  YN1 X alleged that, contrary to the applicant’s June 19xx 
memorandum, he never threatened YN2 with violence, although he frequently had to 
remind a YN2 not to “jump the chain of command” and to keep YN1 X informed of his 
whereabouts during working hours.  He recalled that on one occasion, his direction to 
YN2 “became heated” but he alleged that he never threatened the YN2 with violence or 
discriminated against him and that they had a good relationship.  He further alleged 
that the applicant told YN1 Y and him that they should eat lunch with YN2 so that he 
would not feel discriminated against.  He alleged that her comments caused tension in 
the office. 

 
YN1 X also alleged that the reserve personnel felt alienated because they were 
not getting paid timely, not receiving orders on time, and not being informed of policy 
changes.  He had to cope with them because they “did not want to deal with [the appli-
cant] due to her attitude.”  He also alleged that she frequently came to work late, did 
not wear the proper uniform, and kept her office door closed because she was “on the 
phone for hours at a time.”  The previous XO had noticed this and eventually required 
the applicant to check in and out with him. 

 
YN1 X alleged that when the applicant submitted her request to go on TAD to 
XXXXX, her supervisor told her she had to be weighed.  He alleged that the applicant 
“avoided doing this right up till it was time for her to go” because she was overweight 

 
Regarding the applicant’s allegation that YN1 X undercut her authority by com-
plaining  to  the  XO,  he  stated  that  he  resorted  to  complaining  to  the  XO  and  others 
because, whenever he approached her, she “gave me the impression that her personal 
problems far outweighed anything I had to say.”  YN1 X alleged that in mid September 
19xx, the applicant came to the office in a “foul mood” one day and accused him of not 
completing a task that she had not even assigned to him.  When he told her he did not 
know what she was talking about, she told him he was a “’fuck up’ just like everyone 
else in the department” in front of his subordinates.  He left the office, ran into the mas-
ter chief, and told him what was going on.  The next day, the applicant was relieved as 
Administrative Officer.  YN1 X alleged that the applicant was relieved of her position 
because “she had created a hostile and detrimental working environment.”  

 
YN1  X  alleged  that  after  the  new  Administrative  Officer  took  over,  he  held 
meetings  at  which  he  would  assign  tasks  and  deadlines  and  ask  about  results.    He 
alleged  that  the  supervisor  was  very  fair  but  the  applicant  “could  not  produce  any 
results”  and  gave  excuses.    Once  when  the  new  supervisor  “became  upset”  with  her 
excuses,  she  was  embarrassed.    While  at  work, YN1 X alleged, she was either on the 
phone or looking at the newspaper. 

and did not want it to stop her from going on TAD.  When the supervisor asked the 
HS1  about  it,  he  was  told  that  the  applicant  had  her  medical  record  and  had  never 
turned it in.   

 
YN1  X  also  stated  that  contrary  to  the  applicant’s  statement,  he  had  “never 
attended [alcohol treatment] Level III nor was I ever directed not to use alcohol.”  He 
also alleged that other statements she had made about his record were also false. 
 
Declaration of the CWO Who Headed the Supply Branch at the XXX 
 
 
The CWO who headed the Supply Branch under the applicant’s supervision as 
department head until the branch was made a separate department stated that he had 
never been told about the applicant’s June 19xx memorandum and was unaware of any 
threats of violence.  He stated that YN1 X sometimes came to him for guidance about 
leadership since he received very little from the applicant.  Other members of her staff 
also  asked  him  for  guidance.    He  stated  that  he  was  not  told  why  the  applicant  was 
relieved as Administrative Officer and he was told that his branch was moved physi-
cally away from the applicant’s branch because the Planning Department needed more 
space. 
 
 
The  CWO  stated  that  the  applicant  was  “the least effective leader” he encoun-
tered in the Coast Guard.  He alleged that her “complicated” personal life “had com-
plete priority,” causing her to be “away from work physically or mentally most of the 
time” and leaving her staff “effectively rudderless.”  He alleged that she “alienated the 
reserve YNs to the point that most retired.”  
 
Declaration of the Command Master Chief at the XXX 
 
 
The  master  chief  stated  that  in  mid  September  19xx,  he  ran  into  YN1  X,  who 
greeted him with “a negative comment.”  He realized something was wrong and took 
the yeoman to the Chief’s lounge for privacy.  YN1 X disclosed many “issues” to him 
and stated that because the applicant had shifted a lot of work onto him, he was work-
ing 12-hour days and most weekends to try to keep up.  She was doing nothing to help.  
When the yeoman began to cry, the master chief promised he would help him even if it 
meant sharing his work.  Because the applicant was not “on board,” he went to the XO, 
who indicated that the problem would be fixed.  The applicant was removed from her 
position the next day. 
 
 
The master chief alleged that he “never saw [the applicant] do anything to help 
her staff.  The door to her office was always closed and she routinely left early on lib-
erty.”  He also stated that YN1 X was an “outstanding” petty officer with “exceptional 
military bearing and ability.”  
 

Advisory Opinion of the Chief Counsel of the Coast Guard 
 
 
The  Chief  Counsel  argued  that  the  Military  Whistleblowers  Statute,  10  U.S.C. 
§ 1034,8 does not apply to the applicant’s case even though she argued that the disputed 
OER was prepared in retaliation for her June 19xx memorandum.  He alleged that she 
has never proved that the incidents alleged in her memorandum constituted illegal dis-
crimination  based  on  race.    He  argued  that  merely  indicating  that  the  parties  to  the 
alleged  incidents  were  of  different  races  does  not  prove  that  race  was  a  contributing 
factor.  He further argued that her memorandum did not meet the third-party reporting 
requirements  for  whistleblower  status  contained  in  Article  5.A.2.b.  of  COMDTINST 
M5350.4  because  she  did  not  show  that  the  situations  had  not  been  resolved,  that 
addressing the situations with the parties directly was unreasonable under the circum-
stances (since she was the supervisor of every person she mentioned in the memoran-
dum),  or  that  the  behavior  reported  was  clearly  criminal  in  nature.    Therefore,  he 
argued, her June 19xx memorandum is not a protected complaint under the statute. 
 
 
The Chief Counsel also argued that the applicant’s July 9, 19xx, civil rights com-
plaint  is  not  a  protected  communication  under  the  statute  because  she  did  not  file  it 
within 45 days of her removal as Administrative Officer, as required by COMDTINST 
M5350.4, and she filed it several months before the anticipated alleged reprisal—the dis-
puted OER—was completed.  Therefore, he argued, her complaint cannot be considered 
a valid discrimination complaint protected by 10 U.S.C. § 1034.  However, he argued, 
even assuming arguendo that her July 9, 19xx, civil rights complaint is a protected com-
munication within the meaning of the statute, the applicant has not made a prima facie 
showing that either her removal as Administrative Officer or the preparation of the dis-
puted  OER  was  retaliation  because  the  record  is  “replete”  with  evidence  of  her  sub-
standard  performance  during  the  evaluation  period.    Therefore,  the  Chief  Counsel 
argued, the Board should conclude that the procedures required by 10 U.S.C. Part 53 
are inapplicable.9 
 
 
Regarding  the  merits  of  the  applicant’s  allegations,  the  Chief  Counsel  argued 
that she failed to provide clear and convincing evidence that “there was any reprisal or 
bias in the disputed OERs.”  He argued that, although the applicant repeatedly alleged 
that  her  rating  chain  retaliated  against  her  after  she  submitted  her  June  19xx 
memorandum  about  a  hostile  work  environment,  “[n]othing  in  any  of  the  testimony 
                                                 
8 The statute states that “[n]o person may take (or threaten to take) an unfavorable personnel action … as 
a reprisal against a member of the armed forces for making or preparing … any communication that the 
member  reasonably  believes  constitutes  evidence  of  …  a  violation  of  law  or  regulation,  including  … 
sexual  harassment  or  unlawful  discrimination  …  that  is  made  to  a  Member  of  Congress,  an  Inspector 
General,  or  any  other  person  or  organization  (including  any  person  or  organization  in  the  chain  of 
command)  designated  by  regulations  or  other  procedures  to  receive  such  communications.”  10  U.S.C. 
§ 1034(b). 
9  Under 10 U.S.C. § 1034(f), if an applicant “has alleged a personnel action prohibited by subsection (b),” 
the  Board  “shall  review”  the  report  of  the  Inspector  General,  “may  request”  the  Inspector  General  to 
gather more evidence, and must issue a final decision within 180 days. 

provided  by  her  superiors  indicates  that  the  June  19xx  complaint  played  any  role 
whatsoever  in  their  decision  to  relieve  her  in  September  19xx  nor  in  the  evaluation 
process completed in November 19xx.”  The Chief Counsel built on the PRRB’s findings 
about the case by making the following arguments about how the new declarations he 
gathered reflect on the applicant’s allegations: 
 
 
COMMENT [C]:  The Chief Counsel argued that the applicant’s evidence indi-
cating that she issued many checks does not disprove the truth of the comment because 
it  does  not  negate  her  supervisor’s  statement  that  during  the  evaluation  period  she 
refused  to  learn  the  new  system  and  delayed  some  members’  receipt  of  mutual 
assistance checks.  The Chief Counsel pointed out that the XO’s declaration supports the 
supervisor’s comment in the disputed OER. 
 
 
COMMENT  [H]:    The  Chief  Counsel  stated  that  the  PRRB  “adequately 
addressed the factual correctness of the comment” and that the comment’s accuracy is 
further supported by the declarations of the applicant’s former CO and XO, who both 
indicated that the applicant was negatively affecting the performance of her staff during 
the final months of the previous reporting period.  He pointed out that the former CO 
particularly  mentioned  her  negative  impact  on  the  Supply  Branch,  which  made  him 
decide that that branch should be removed from her department.  Therefore, he argued, 
the  Board  should  find  that  the  applicant  has  failed  “to  overcome  the  presumption  of 
regularity afforded this comment.” 
 
 
COMMENT [J]:  The Chief Counsel stated that the applicant’s argument that she 
met  the  weight  standard  are  irrelevant  to  the  truth  of  the  comment.    He argued that 
YN1 X’s statements about this matter in his declaration support the comment and that 
the  applicant’s  avoidance  of  her  supervisor’s  command  by  delaying  her  weighing 
reflects on her “Responsibility,” one of the performance categories grouped with com-
ment [J].  
 

COMMENT  [K]:    Regarding  this  comment,  the  Chief  Counsel  stated  that  her 
supervisor’s declaration indicates that it reflects her conduct with respect to obtaining a 
quota for the plan-writing class without her chain of command’s knowledge or permis-
sion.  The Chief Counsel alleged that she has failed to prove that she followed normal 
procedures for requesting training or that she received any kind of tacit approval from 
her command.  He argued that even if, as she alleged, she asked her supervisor at some 
point to “look out for” a message about the class, such a statement would not amount to 
following  proper  procedure  or  receiving  her  command’s  consent  to  take  the  class.  
Therefore, he argued, she has not proved that comment [K] is erroneous or unjust. 
 
 
out, the applicant did not dispute in her application to the PRRB: 
 

The  Chief  Counsel  also  addressed  the  following  comments,  which,  he  pointed 

COMMENTS  [A1]  &  [A2]:    The  Chief  Counsel  alleged  that  the  applicant’s 
 
excuse for resisting supporting the reservists (being short-staffed) “does not refute the 
objectivity of the OER comment” and that there is “ample evidence indicating that the 
comments were fundamentally fair.”  He pointed out that the supervisor indicated in 
his declaration that he had received numerous complaints from the reserve Command 
Enlisted Advisor; that the CWO who headed the Supply Branch stated that she “alien-
ated the reserve YNs to the point that most retired”; and that YN1 X stated that he had 
to deal with the reservists’ significant administrative problems because they would not 
deal with the applicant “due to her attitude.”  Therefore, he argued, the Board should 
find that the applicant has failed “to overcome the presumption of regularity afforded 
this comment.” 
 
 
COMMENT [B]:  The Chief Counsel stated that there is ample evidence in the 
record  to  support  the  comment  that  the  applicant’s  “administrative  credibility”  came 
into question and that she was aided by a very capable YN1.  He pointed out that her 
previous XO indicated that she came to the job with little experience and needed a lot of 
help  and  that  the  declarations  of  both  the  new  CO  and  YN1  X  indicated  why  her 
“administrative credibility” was in question.  He also pointed out that both the Com-
mand Master Chief and the applicant’s supervisor praised YN1 X’s abilities. Therefore, 
he  argued,  the  Board  should  find  that  the  applicant  has  failed  “to overcome the pre-
sumption of regularity afforded this comment.” 
 
 
COMMENT [E]:  The Chief Counsel pointed out that the applicant provided no 
evidence to disprove this comment.  He also pointed out that in his declaration, YN1 X 
stated that the applicant used very derogatory profanity to criticize his work “in plain 
view of everyone in the Department.”  Therefore, he argued, the Board should find that 
the applicant has failed “to overcome the presumption of regularity afforded this com-
ment.” 
 
 
COMMENT  [F]:    The  Chief  Counsel  stated  that  the  supervisor’s  declaration 
amply supports this comment and that, therefore, the Board should find that the appli-
cant has failed “to overcome the presumption of regularity afforded this comment.” 
 
 
COMMENT [G]:  The Chief Counsel stated that the applicant has admitted that 
this statement is true but blamed the incident on YN1 X’s poor performance rather than 
her lack of leadership.  He alleged that comment [G] is amply supported by the declara-
tions of the applicant’s XOs and COs and by those of the CWO and Command Master 
Chief.    Therefore,  he  argued,  the  Board  should  find  that  the  applicant  has  failed  “to 
overcome the presumption of regularity afforded this comment.” 
 
 
Regarding  the  disputed  comments  in  the  concurrent  OER  (Comments  [1]  and 
[2]), the Chief Counsel argued that the PRRB properly found that the applicant’s unsup-
ported allegations of bias and taint and her own opinion of her performance at XXXXX 

are  insufficient  to  overcome  the  presumption  of  regularity  afforded  the  comments  of 
her rating chain at XXXXX. 
 
 
The Chief Counsel did not include in the advisory opinion an analysis of whether 
the alleged errors and injustices in the two OERs, if proven, could have caused her to be 
passed over for promotion and consequently retired.  However, he offered to provide 
one or to address any other matter upon the Board’s request. 
 

APPLICANT’S RESPONSE 

 

On  February  28,  2002,  the  Chairman  forwarded  copies  of  the  Chief  Counsel’s 
advisory opinion and its attachments to the applicant and invited her to respond.  The 
applicant  requested  and  was  granted  extensions  totaling  more  than  five  months  and 
responded on September 3, 2002.   

 
In  her  response,  the  applicant  stated  that  she  never  alleged  that  the  disputed 
OER was prepared in retaliation for her civil rights complaint and she asked the Board 
to “ignore the Coast Guard’s responses that contain any reference to Civil Rights issues 
so they do not detract from the main focus of [the] application.”  She stated that she is 
asking the Board to remove the OER because it is an unfair evaluation of her perform-
ance and full of “lies, half truths and distortion of facts,” not because of any purported 
retaliation. 

 
The  applicant  stated  that  the  declarations  provided  by  the  Coast  Guard  prove 
her allegation that her CO and XO were prejudiced against her by negative reports they 
received at the beginning of the reporting period and even before the period began.  She 
alleged  that  the  XO’s  statement  proves  that  he  prejudged  her  based  on  the  negative 
reports, removed her from her position “at the first opportunity,” and tried to substan-
tiate his decision afterward. 

 
The applicant alleged that if her performance were truly lacking during the prior 
evaluation period and if she were truly the “poor fragile person” they described in their 
declarations, her previous CO and XO would not have allowed her to be the Adminis-
trative Officer for two and one-half years or given her positive OERs.  She argued that 
their recent declarations are less reliable indicators of her performance than the positive 
OERs  they  timely  prepared  and  that  their  declarations  “were  certainly  colored  by 
information provided by” her rating chain for the disputed OER.  She argued that the 
statement she provided from the CWO who had served as the Operations Officer of the 
XXX until July 19xx (see page 7 above) also proves that there was prejudice against her. 
 
 
The applicant alleged that the supervisor’s statement in his declaration that she 
did  not  complete  the  job  of  updating  and  transferring  the  unit  instructions  is  contra-
dicted by his comment in the disputed OER that she “[c]onsolidated unit instructions & 
migrated  to  SWS  III.”    She  alleged  that  his  comment  that  the  unit  would  have  been 

required to pay for her per diem and travel costs for the plan-writing class is contra-
dicted  by  the  message  he  received  from  Headquarters  showing  that  they  were  both 
enrolled  in  the  class,  which  shows  that  Headquarters  provided  the  travel  orders  and 
“fully funded the school.”  She alleged that he has provided three different stories about 
her training the reservists: in the disputed OER, he wrote that she “effectively provided 
alcohol-abuse training to all hands”; he told the PRRB that she showed up late in civil-
ian clothes and did not participate; and after she submitted a contrary statement by the 
Reserve Command Master Chief, he stated that he had to order her to provide training 
for the reservists. 
 
Regarding the XO’s declaration, the applicant asked how she could have written 
 
three times as many checks as all others at the command if she did not know the soft-
ware.  She alleged that, in claiming that he discovered her marriage when she went on 
TAD,  the  XO  lied,  because  no  interviews  with  spouses  are  required  prior  to  TAD 
assignments.  She alleged that the XO only discovered her marriage after the evaluation 
period,  in  November  19xx,  because  spouses  must  be  interviewed  prior  to  permanent 
transfers.  She alleged that he lied about the date he discovered her marriage because 
she had shown that his prior claim that she would not have been allowed to take her 
dependents on TAD was also false.   
 
 
The applicant alleged that YN1 X’s declaration is “replete with lies.”  She alleged 
that she was not even at the office on September 17, 19xx, so she could not have used 
profanity on him that day in the presence of others, as he alleged.  She argued that the 
Command Master Chief’s statement that she was “not on board” proved her allegation 
and the falseness of YN1 X’s declaration.  She also alleged that the negative compliance 
report  completed  in  September  19xx,  six  months  after  she  left  the  office,  proves  that 
YN1 X was not a capable yeoman.   
 

The applicant stated that she believes that, in praising YN1 X, the former CO was 
misremembering  because  the  capable  YN1  she  had  worked  with  while  he  was  at  the 
XXX  was  YN1  Y,  who  no  longer  worked  in  her  department  during  the  evaluation 
period for the disputed OER. 
 
 
The applicant pointed out that the statement of the CWO who headed the Supply 
Branch about her causing the reserve yeomen to retire is hearsay.  She alleged that she 
was friends with both of the reserve yeomen who retired while she was at the XXX and 
that one retired for medical reasons and the other retired because she had had trouble 
during a prior temporary active duty contract that “negatively affected her ability get 
any more” contracts. 
 
 
The applicant repeated her allegation that if her performance had been as bad as 
is indicated in the disputed OER, other negative entries would have been made in her 
record during the evaluation period.  Finally, she argued that she only lacked credibility 
when  she  arrived  at  the  XXX  because  she  had  previously  received  “out  of  specialty 

RELEVANT REGULATIONS 

 

Article  10.A.  of  the  Personnel  Manual  (COMDTINST  M1000.6A)  governs  the 
 
preparation of OERs.  Each OER is prepared by the reported-on officer’s “rating chain” 
of three officers:  the supervisor (the officer to whom the reported-on officer answers on 
a daily basis), who completes blocks 3, 4, and 5 of the OER; the reporting officer (the 
supervisor’s supervisor), who reviews the supervisor’s blocks and completes blocks 7 
through 10; and the reviewer (the reporting officer’s supervisor), who checks the OER 
for errors, omissions, and inconsistencies.  Article 10.A.1.b. states the following: 

Each commanding officer must ensure that accurate, fair, and objective evalua-

 
17. 
tions are provided to all officers under their command. . . .  
 
Individual officers are responsible for managing their performance.  This respon-
2. 
sibility  entails  determining  job  expectations,  obtaining  sufficient  performance  feedback, 
and using that information to meet or exceed standards. 

assignments” as a result of the Coast Guard’s failure to timely remove an OER that the 
BCMR  had  ordered  removed  from  her  record  in  Docket  No.  124-92.    Therefore,  she 
argued, her failure to be promoted and mandatory retirement are unjust results of the 
Coast Guard’s failure to implement an order of the BCMR. 
 

 
 
Article 10.A.2. provides that it is the responsibility of the reported-on officer to 
seek performance feedback from the supervisor; the supervisor provides performance 
feedback  upon  the  reported-on  officer’s  request  or  whenever  appropriate;  and  the 
reporting officer provides performance feedback to the reported-on officer “as appro-
priate.”  Article 10.A.1.c.5. provides that  
 

[n]o specific form or forum is prescribed for performance feedback … .  [It] occurs when-
ever  a  subordinate  receives  advice  or  observations  related  to  their  performance  in  any 
evaluation  area.    Performance  feedback  can  take  place  formally  (e.g.,  during  a  confer-
ence) or informally (e.g., through on-the-spot comments). Regardless of the forum, each 
officer  should  be  clear  about  the  feedback  received.  If  the  feedback  is  not  fully  under-
stood, it is the Reported-on Officer's responsibility to immediately seek clarification.  

 
 
Article 10.A.2.g.2.b. provides that an officer may be disqualified from serving on 
a rating chain if he or she has been relieved “for cause due to misconduct or unsatisfac-
tory performance, being an interested party to an investigation or court of inquiry, or 
any other situation in which a personal interest or conflict on the part of the Supervisor, 
Reporting Officer, or Reviewer raises a substantial question as to whether the Reported-
on Officer will receive a fair, accurate evaluation.” 
 
 
instructions state the following: 
 

 
Article 10.A.4.d. of the Personnel Manual governs the preparation of OERs.  The 

(d) 
In the “Comments” sections following each evaluation area, the Reporting Offi-
cer  [or  Supervisor]  shall  include  comments  citing  specific  aspects  of  the  Reported-on 
Officer’s performance and behavior for each mark that deviates from a “4.”. . .    
 
(e) 
Comments  should  amplify  and  be  consistent  with  the numerical evaluations in 
the evaluation area.  They should identify specific strengths and weaknesses in perform-
ance 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.f.1. prohibits a rating chain from mentioning any ongoing investi-
gation, including discrimination investigations, in an OER.  However, “[t]his restriction 
does  not  preclude  comments  on  appropriate,  undisputed,  supportable  and  relevant 
facts, so long as no reference is made to the pending proceedings.”  Article 10.A.4.f.11. 
prohibits a rating chain from discussing a “Reported-On Officer’s performance or con-
duct which occurred outside the reporting period.” 

 
Article 10.A.4.g. states an officer may submit a reply to any OER within 14 days 
of receiving it and have this reply filed with the OER.  The purpose of the reply is to 
“provide an opportunity for the Reported-on Officer to express a view of performance 
which may differ from that of a rating official.” 

FINDINGS AND CONCLUSIONS 

1. 

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

 
 
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: 
 
 
§ 1552.  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. 
 
 
In several documents the applicant submitted, she suggested that the dis-
puted OER and/or her removal as Administrative Officer, which is mentioned in the 
disputed OER, were actions of reprisal for complaints she had made.  The Chief Coun-
sel  argued  in  his  advisory  opinion  that  the  provisions  of  the  Whistleblower  Statute, 
10 U.S.C. § 1034, regarding allegations of reprisal do not apply to her application.  In 
response to that advisory opinion, the applicant asked the Board essentially to ignore all 
civil  rights  and  retaliation  arguments  because  she  is  asking  the  Board  to  remove  the 
OER because of its inaccuracy and unfair assessment of her performance, not because of 
any  alleged  retaliation.    Therefore,  the  Board  finds  that  the  applicant  has  waived  the 

 

2. 

3. 

4. 

issue of whether her removal as Administrative Officer and the disputed OER were acts 
of reprisal or retaliation, and the Board will not address it. 
 
 
Absent  strong  evidence  to  the  contrary,  the  Board  presumes  that  rating 
officials have acted correctly, lawfully, and in good faith.10  To overcome the presump-
tion of regularity, an applicant must present at least some “clear, cogent, and convinc-
ing”  evidence—i.e.,  evidence  that  specifically  and  convincingly  contradicts  her  rating 
officials’ marks and comments.  If the presumption is overcome, the Board will weigh 
the evidence in the record to determine whether the applicant has met her burden of 
proof—the preponderance of the evidence—with respect to the disputed comments and 
marks.11  The Board determines whether the applicant has proved by a preponderance 
of the evidence that the disputed OERs were adversely affected by a “misstatement of 
significant hard fact,” factors “which had no business being in the rating process,” or a 
prejudicial violation of a statute or regulation.12  With this standard in mind, the Board 
has carefully considered all of the evidence presented regarding the disputed and con-
current OERs and draws the following conclusions with respect to the evidence. 
 

COMMENTS  [A1]  &  [A2]:  “With  some  resistance  eventually  agreed  to 
provide weekend admin support to reservists.” & “Resistant to full support to & from 
reservists.” 
 

5. 

The applicant alleged that she provided as much support to the reservists as she 
could “under the circumstances,” given that she was short-staffed and in the middle of 
the  transfer  season.    An email message from the reserve command master chief indi-
cates  that  she  provided  training  at  a  reserve  all  hands  meeting  in  November  19xx.  
Another  message  in  the  record  indicates  that,  after  the  transfer  season  was  over,  she 
arranged for two yeomen to assist the reservists once a month each on Saturdays.  How-
ever, none of the applicant’s evidence contradicts comment [A1] or [A2].  The comments 
do not state that she never supported the reservists but only that she resisted support-
ing them, and an email message from the reserve command master chief dated August 
15, 19xx, clearly shows his frustration over a lack of administrative support.  Although 
the  applicant  was  able  to  point  out  variations  in  her  supervisor’s  descriptions  of  her 
performance with respect to the reserve all hands meeting, the Board finds that she has 
not  rebutted  the  presumption  of  regularity  with  respect  to  comments  [A1]  and  [A2] 
because she has not presented any evidence that directly contradicts them. 
 

6. 

COMMENT [B]:  “Administrative credibility at times in question, profes-

sional competence supplemented by very capable YN1.” 

                                                 
10  Arens v. United States, 969 F.2d 1034, 1037 (Fed. Cir. 1992); Sanders v. United States, 594 F.2d 804, 813 (Ct. 
Cl. 1979). 
11    In  determining  the  preponderance  of  the  evidence,  the  Board  continues  to  consider  the  evidentiary 
weight of the rating chain’s assessment even though the presumption of regularity has been rebutted.  See 
Texas Dep’t of Community Affairs v. Burdine, 450 U.S. 248, 256 n.10 (1981). 
12  Hary v. United States, 618 F.2d 704, 708 (Cl. Ct. 1980); CGBCMR Docket No. 86-96. 

 
 
The  applicant  challenged  this  comment  by  alleging  that  the  YN1  in  question, 
YN1 X, was not “capable.”  She submitted a copy of a compliance report dated Septem-
ber 19xx, which indicated that the department was not complying with several policies.  
However, there is no evidence that YN1 X was responsible for the failures identified in 
the compliance report, and the record includes many statements from officers attesting 
to the capability of YN1 X.  The record also contains many statements that support the 
first half of comment [B].  The applicant did not submit a single statement from a col-
league to indicate that she was a hardworking, effective, or “credible” administrative 
officer during the evaluation period.  Therefore, the Board finds that the applicant has 
failed to overcome the presumption of regularity with respect to comment [B].   
 

7. 

COMMENT [C]: “[R]efused to learn computerized check-issuing system 

8. 

resulting in unfair delays to applicants.” 
 
 
The applicant alleged that she knew the computerized check-writing system for 
issuing mutual assistance checks, and she submitted a statement from the office’s cur-
rent mutual assistance clerk, who stated that between January 19xx and March 19xx, the 
applicant processed 37 checks totaling $24,510.86, whereas all other persons in the office 
had together issued 12 checks totaling $16,675.54.  However, this information does not 
contradict  comment  [C],  which  indicates  that  at  some  point  between  the  start  of  the 
evaluation  period  on  July  1,  19xx,  and  when  she  left  the  XXX  in  February  19xx,  she 
refused to learn a new check-issuing system and thereby unfairly delayed payments to 
members.  Although comment [C] was written by the supervisor, the XO supported it 
in his declaration for the Chief Counsel.  Therefore, the Board finds that the applicant 
has failed to overcome the presumption of regularity with respect to comment [C]. 
 

COMMENTS [D1] & [D2]:  “[B]ut failed to follow CG prgm guidelines & 
failed  to  inform/update  XO  on  personnel  problems  &  rehab  recommendations;  e.g. 
applied  inappropriate  &  unrealistic  standard  in  selecting  counselor,  unnecessarily 
delaying essential patient counseling.” & “Held off on required counseling of member 
involved  in  alcohol  incident  –  requesting  specific  counselor  –  increasing  anxiety  of 
member in need of counseling.” 
 
 
The applicant submitted a statement by the Addictions Program Representative 
 
for MLC, who described her as a very experienced, excellent CDAR who “continually 
made extra efforts to find members at [the XXX] the best care possible.”  Moreover, the 
same officer stated in an email to the applicant that he could not recall her ever delaying 
treatment for a member or asking for a specific counselor based on the race of the mem-
ber.  The Board finds that these statements are sufficiently clear and convincing about 
the applicant’s professional abilities and actions as a CDAR to overcome the presump-
tion of regularity afforded comments [D1] and [D2].  Moreover, the applicant’s abilities 
as CDAR are supported in the disputed OER itself, as it includes comments that she had 
a “[s]trong commitment to members as alcohol/substance abuse counselor”; “[d]emon-

strated  concerned  response  to  unit  members  in  need  of  counseling  for  both  alcohol 
screening  and  mutual  assistance  requests”;  and  “[a]s  CDAR,  effectively  provided 
alcohol-abuse training to all hands.”   
 
 
The applicant alleged that she failed to inform the XO about certain CDAR mat-
ters because he had a “closed door policy” for her.  The XO admitted that he had some-
one else in the office with him whenever she came in, but he also stated that she never 
told him that she needed to speak to him in private about a CDAR matter and made 
unilateral  decisions  that  “were  not  hers  to  make.”    The  applicant  did  not  deny  these 
statements. 
 
 
The  applicant  alleged  that  the  African-American  member’s  counseling  was 
delayed not because of her desire that he be treated by an African-American counselor 
but  because  the  member  had  to  undergo  NJP  before  he  could  be  diagnosed,  and  the 
statement of the Addictions Program Representative supports her allegation.  However, 
the supervisor in his declarations to the PRRB and to the Chief Counsel indicated that 
when he noticed that the member’s treatment was being delayed and asked the appli-
cant for an explanation, she told him that she was seeking an African-American coun-
selor for the member.  The supervisor’s statement is supported by the XO in his declara-
tion to the PRRB.  Therefore, although the Navy’s rule about treatment and NJP may 
have caused a delay in the member’s treatment, the Board finds that the applicant has 
not proved by a preponderance of the evidence that comments [D1] and [D2] are false 
or that the disputed OER as a whole unfairly reflects her performance as CDAR during 
the evaluation period. 
 
 
 

COMMENT [E]:  “[R]eprimanded senior POs in presence of nonrates.” 

9. 

10. 

The applicant presented no evidence that contradicts this statement.  Moreover, a 
statement by YN1 X in his declaration to the Chief Counsel indicates that in front of his 
subordinates one day she told him that he was a “’fuck up’ just like everyone else in the 
department.”  Therefore, the Board finds that the applicant has failed to overcome the 
presumption of regularity with respect to comment [E]. 
 

COMMENT [F]:  “[G]ave poor advice about their low marks to two mar-
ginally  performing  POs;  result:  subordinates  involved  CEA,  XO  in  seeking  relief  fm 
her.” 
 

 
The applicant alleged that when her supervisor failed to recommend a “margin-
ally  performing”  HS1  for  promotion,  she  advised  the  HS1  to  appeal  the  decision 
because it was based on only six weeks of observation and she believed the HS1 to be “a 
capable caring professional.”  However, the HS1 spoke to a career counselor and decid-
ed to retire.  These allegations do not contradict comment [F] and the applicant present-
ed no evidence that does contradict the comment.  Therefore, the Board finds that the 

applicant has failed to overcome the presumption of regularity with respect to comment 
[F]. 
 

11. 

COMMENT  [G]:  “Her  poor  interaction  w/  subords  &  failed  leadership 

resulted in emergency meetings of CPO Mess, CEA, & XO.” 
 
 
 
The applicant alleged that this comment resulted from an incident in which YN1 
X was caught using “foul and aggressive language” and blamed it on her.  She alleged 
that YN1 X was not credible because he had a history of having difficulty with super-
visors and was drinking despite having received Level III treatment for alcohol abuse.  
She alleged that she was not even in the office that day and was never given a chance to 
tell her side of the story.  However, the applicant submitted no evidence whatsoever to 
show  that  her  interactions  with  her  subordinates  was  not  lacking  or  that  emergency 
meetings  of  those  officers  were  not  required  because  of  her  failed  leadership.    More-
over,  the  XO  stated  in  his  declaration  to  the  PRRB  that  during  the  evaluation  period 
almost all of her subordinates complained to him about her, and other members also 
reported  her  unprofessional  behavior  and  interactions  to  him.    In  addition,  the  XO 
stated that prior to her removal as Administrative Officer, he had several meetings with 
other officers and petty officers concerning her failed leadership.  Therefore, the Board 
finds  that  the  applicant  has  failed  to  overcome  the  presumption  of  regularity  with 
respect to comment [G]. 
 

12. 

COMMENT  [H]:  “At  beginning  of  the  period,  served  as  Admin  Dept 
Chief which included F&S2 and SKs.  Dept was dysfuctional & Supply Branch was bro-
ken  out  as  separate  dept  to  allow  [the  applicant]  to  focus  on  YNs  &  admin  issues  & 
regain leadership credibility.” 
 
 
The  applicant  alleged  that  the  Supply  Branch  was  “broken  out”  as  a  separate 
 
department only to avoid having one CWO (her) supervise another CWO who headed 
that branch.  She also alleged that her prior good OER proves that the department was 
not dysfunctional and that she did not need to regain leadership credibility.  In support 
of her allegation, she submitted a copy of an email from the CWO who headed the Sup-
ply Branch.  He stated that he was told his office was physically relocated to make more 
room for the Planning Department, but this does not address why his branch was made 
a separate department.  Moreover, comment [H] is amply supported by the declarations 
of the applicant’s former CO and the new XO regarding their reasons for removing the 
Supply  Branch  from  her  control  and  by  the  their  declarations  and  those  of  the  same 
CWO and the command master chief regarding the dysfunction of the department, her 
failed leadership, and her interactions with personnel in the Supply Branch.  Therefore, 
the Board finds that the applicant has failed to overcome the presumption of regularity 
with respect to comment [H]. 
 

13. 

COMMENT [I]:  “Admin Dept cont’d to be dysfunctional despite numer-

ous command counseling sessions.  Acted unprofessionally during counseling.” 

 
The  applicant  alleged  that  she  had  only  one  command  counseling  session  and 
that it was merely a briefing for the new CO when he arrived at the XXX.  She submit-
ted no evidence of this allegation, but the CO did not mention any counseling sessions 
in his statement to the civil rights investigator and no other declarant referred to a spe-
cific counseling session.  However, a counseling session occurs whenever anyone desig-
nated  by  the  command  counsels  the  member,  and  it is clear from the record that the 
applicant’s supervisor and XO frequently made her aware during the evaluation period 
that  she  was  not  meeting  their  expectations.    In  addition,  the  record  includes  many 
statements indicating that the department was dysfunctional under her leadership, and 
the applicant did not deny that she acted unprofessionally during counseling sessions.  
Therefore, the Board finds that the applicant has failed to overcome the presumption of 
regularity with respect to comment [I]. 
 

COMMENT  [J]:  “Took  advantage  of  position;  e.g.  refused  to  submit  to 
direct-subordinate  HS1’s  repeated  request  for  mandatory  weigh-in  prior  to  TAD;  XO 
led to believe weigh-in accomplished.” 
 
 
 
The applicant alleged that this comment is disproved by the lack of an entry in 
her record showing that she failed to meet the weight standard and an email message 
from the HS1 stating that the applicant was weighed but that the HS1 “was never able 
to get the percent body fat so it was not adequate for the official weight check.”  How-
ever, the fact that she ultimately was weighed and met the weight standard does not 
prove that she did not refuse to submit to repeated requests to be weighed or that the 
XO  was  not  at  some  point  wrongly  led  by  her  words  or  actions  to  believe  that  the 
“weigh-in” requirements for her TAD assignment had been met.  Moreover, both the 
supervisor and the XO reconfirmed the truth of comment [J] in their statements to the 
PRRB. Therefore, although the record indicates that the applicant was weighed before 
she went on TAD, the Board finds that she has not proved by a preponderance of the 
evidence that comment [J] is erroneous or unjust in how it characterizes her actions.   
 

COMMENT  [K]:  “[W]rongly  &  surreptitiously  had  orders  for  training 
issued by HQ, bypassed normal process including Supervisor, Training Officer & XO; 
result – kept eligible member from attending school. ”13 
 
 
 
The applicant alleged that she told her supervisor to expect a message about the 
class and that he set her up by not asking her for a training request form.  However, she 
also  admitted  that  she  accepted  Mr.  X’s  invitation  to be enrolled in the class without 
consulting her command.  In their declarations, both the supervisor and the XO indi-
cated  that  they  knew  nothing  about  her  enrollment  until  they  received  the  message 
from Headquarters on her last day at the XXX.  Although the applicant and the Coast 
Guard submitted many documents and allegations concerning her quota for the class 
and why it was cancelled, these allegations are irrelevant to the issue addressed in com-
                                                 
13 The shaded phrase was deleted from the OER by the PRRB. 

14. 

15. 

ment [K].  Therefore, the Board finds that the applicant has failed to overcome the pre-
sumption of regularity with respect to comment [K]. 
 

16. 

COMMENT  [L]:   “Professional  skills/position  often  used  to  ‘work  the 
system’ to own purposes/advantage, adversely impacting subordinates and command 
good order … .” 
 
The applicant alleged that this comment is a direct if veiled reference to her filing 
 
civil rights complaints and, as such, is prohibited by Article 10.A.4.f. of the Personnel 
Manual.  She submitted a copy of a rough draft for the disputed OER, which includes 
the statements “[e]xhibits discriminatory tendencies; stirs the pot by creating gender & 
racial issues where none exist.  Uses civil rights issues as scare tactics towards supervi-
sor.    Invited  outside  agency  civil  rights  investigator  to  question  command  on  CG 
trends.”  However, other than the fact that comment [L] did not appear in the supervi-
sor’s rough draft for the OER, and the fact that the language about her creating “racial 
issues” and inviting an investigator did appear, there is no evidence that comment [L], 
which appears in the XO’s part of the disputed OER, is a revised version of the deleted 
language in the rough draft, which appeared in the supervisor’s part of the OER.  More-
over, both the supervisor and the XO pointed to the applicant’s actions with respect to 
her enrollment in the plan-writing class and her taking her dependents on TAD without 
her command’s knowledge as examples of her “working the system” to her own advan-
tage, and the applicant provided no evidence, other than her own word, to refute these 
statements. 
 
 
In  her  arguments  concerning  comment  [L],  the  applicant  pointed  out  that  her 
supervisor and XO made several erroneous allegations about her actions with respect to 
the TAD assignment and the class because they did not know the rules.  For example, 
they erroneously alleged that it is against regulations ever to “go TAD from TAD,” to 
take a class when one is retiring soon, and to take dependents on TAD.  She has proved 
that  they  sometimes  erroneously  assumed  she  was  breaking  a  regulation,  when  she 
may  only  have  been  acting  against  the  command’s  general  policy  and  without  its 
knowledge,  but  this  does  not  disprove  comment  [L],  which  indicates  only  that  her 
knowledge and ability to “work the system” sometimes adversely affected her subordi-
nates and “command good order.”  Although her rating chain’s declarations provided 
no example of how her “working the system” negatively affected a subordinate, they do 
indicate that “command good order” was adversely affected when she failed to follow 
the chain of command to request training and moved her dependents without warning 
her command or the command at XXXXX.   
 

The  applicant  also  pointed  out  that  some  of the examples of her “working the 
system”  described  by  her  rating  chain  in  their  declarations  occurred  outside  of  the 
evaluation period. Article 10.A.4.f.11. of the Personnel Manual prohibits a rating chain 
from discussing a “Reported-On Officer’s performance or conduct which occurred out-
side the reporting period” in an OER.  However, the fact that her rating chain cited such 

examples  in  their  statements  to  the  investigator and declarations does not prove that 
she did not also “work the system” to her own advantage and to the detriment of her 
subordinates and “command good order” during the evaluation period.  Therefore, the 
Board finds that the applicant has not proved by a preponderance for the evidence that 
comment [L] is prohibited by the Personnel Manual, erroneous, or unjust in its charac-
terization of her actions. 
 

18. 

COMMENTS [1] & [2]: “This officer also seemed to be dedicated to the 

CG.” & “This officer is considered qualified for promotion to CWO4.” 
 
The applicant alleged that these comments are unfair because her rating chain at 
 
the XXX essentially sabotaged her reputation and performance at XXXXX by unfairly 
canceling  her  orders  to  attend  the  plan-writing  class  and  by  biasing  the  XXXXX 
command against her.  She submitted evidence indicating that there was room for her 
in the class and that it would have been helpful for her work at XXXXX.  She alleged 
that her supervisor’s explanation as to why he cancelled her quota is a lie because the 
message  he  received  from  Headquarters  indicated  that  Headquarters  had  issued  the 
travel orders, thereby fully funding the class.  She also proved that her supervisor and 
the  lieutenant  at  XXXXX  knew  each  other  and  had  some  communication  about  her 
performance.   
 
 
There  is  no  evidence  in  the  record,  however,  indicating  that  the  applicant’s 
supervisor was not honestly mistaken about the cost of the class to the XXX.  In addi-
tion,  the  record  indicates  that  her  command  had  previously  verified  that  she  did not 
need any training to do the work, and her command at XXXXX apparently agreed with 
this assessment.  While the class may have been helpful to her, as Mr. X stated, there is 
no  evidence  in  the  record  that  it  was  necessary  for  her  to  do  the  work  or  that  either 
command denied her enrollment because of prejudice.  Moreover, the record indicates 
that the applicant did not work very hard at XXXXX to earn a good OER:  in response to 
an  innocuous  inquiry  from  her  supervisor  about  her  upcoming  retirement,  the  lieu-
tenant  at  XXXXX  wrote  back  on  May  28,  19xx,  that  “[s]he  has  checked  out cause she 
knows that she will not get what she needs on an OER, so now she does bills and reads 
the  paper.”    Therefore,  the  Board  finds  that  the  applicant  has  failed  to  overcome  the 
presumption of regularity with respect to comments [1] and [2]. 
 

The applicant alleged that she never got a “fresh start” with the new rat-
ing chain that formed in the summer of 19xx because they had heard complaints from 
her subordinates and saw her June 19xx memorandum.  The record indicates that the 
new  CO  and  XO  did  see  her  June  19xx  memorandum  and  that  her  subordinates  did 
complain  to  the  XO  about  her.    However,  the  applicant  has  not  proved  that  it  was 
improper or unfair for the previous CO to provide them with a copy of the memoran-
dum or to inform them of the status of her department.  Moreover, an email message 
from the XO dated August 12, 19xx, states that the CO had told the XO that the appli-
cant was to begin with a “clean slate,” and the applicant’s supervisor did not join the 

19. 

office  until  September  19xx,  after  she  had  already  been  removed  from  her  position.  
Although the applicant was removed from her post just a few weeks after the new CO 
arrived, the record indicates that in that short time, he had already noticed a difference 
between her actual performance and the comments and marks she had received in prior 
OERs.    In  addition,  the  XO  stated  that  before  they  decided  to  remove  her,  he  had 
received many complaints about her performance and he had consulted with the CO 
about her several times.  Under Article 10.A.2.g.2.b. of the Personnel Manual, an officer 
is “disqualified” from serving on a rating chain only if he or she has been relieved “for 
cause due to misconduct or unsatisfactory performance, being an interested party to an 
investigation or court of inquiry, or any other situation in which a personal interest or 
conflict on the part of the Supervisor, Reporting Officer, or Reviewer raises a substantial 
question as to whether the Reported-on Officer will receive a fair, accurate evaluation.”  
The Board finds that the applicant has not proved by a preponderance of the evidence 
that any member of her rating chain at the XXX or at XXXXX was unfairly prejudiced 
against her or was otherwise disqualified from serving on her rating chain.  
 
 
The applicant alleged that if her performance had been as bad as the dis-
puted OER indicates, her supervisor would have made some other entry in her record.  
She alleged that she was not properly counseled and that she met all her supervisor’s 
expectations  after  he  was  made  Administrative  Officer.    She  stated  that  some  of  the 
positive comments in the disputed OER prove that she performed work that he stated 
she had not completed.  However, the comments in the disputed OER indicating that 
she did work on certain projects do not prove that she met her supervisor’s expectations 
with respect to those projects.  In addition, YN1 X indicated in his declaration that at 
office meetings, the applicant “could not produce any results” and gave her supervisor 
excuses about why her work was not done.  Moreover, Articles 10.A.1. and 10.A.2. of 
the Personnel Manual place the primary onus for ensuring performance feedback on the 
reported-on officer.  Officers are expected to make sure that they know their supervi-
sor’s expectations and meet them.  The applicant has not proved that her rating chain 
did not meet the requirements of the Personnel Manual with respect to evaluating her 
performance. 
 

20. 

21. 

The applicant made numerous allegations with respect to the actions and 
attitudes of her command, her rating chains, and other Coast Guard members.  Those 
allegations not specifically addressed above are considered to be without merit and/or 
not dispositive of the case.  
 
 
The applicant has not proved that any comment or mark in the disputed 
OER or the concurrent OER (as corrected by the PRRB) is erroneous or unfair.  She has 
not proved that the marks and comments in the OERs are the result of anything other 
than her rating chain members’ fair and objective assessments of her performance dur-
ing the evaluation periods. 
 

22. 

23. 

24. 

 
 
 
 
 

The applicant argued that the Board should remove her failures of selec-
 
tion for promotion and expunge her retirement because the selection boards that failed 
to select her reviewed her record with the disputed OERs in it.  Although this Board has 
not found any further errors in the disputed OERs to correct, the PRRB did find and 
remove one erroneous comment from the disputed OER and another from the concur-
rent  OER.    Therefore,  the  Board  must  consider  whether  the  erroneous  comments 
removed by the PRRB could have caused her failures of selection by the PY 2000 and 
2001 CWO selection boards in 19xx and 2000, respectively. 
 

In Engels v. United States, 678 F.2d 173, 175-76 (Ct. Cl. 1982), the Court of 
Claims held that the BCMR should decide whether an applicant’s failure of selection for 
promotion  should  be  removed  by  answering  two  questions:    “First,  was  [the  appli-
cant’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 prejudice, is it 
unlikely  that  [the  applicant]  would  have  been  promoted  in  any  event?”    The  Board 
finds that the two phrases removed from the applicant’s OERs by the PRRB—“kept eli-
gible  member  from  attending  school”  and  “However,  external  issues  seem  to  have 
impacted on fullest utilization & most effective performance”—make her record appear 
slightly worse than it would have in their absence.  However, the Board further finds 
that, in light of the many negative comments and low marks in the disputed OER and 
the concurrent OER, it is very unlikely that the applicant would have been promoted 
even if those two phrases had not been in the OERs when they were reviewed by the PY 
2000 and 2001 CWO selection boards. 
 

25.  Accordingly, the applicant’s request should be denied. 

[ORDER AND SIGNATURES APPEAR ON FOLLOWING PAGE] 

The application of retired xxxxxxxxxxxxxxxxxxxxxxxxxxxx, USCG, for correction 

ORDER 

 

 
 Kevin C. Feury 

 

 

 
 Donna L. O’Berry 

 

 

 

 

 
 
 Gareth W. Rosenau  

 

 

 

 
 

 

 

 
 

 
 

 
 

 
 

 

 

 
 

 
  

 
 

  

 

 

 
 

 

 
 

 

 
 

 
 

 
 
of her military record is denied.   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

 
 
  
 

 
 
 
 

 
 

 
 

 

 

 

 

 
 

 
 

 
 

 
 

 

 



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