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Decision Text

CG | BCMR | OER and or Failure of Selection | 2004-192
Original file (2004-192.pdf) Auto-classification: Denied
DEPARTMENT OF HOMELAND SECURITY 

BOARD FOR CORRECTION OF MILITARY RECORDS 

 

 
Application for Correction of 
the Coast Guard Record of: 
 
                                                                                     BCMR Docket No. 2004-192 
 
xxxxxxxxxxxxxxxxxxx 
xxx xx xxxx, xxx/E-7 
   

FINAL DECISION 

 

 
 

 
AUTHOR:  Andrews, J. 
 
 
This is a proceeding under the provisions of section 1552 of title 10 and section 
425 of title 14 of the United States Code.  It was docketed on September 24, 2004, upon 
the BCMR’s receipt of the applicant’s completed application.  The Coast Guard submit-
ted an advisory opinion on February 15, 2005, and the applicant was granted a 42-day 
extension and responded on April 29, 2005.  The applicant’s response was forwarded to 
the Coast Guard for consideration on May 2, 2005.  On June 21, 2005, the BCMR asked 
the Coast Guard to respond in writing to certain factual questions and a legal argument 
raised in the applicant’s response to the advisory opinion.  The Coast Guard submitted 
a supplemental advisory opinion on June 29, 2005, and the applicant responded to it on 
July 11, 2005. 
 
 
members who were designated to serve as the Board in this case. 

This  final  decision,  dated  July  28,  2005,  is  signed  by  the  three  duly  appointed 

 

APPLICANT’S REQUEST AND ALLEGATIONS 

 
 
The  applicant  asked  the  Board  to  correct  his  record  by  removing  his  officer 
evaluation report (OER) for the period April 1, 2001, to January 31, 2002, when he was 
serving as a temporary lieutenant junior grade (LTJG).  He also asked that his commis-
sion  be  reinstated  and  that  he  be  promoted  to  lieutenant  with  his  peer  group  and 
receive all back pay and allowances. 
 
 
The applicant stated that his commission was revoked as a result of an improper 
imposition  of  non-judicial  punishment  (NJP)  at  mast after he was unjustly accused of 
sexual harassment.  He stated that on August 22, 2001, he was informed that an e-mail 

conversation he was having with a second class petty officer (BM2 Y) “was becoming 
uncomfortable  and  [she]  had  asked  someone  to  let  [him]  know.”    He  alleged  that  he 
immediately apologized to the BM2 “and considered the matter resolved.”  However, 
he was quickly summoned by the executive officer (XO), who told him that he would be 
placed on report for sexual harassment.  The applicant alleged that later that day, the 
commanding officer (CO) told him, “It doesn’t matter what you have to say, your fate 
has already been decided and all I have to do is find the facts to back it up.”  Two days 
later, he was reassigned from his cutter to a shore unit on temporary active duty (TAD). 
 
 
The applicant alleged that on September 26, 2001, he met with the lieutenant (not 
an attorney) who was appointed to serve as his mast representative.  He was advised 
that if he admitted to the charges, he would receive a lesser punishment.  He alleged 
that the next day, he saw the CO and XO and asked if he could have an attorney be his 
spokesperson at mast.  He alleged that the CO replied that he would not allow an attor-
ney to set foot on the cutter.  He alleged that his CO’s decision not to permit him to be 
represented by an attorney would only have been correct if the punishment had been 
limited to fourteen days of restriction and an oral reprimand. 
 

As a result of the mast on October 1, 2001, the applicant received NJP in the form 
of a Punitive Letter of Reprimand.  He appealed the NJP on the grounds that his pun-
ishment was disproportionate, but his appeal was denied.  On July 25, 2002, he was told 
that the Commandant had revoked his temporary commission as of October 25, 2002. 
 
 
The applicant alleged that the NJP for sexual harassment was unjust because he 
made no sexual advances or requests for sexual favors and his comments never affected 
anyone’s work performance.  He alleged that his comments were limited to one e-mail 
conversation with the BM2, to whom he immediately apologized after he heard she felt 
uncomfortable.  Therefore, he argued, his comments “could not have created an intimi-
dating or hostile work environment.”  He argued that he would only have been guilty 
of  sexual  harassment  if  he  had  continued  with  his  behavior  after  being  told  she  felt 
uncomfortable.  In addition, he argued, his comments did not establish any “quid pro 
quo” or pattern of sexual harassment. 
 
 
The  applicant  stated  that  the  BM2  never  filed  a  complaint  against  him.    He 
alleged that particular comments in the e-mail conversation were “taken out of context 
in  order  to  support  the  charges.”    He  alleged  that  he  would  have  been  let  off  with  a 
warning  had  his  command  considered  the  entire  e-mail  conversation.    Moreover,  he 
pointed out, during the investigation, his command could find no AIS User Acknowl-
edgement  Form  regarding  computer  and  email  use  policy  with  his  signature,  even 
though the form was used against him during the NJP and resulted in more charges. 
 
The applicant also alleged that he attempted to refuse mast and demand trial by 
 
court-martial but was not allowed to.  He argued that he should have been allowed to 
refuse mast because by the time the mast occurred, he had been transferred TAD to a 

shore unit and did not expect to be returned.  He argued that he was unjustly denied his 
right to refuse NJP and request court-martial.  He submitted no evidence to support his 
various allegations.  The applicant alleged that he did not learn that his rights had been 
violated until almost two years later, in 2004, during conversations with others. 
 

SUMMARY OF THE RECORD 

 
 
On  February  18,  xxxx,  after  completing  Officer  Candidate  School  (OCS),  the 
applicant—then a chief petty officer with almost ten years of military service—signed 
an Acceptance and Oath of Office to accept a temporary commission as an ensign.  He 
was assigned to a cutter as a Deck Watch Officer and his duties included serving as the 
Education  Services  Officer  (ESO).    A  “page  7”  entry  in  his  record  indicates  that  on 
March 24, 2000, the Code of Conduct was explained to him and the crew of the cutter. 
 
 
On his first OER, covering his service on the cutter from February 19 to Septem-
ber 30, 2000, the applicant received ten marks for 4, seven marks of 5, and one mark of 6 
in the various performance categories1 and a mark of 5 on the Comparison Scale.2  He 
was recommended for promotion to LTJG.  On his second OER, covering his service on 
the cutter through March 31, 2001, he received six marks of 4, ten marks of 5, and two 
marks of 6 in the performance categories, a mark of 5 on the Comparison Scale, and his 
XO’s  recommendation  for  promotion.    The  applicant  was  selected  for  promotion  and 
was promoted to LTJG on August 18, 2001. 
 
Charges Against the Applicant 
 
On  August  22,  2001,  the  applicant  acknowledged  in  writing  that  he  had  been 
 
charged with these offenses: fraternization (interrelating on terms of military equality; 
UCMJ  Article  134;  four  counts),  attempts  at  fraternization  (UCMJ  Article  80;  seven 
counts), failure to obey an order or regulation (by soliciting inappropriate interpersonal 
relationships  and  using  the  email  system  to  do  so;  UCMJ  Article  92;  thirteen  counts), 
dereliction  of  duty  (by  committing  sexual  harassment;  UCMJ  Article  92;  two  counts), 
and  conduct  unbecoming  an  officer  (by  seeking inappropriate relationships with sub-
ordinates; UCMJ Article 133; seven counts).  He was advised that the evidence against 
him  showed  that  he  had  verbally  solicited  an  inappropriate  relationship  with  YN3  B; 
had sexually harassed YN3 B and BM2 Y; and had sought inappropriate personal rela-
tionships in email messages to YN3 B and BM2 Y.  He was advised that his command 
intended to impose NJP and that he was entitled to be accompanied at mast by a mast 
representative or spokesperson. 

                                                 
1  Coast Guard officers are evaluated on a scale of 1 to 7 in a variety of performance categories, with 7 
being the highest mark. 
2  The Comparison Scale is not actually numbered.  However, as with the performance categories, there 
are seven possible marks.  Officers are supposed to be marked in comparison with all other officers of the 
same rank known to the reporting officer.  A mark in the fifth place means the officer was rated to be a 
“distinguished performer; give tough challenging, visible leadership assignments.” 

 

The applicant was also advised in writing of various other rights, including the 
right to review all evidence against him, to present evidence and witnesses, and to ques-
tion  witnesses  against  him.    In  addition,  he  was  advised  that  the  maximum  NJP  that 
could be imposed was an admonition or reprimand and thirty days of restriction and 
that he had a right to appeal the NJP.  The acknowledgement form that the applicant 
signed is specifically for an officer attached to a vessel and so does not include a right to 
consult counsel about the NJP or to refuse NJP and demand trial by court-martial.  Also 
on August 22, 2001, the applicant was sent to work at a shore unit, the Xxxxxxxx Area, 
where he served as an anti-terrorism and force protection coordinator. 

 
Following an investigation, on September 25, 2001, the investigator and the XO 
recommended that the charges against the applicant be disposed of at mast.  The mast 
was held on October 1, 2001.  A lieutenant served as the applicant’s mast representative. 
The evidence gathered by the investigator included the following: 
 
Evidence of BM2 Y 

 
BM2 Y, a crewmember on the cutter, provided the following email messages: 
 

Date 
7/28/01  1454  Hello 

Time  Subject 

From 
App. 

To 
BM2 Y 

8/16/01  2308  Party 

App. 

BM2 Y 

8/16/01  2349  XXXXX 

App. 

BM2 Y 

8/17/01  1608  RE: Party 
8/17/01  1619  RE: Party 
8/17/01  2333  RE: Party 

BM2 Y 

App. 
BM2 Y  App. 
App. 

BM2 Y 

8/17/01  1616 
8/17/01  1923  RE:  

 

8/17/01  2142  RE:  

8/18/01  1423  RE: 

8/19/01  0254  RE:  

8/19/01  1952  … 

App. 
App. 

App. 

App. 

App. 

App. 

BM2 Y 
BM2 Y 

BM2 Y 

BM2 Y 

BM2 Y 

BM2 Y 

Message 
“Hey Dee, It was great talking to you last night … You 
can be my BMOW anytime!!! …” 
“Hey Dee, I hope to see you at the wetting down 
[promotion] party in XXXX.  I haven’t decided on a 
location yet, but I’ll let you know when I do.  Bob” 
“Dee, Let me know if you’re going to a tattoo parlor in  
xxxxxx.  I want to go with you so I can get some more 
work done on one of mine.  Bob” 
“Which would you prefer … Sports Bar or Hotel Bar?” 
“Either would be good, there’s beer at both.” 
“Hey D, I just wanted to let you know that I have 
decided to have the wetting down party in xxxxxx.  I 
can get a lot more alcohol for my money.  But we can 
still party in xxxxxx if you want to.” 
“If I tell you something, can you keep it to yourself?” 
“I’ve been wanting to ask this for a while now and don’t 
quite know how you’ll react to it so I’m kind of 
hesitant.” 
“True … I’ll ask you next time we’re together and no 
one else can hear what we’re saying.” 
“D, Ever hear that song……If I said you have a 
beautiful body would you hold it against me?” 
“D, RDC dared me to say that to you … so tell him he 
owes me a beer now.” 
“D, Just so you know what started that whole 
conversation … I told RDC that I thought you were 
attractive and he told me that I didn’t have the balls to 
tell you.  So I figured that was an easier way to say it.  
But I guess that I just came out and told you again.  
Anyway … that’s what started it.” 

8/21/01  0010  Sometime 

RDC 

App. 

“This is not cool sir, this is my name in print.  I have full 
confidence in your honor to enlighten those concerned 
with the truth.” 

will you 
explain 
this to 
me? 

8/21/01  1157  RE: [same 
as above] 

App. 

RDC 

“Chief, I am so sorry for getting you involved with this 
mess.  I will straighten this out and yes I will explain it 
to you.  Again, I hope you can forgive me.” 

 
BM2  Y  stated  that  she  had  never  before  had  a  private  conversation  with  the 
applicant, but when he asked her in an email on August 17, 2001, if she could keep a 
secret, she responded, “Of course.”  When he replied that he was hesitant, she told him 
that  she  did  not  know  how  to  react  because  she  did  not  know  what  he  was  talking 
about.  When he said he would tell it to her when they were alone, she decided that he 
was hinting at something inappropriate and so stopped responding to his emails.  The 
next  day  when  he  sent  her  the  comment  about  holding  her  body  against  him,  she 
advised her supervisor about the problem.  When the applicant continued sending sug-
gestive emails on the third day, August 19, BM2 Y again informed her supervisor.  In 
one of the emails, the applicant stated that he had been sending the emails because an 
RDC had dared him to.  However, when BM2 Y and her supervisor checked with the 
RDC, he denied it but said that the applicant had told him that he had used his name 
“in vain” and might have gotten him in trouble.  The RDC told BM2 Y that the applicant 
was just trying to “cover up for the inappropriate emails.”  She knew that YN3 B was 
having a similar problem with the applicant, and so she took the matter and copies of 
the emails to her chief later that day, who passed them on to the XO.  BM2 Y further 
stated that a Navy petty officer who had been on their last patrol had “also complained 
of inappropriate emails from [the applicant] toward the end of the patrol.” 
 
Evidence of YN3 B 

 
YN3 B, another crewmember, stated that the applicant asked her on several occa-
sions if she would go windsurfing with him and made it clear that it “would just be the 
two of us.”  Even though she always refused, he “would then push the question again.”  
YN3  B  stated  that  he  asked  her  to  go  windsurfing  in  this  way  “about  4-5  times  each 
inport the last few inports.”  She stated that she had heard another E-4 “talking about 
him  asking  her  several  times  too  and  her  saying  how  uncomfortable  she  would  be.”  
YN3  B  further  stated  that  one  time  when  she  had  to  see  him  in  his  stateroom,  she 
noticed that his porthole was closed and said that, if she had a porthole, she would keep 
it  open.    In  response,  the  applicant  “looked  at  me  seductively  and  said  ‘well  we  can 
arrange  that,’”  with  sexual  overtones  that  made  her  uncomfortable.    Finally,  YN3  B 
stated that on August 16, 2001, when the applicant told her by email that he had a hotel 
room reserved and invited her there, she initially misunderstood and thought he was 
talking about reserving a room for a party.  She provided the following email messages: 

 

Date 
8/16/01  0002  Hello 

Time  Subject 

From 
App. 

To 
YN3 B 

Message 
“Hey [first name], I was wondering if you’re free next 
Wednesday night?” 

8/16/01  1044  RE: Hello 

YN3 B  App. 

8/16/01  1050  RE: Hello 

App. 

YN3 B 

8/16/01  1100  RE: Hello 
8/16/01  1710  RE: Hello 

YN3 B  App. 
App. 

YN3 B 

8/16/01  1715  RE: Hello 
8/16/01  1717  RE: Hello 
8/16/01  1718  RE: Hello 
8/16/01  1720  RE: Hello 
8/16/01  1725  RE: Hello 
8/16/01  1727  RE: Hello 

YN3 B 

YN3 B  App. 
App. 
YN3 B  App. 
App. 
YN3 B  App. 
App. 

YN3 B 

YN3 B 

8/16/01  1737  RE: Hello 

YN3 B  App. 

8/16/01  1842  RE: Hello 

App. 

YN3 B 

8/16/01  1844  RE: Hello 

YN3 B  App. 

8/16/01  1847  RE: Hello 

App. 

YN3 B 

8/16/01  1849  RE: Hello 
8/16/01  2015  RE: Hello 
8/17/01  0913  RE: Hello 

YN3 B  App. 
App. 
YN3 B  App. 

YN3 B 

“Hi, you’re talking about your party right?  Dee and I 
both talked about it and we both want to go.” 
“That sounds great, I think that I am taking the 
Wardroom out for dinner first.. What about later on 
afterwards?” 
“Just tell us the time and place.” 
“I’d love to have both of you there … are we going to 
do anything later in the evening?” 
“I am going to behave, and you???” 
“that depends … I’d rather not.” 
“When and Where?????” 
“Wednesday evening … I’ve got reservations.” 
“To the Hotel Bar?” 
“I think we are talking about two different things … The 
party will probably be at the Sports Bar.  I meant that I 
have reservations at the hotel for a room Wednesday 
night.” 
“I just made a deal with [another crewmate].  I will be 
standing his duty.  He offered me a deal I couldn’t 
refuse.” 
“Okay, question …Do you remember anything that you 
and I talked about the last time we were in XXXXXX 
XXXXXXX?” 
“Not a thing.  The last thing I remember was sitting at 
the bar with my two fisher friends.” 
“Okay I see where we’re going separate ways here.  
As hard as this is going to be, I will try and forget it 
ever happened. … Anyway, you’re not going to be 
there at the party now?  I was thinking that it might be 
better at the Hotel Bar.  What do you think?  I think it is 
a nicer place.” 
“The hotel bar is nicer. [omitted text]” 
“Well either way, [L], I want to take you out in xxxxx.” 
“I have duty the first night, and then I am going to my 
cousins and won’t be back until the day we get 
underway.” 

 
YN3 B also provided an email conversation in which she was asking the appli-
cant for guidance on how to pass certain tests.  When she thanked him for his help, he 
responded, “You’re welcome [L], I’ve always been willing to do anything for you I can.  
All you have to do is just ask, and give me that look …” 

 

Evidence of QM3 Y 

 
QM3  Y,  who  was  a  subordinate  in  the  applicant’s  department,  stated  that  the 
applicant  sometimes  asked  her  what  her  plans  were  for  the  weekend  in  a  way  that 
made her feel uncomfortable.  Also, he would give her looks when they crossed paths 
“that would give me chills because it gave me the creepiest feeling.”  She stated that on 
July 18, 2001, she was walking with an MK3 when the applicant came up and “insisted 
that we would join him and go to a karaoke bar.”  He told them that he would be upset 
if  they  refused,  and  he  gave  them  looks  that  made  them  feel  uncomfortable.  QM3 Y 

 

Evidence of PWE 
 

 
PWE stated that when the XO asked him to find an AIS User Acknowledgement 
Form regarding computer and email use policy with the applicant’s signature, he was 
unable to do so.  “Although all SW III users must read, acknowledge and sign an AIS 
form, one could not be found for [the applicant]” or for several other crewmembers. 
 
Statement by the Applicant for the Investigation  
 
 
On  September  19,  2001,  after  being  advised  of  his  Miranda/Tempia  rights, 
including the right to consult counsel prior to questioning, the applicant signed a state-
ment  in  which  he  “emphatically  den[ied]  any  attempt  to  have  an  inappropriate  rela-
tionship with anyone.”  Regarding the incident with QM3 Y and another female crew-
member  on  July  18,  2001,  he  stated  that  he  ran  into  the  two  women  standing  with  a 
group  of  shipmates  and  told  them  that  he and some others were going to a bar after 
dinner and that “they should stop by later if they didn’t have any other plans.”  When 
QM3  Y  stated  that  she  was  under  21,  he  told  her  she  could  get  in  but  would  not  be 
allowed to buy alcohol.  The two women agreed to stop by the bar after dinner. 

 
Regarding  QM3  Y’s  end  of  course  material,  the  applicant  alleged  that the only 
thing he said after he had told her that she would get the material in about six weeks 
was to ask if there were anything else he could do for her.  He stated that he asks this of 
everyone because he enjoys helping people succeed and had no idea that the question 
made her uncomfortable.  He would have apologized if he had known. 

 
Regarding YN3 B, the applicant stated that when she found out he liked to wind-
surf, she asked him, “When are you going to take me windsurfing?”  He told her that he 
“went every weekend and sometimes after work, so if she wanted to go, let me know 
and I would bring the gear.  I only have two windsurfing boards, so when I told her 
that it would just be us going, I assumed it was understood why.”  He stated that the 
“look”  he  referred  to  when  she  was  asking  for  help  in  studying  for  tests  was  a  “lost 
puppy” look she gave him every time she asked for something.  He stated that when 
she  commented  on  his  closed  porthole  and  he  said,  “Well  maybe  we  will  be  able  to 
arrange that,” he meant that if she could get into Officer Candidate School, she could 
get a stateroom with a porthole of her own. 

stated that the emails3 the applicant sent her after she asked him about end of course 
material  might  have  seemed  harmless  if  they  had  come  from  someone  else but made 
her uncomfortable in light of her prior experiences with him.  She also stated that from 
February through July 2001, the applicant had been “flirty” with an E-3 she knew.  

 

                                                 
3  No copies of these emails are in the record before the Board. 

Regarding his discussion of the “wetting down” party with YN3 B, the applicant 
stated that when he said he did not want to behave, he simply meant that he wanted to 
celebrate his promotion at a bar and that he told her he had a room reserved to indicate 
that he would not try to return to the cutter if he had too much to drink.  He stated that 
when  he  told  YN3  B  that  he  wanted  to  take  her  out  in  Xxxxxx,  he  “thought  it  was 
understood  that  [he]  meant  [he]  wanted  her to come to the wetting down party with 
[him].”    Later,  he  told  her  that  the  party  was  going  to  be  on  their  second  night  in 
Xxxxxx and that she could bring her cousins because he “would like for her to be at the 
party if she could make it.”  When she told him she did not know her cousins’ plans, he 
dropped the subject and did not mention it again.  He stated that he “never meant that 
[he] wanted to go out on a date” with YN3 B. 

 
The  applicant  stated  that  he  told  BM2  Y  that  she  could  be  his  BMOW  (boat-
swain’s mate of the watch) any time because she had done a good job.  He stated that he 
asked to accompany her to a tattoo parlor because she had previously mentioned to him 
that the tattoo parlors in Xxxxxx were good and cheaper than those in the United States 
and because he did not know the city or which tattoo parlor was good.  He stated that 
he had no intention of having an inappropriate relationship with her. 

 
The applicant stated that when he told BM2 Y that he thought she was attractive, 
he said that the RDC had dared him to do so because the RDC “always joked around 
with everyone, so I thought by saying he was involved she would realize that I did not 
mean anything by it.  I told RDC what I had said later that evening and apologized for 
getting him involved.”  The applicant stated that the next day the RDC told him that 
BM2  Y had reported the matter to her supervisor and did not want the applicant “to 
talk to her like that again.”  The applicant planned to apologize to BM2 Y but was called 
into the XO’s office two hours later. 

 
The  applicant  further  stated,  “I  am  profoundly  sorry  for  my  actions  and  wish 
that this entire situation had never occurred.  I have realized that I may have been too 
personal and not professional enough by calling junior personnel by their first name. … 
I also know that I crossed the line by what was said to [BM2 Y] and am sorry.  I have 
also learned a valuable lesson about the way people interpret and perceive what is said 
and will never be anything but professional with everyone I deal with from now on.”  
He apologized for hurting the crew and his wife and stated that he knew he had “lost 
any chance for continuing [his] sea career and … had to re-think [his] future.” 

NJP and Appeal 

 

 
1. 

 
As a result of the mast on October 1, 2001, the applicant’s CO entered a Punitive 

Letter of Reprimand in his record with the following text in pertinent part: 

In accordance with [UCMJ, Art. 15; MJM, Para. 1.E.2.a.; and Pers. Man., Art. 8.E.2.], 
you are hereby reprimanded for your conduct aboard [the cutter during] the period 
16 July to 16 August 2001.  You behaved in a reproachable manner by your conduct 

toward two female crewmembers assigned aboard this cutter.  Your behavior consist-
ed  of  attempts  at  fraternization, fraternization, failure to obey orders, dereliction of 
duty, and conduct unbecoming an officer. 

2.  You used the cutter’s email system for unauthorized purposes, and initiated and pur-
sued to the point of harassment correspondence with two female crewmembers in a 
wholly inappropriate and unprofessional manner.  Your actions were not in keeping 
with  Coast  Guard  policies  dealing  with  fraternization  and  the  prevention  of  sexual 
harassment.    Lastly,  your  actions  brought  discredit  upon  the  officer  corps  of  the 
United States Coast Guard. 

3.  You are advised of your right to appeal to … Commander, Xxxxxxxx Area. ... 
 
On  October  5,  2001,  the  applicant  submitted  an  appeal  to  the  NJP.    He  com-
plained that the “punishment awarded was, under the circumstances, disproportionate 
to the acts of misconduct that I committed.  While I do not question the seriousness of 
the  situation  and  a  need  for  punishment,  I  respectfully  ask  that  this  being  my  first 
offense, my service record and the following statement be taken into consideration as 
mitigating factors.”  The applicant went on to state that throughout his career—first as 
an enlisted member, then as an “A” school instructor, and, following OCS, as the ESO of 
the  cutter—he  had  worked  with  junior  enlisted  personnel.   As the ESO, he stated, he 
had tried to make himself “more approachable” and “tried to befriend everyone that I 
came in contact with just as I did as an instructor.  I became friendly with both male and 
female crewmembers so they would feel at ease speaking to me … .  I was never given 
any guidance to suggest that I may have been crossing the line between the enlisted and 
officer  corps.”    He  stated  that  he  had  changed  his  behavior  completely  after  he  was 
advised  of  the  complaints  on  August  20,  2001,  but  was  transferred  off  the  cutter  too 
quickly to prove to his command that he had corrected himself.  He stated that he now 
clearly understood “where the line is drawn between the enlisted and officer corps and 
the need for professionalism over personalism.”  He stated that the Punitive Letter of 
Reprimand would effectively end his career as an officer and asked that it be replaced 
with an Administrative Letter of Censure. 
 
 
The applicant’s CO forwarded the appeal to the Area Commander with his own 
recommendation  that  it  be  denied.    The  CO  stated  that  he  sent  the  applicant  ashore 
TAD because the evidence persuaded him that the applicant had created a hostile work 
environment on the cutter.  He stated that the applicant had admitted to all charges at 
the  mast  and  should  be  transferred  off  the  cutter  permanently  once  his  appeal  was 
complete.    The  CO  further  stated  that  the  applicant  had  clearly  “crossed  the  line  of 
inappropriate relationships” and that his claim that he was never given any guidance to 
indicate that he might be crossing the line was not credible.  The CO pointed out that 
the applicant had received training on the Commandant’s policies regarding interper-
sonal relationships, fraternization, and sexual harassment while assigned to the cutter 
and that he presumably also received such training as a petty officer, as an “A” school 
instructor, and at OCS.   
 

The CO stated that the applicant’s actions in telling one subordinate that she had 
a beautiful body and another that he wanted to take her out constituted not just a “mis-

step” but a “serious violation of the integrity expected of an officer” and a “flagrant dis-
regard for the rules.”  The CO indicated that the applicant’s actions were particularly 
egregious in light of the fact that both he and one of the subordinates he harassed were 
married.  The CO stated that although statements are often taken the “wrong way … in 
a way not intended by the originator of the remark” and that such matters are normally 
resolved satisfactorily at the lowest possible level, the CO could not dismiss the appli-
cant’s  remarks  “as  mere  misunderstandings  and  misinterpretations.”    The  CO  stated 
that the applicant’s inappropriate remarks were not those of “an officer innocently try-
ing to make himself more ‘approachable,’” but those of “an officer seeking out someone 
who  might  be  interested  in  his  advances.    I  consider  his  remarks  not  innocent  but 
predatory.    As  such,  an  Administrative  Letter  of  Censure  doesn’t  measure  up  to  the 
offenses committed, but a Punitive Letter of Reprimand does.” 
 
 
On  October  26,  2001,  the  Area  Commander  denied  the  applicant’s  appeal.    He 
stated that a military lawyer had concluded that the evidence was sufficient to conclude 
that the applicant had committed the charged offenses.  The Area Commander stated 
that  he  had  reviewed  the  justness  of  the  charges  even  though  the  applicant  had  not 
appealed  on  that  basis.    He  stated  that  his  review  indicated  that  some  of  the  charges 
“could  be  considered  multiplicious  under  military  law  and  if  tried  at  court-martial 
would likely be withdrawn or dismissed.  Even after taking this into account, however, 
I  find  that  the  NJP  was  justly  imposed.”    The  Area  Commander  also  stated  that  the 
Punitive Letter of Reprimand “was not excessive under the circumstances, and that any 
rational person could have come to the same conclusion about the type and quality of 
punishment as did your commanding officer.” 
 
Disputed OER 
 
The disputed OER covers the applicant’s service from April 1, 2001, to January 
 
31, 2002.  The Punitive Letter of Reprimand is cited in block 2 as an attachment to the 
OER.  In the OER, the applicant received two marks of 1 for “Workplace Climate” and 
“Responsibility,”  two  marks  of  2  for  “Judgment”  and  “Professional  Presence,”  four 
marks of 4, six marks of 5, and four marks of 6 in the performance categories, and an 
“Unsatisfactory”  mark  in  the  lowest  spot  on  the  Comparison  Scale.    The  low  marks 
were supported by the following comments: 
 

  “At CO’s NJP, mbr was found to have committed the offenses of sexual har-
assment & violation of the CG’s human relations policy.” 

 

 

 

  “Leadership  potential  now  severely  limited  after  finding  of  commission  of 
sexual harassment & fraternization.” 

  “Poor judgment displayed in improper use of email, pursuit of inappropriate 
relationships w/ juniors.” 

  “Unethical  behavior  displayed  in  initiating  &  pursuing  inappropriate  rela-
tionships w/ junior enl[isted].  Derelict in obligation to not commit sexual har-
assment.  Discredited self/USCG thru conduct unbecoming an officer – violated 
CG  policy  on  use  of  email;  used  email  to  ask  inappropriate  questions,  solicit 
inappropriate  interpersonal  contact  w/  juniors.    Improperly  addressed  junior 
enl[isted] by first names in violation of CG policy.” 

 

  “[The applicant] is not recommended for promotion to O-3.  [He had] great 
officer potential … —all of which was cast aside by abuse of position & authority 
manifested  in  sexual  harassment.    This  officer’s  leadership  ability  has  been 
severely compromised and is of dubious future value to the CG.” 
 
Because the marks of 1 rendered the disputed OER officially “derogatory,” the 
applicant was permitted to submit an addendum to it for his record, in accordance with 
Article  10.A.4.i.  of  the  Personnel  Manual.    He  submitted  an  addendum  on  March  29, 
2002, in which he stated the following in pertinent part: 

 
It  is  my  sincere  hope  that  readers  of  this  OER  will  also  take  into  consideration  my  13 
years of honorable, unblemished service.  I deeply regret the events that gave rise to the 
adverse aspects of this OER and I have learned—the hard way—a valuable lesson about 
the  need  to  ensure  that  my  future  conduct  is  entirely  above  reproach.    I  appreciate the 
rating  chain’s  fairness  in  including  in  this  OER  matter  that  is  favorable  and  accurately 
reflects my performance of duty.  … I believe that I can still be a productive member of 
the Officer Corps.  I am working hard to prove myself worthy of the commission I hold. 
 
The  applicant  also  received  a  “concurrent  OER”  from  the  Xxxxxxxx  Area 
command  covering  his  work  ashore  from  August  24,  2001,  to  January  31,  2002.    This 
OER does not mention any of the events that occurred on the cutter, and the description 
of the applicant’s work during the period indicates that it did not involve the cutter. 

 

Revocation of Commission 

 
On  May  29,  2002,  after  being  notified  that  his  record  was  to  be  reviewed  by  a 
Board of Officers to determine whether his temporary commission should be revoked, 
the  applicant  submitted  a  letter  to  a  revocation  panel  at  the  Coast  Guard  Personnel 
Command (CGPC).  He apologized for his conduct and explained that he “became too 
friendly with junior personnel, which led to my corresponding with them on a personal 
level and eventually led to the inappropriate comments made to them.” 

 
The applicant further stated that under the Personnel Manual, an officer’s com-
mission  is  to  be revoked when he is unable to adapt to military life or when his per-
formance indicates that it is doubtful whether he can be formed into an effective leader.  
He stated that neither criterion applied to him.  He stated that despite his prior conduct, 
he was “still an effective leader” trying to prove himself worthy of retaining his com-
mission.  He concluded that should the Board of Officers decide that he did not deserve 

a second chance, he would perform his enlisted duties “with the same performance of 
duty and moral character that got [him] accepted to Officer Candidate School.” 

 
On  June  3,  2002,  the  applicant’s  then  current  supervisor  wrote  to  the  Board  of 
Officers  in  his  endorsement  that  the evidence against the applicant is “indicative of a 
pattern of inappropriate if not predatory behavior vice a one-time lapse of judgment.  It 
is  particularly  troublesome  since  the  members  involved  were  all  junior  enlisted  crew 
aboard  the  [cutter]  and  [the  applicant]  is  married….  As  such,  the  behavior  calls  into 
question  the  moral  qualifications  required  of  a  commissioned  officer  as  described  in 
Title 14.”  The supervisor concluded that although he was happy to have the applicant 
as a member of his staff, he agreed with the CO’s assessment that the applicant’s “effec-
tiveness as an officer has been irreparably damaged and he has very limited potential 
for future service.” 

 
On June 24, 2002, the Board of Officers met and reviewed the applicant’s record 
to determine whether to recommend to the Commandant that his temporary commis-
sion be vacated.  The Board of Officers recommended that his commission be vacated.  
On July 25, 2002, the Commandant approved the recommendation.   

 
On  July  29,  2002,  the  applicant  was  informed  that  his  commission  would  be 
vacated as of October 25, 2002.  He was advised that he could apply to reenlist by Sep-
tember 9, 2002, and that, if his reenlistment was approved, he would be reenlisted at a 
pay grade no lower than the one he held prior to his appointment as a temporary offi-
cer.  On October 26, 2002, the applicant was reenlisted.  He is currently serving aboard a 
different cutter as a chief petty officer. 

VIEWS OF THE COAST GUARD 

 

 
 
On February 15, 2005, the Judge Advocate General (JAG) of the Coast Guard sub-
mitted an advisory opinion recommending that the Board deny the applicant’s request 
for lack of proof and merit. 
 
 
The JAG stated that the applicant’s command “properly followed [Coast Guard] 
regulations” in awarding the applicant NJP and that the collateral consequences of the 
NJP—including the disputed OER and the revocation of his temporary commission— 
“were carried out properly after affording Applicant all the due process rights to which 
he was entitled.” 
 
 
The JAG stated that under Article 15 of the UCMJ, NJP is a means for COs to deal 
with  minor  violations  promptly  and  administratively  and  thus  preserve  discipline 
“without  the  stigma  of  a  court  martial  (i.e.  criminal)  conviction.”    He  argued  that  in 
reviewing  any  NJP,  the  Board  should  “recognize  that  the  commanding  officer  is  the 
official  responsible  under  statute  and  regulation  for  conducting  the  proceedings  and 
determining an appropriate punishment.”  The JAG stated that the applicant’s CO had 

the opportunity to see both his demeanor and that of the witnesses during the mast and 
that the CO’s findings are “therefore entitled to substantial deference.”  He stated that 
the applicant failed to submit any evidence to overcome the presumption that his CO 
acted “correctly, lawfully, and in good faith.”  Arens v. United States, 969 F.2d 1034, 1037 
(1992); Sanders v. United States, 594 F.2d 804, 813 (Ct. Cl. 1979).  He further argued that 
“[a]bsent proof that the [CO’s] determinations were clearly erroneous, or that a substan-
tial right of Applicant was materially prejudiced by clear procedural error, the [CO’s] 
decision should be upheld.”  He further argued that even if the applicant proved a pro-
cedural  or  administrative  error,  “he  would  still  not  be  entitled  to  relief  on  that  basis 
alone.  Under regulations established by the President, non-compliance with any of the 
procedural  provisions  for  imposing  non-judicial  punishment  does  not  invalidate  a 
punishment unless the error materially prejudiced a substantial right of the applicant.” 
 
 
The  JAG  pointed  out  that  the  applicant  admitted  to  committing  numerous 
offenses under the UCMJ at mast and appealed only the proportionality of his punish-
ment.    The  JAG  argued  that  because  in  his  appeal  of  the  NJP,  the  applicant  “did  not 
dispute  the  legality  of  the  NJP  proceeding  or  the  basis  for  finding  he  committed  the 
charged  misconduct,”  the  Board  should  deem  these  issues  waived  “absent  proof  of 
compelling circumstances that prevented the Applicant from raising such issues within 
the military justice system.”  Moreover, the JAG pointed out, the Area Commander who 
reviewed the applicant’s appeal considered sua sponte whether the NJP was unjust and 
determined that it was not. 
 
 
The JAG stated that the applicant’s argument that he did not sexually harass his 
subordinates  is  misplaced  because  sexual  harassment  per  se  is  not  a  violation  of  the 
UCMJ and was not one of the charges at his mast.  Therefore, the “assertion of error … 
has  no  application  to  Applicant’s  NJP.”    The  JAG  further  stated  that  although  sexual 
harassment  was  not  one  of  the  charges  at  mast,  the  CO  “reasonably  characterized 
Applicant’s conduct as sexual harassment” in the disputed OER. 
 
 
The JAG stated that a member has no right to legal counsel at mast.  Moreover, 
he pointed out, the applicant submitted no evidence to support his allegation that the 
CO refused to allow him to be represented by an attorney and did not mention the issue 
in  his  appeal  and  therefore  failed  to  overcome  the  presumption  of  regularity  on  this 
issue.  The JAG argued that even assuming arguendo that the CO “did improperly deny 
Applicant the right to a spokesperson, this would still not afford Applicant any right to 
relief.  The right to have a spokesperson is not a material right and a command does not 
have to postpone a NJP proceeding to allow for the attendance of a spokesperson.  Id.  
In accordance with the orders of the President, failure to comply with any of the proce-
dural  provisions  for  NJP  proceedings  isn’t  grounds  for  invalidating  a  punishment 
unless the error materially prejudiced a substantial right of the servicemember.” Man-
ual  for  Courts-Martial  (MCM),  Part  V,  Para.  1h.    The  JAG  stated  that  the  role  of  a 
spokesperson at mast is “severely limited” and stated that since the applicant admitted 

to the charges “[i]t is hard to imagine how the presence of a spokesperson would have 
changed the outcome of the NJP.” 
 
Finally, the JAG argued that the applicant’s assertion that he should have had the 
 
right to refuse NJP because he had been transferred from the cutter on TAD at the time 
of the mast “is simply false as a matter of law.”  See, e.g., St. Clair v. Secretary of Navy, 155 
F.3d 848 (7th Cir. 1998); Bennett v. Tarquin, 466 F. Supp. 257 (D. Haw. 1979). 

APPLICANT’S RESPONSE TO THE VIEWS OF THE COAST GUARD 

 

 

 

On February 16, 2005, the BCMR sent the applicant a copy of the Coast Guard’s 
views and invited him to respond within 30 days.  He requested and was granted a 42-
day extension of the time to respond.  His response was received on April 29, 2005. 

 
The applicant argued that the purported purpose of NJP to preserve good order 
and discipline by promptly dealing with minor infractions was not fulfilled in his case 
since he had been removed from the cutter for 41 days by the time his mast was held.  
Moreover, he argued, in Robinson v. Dalton 45, F. Supp. 2d 1 (D.D.C. 1998), the Board for 
Correction  of  Naval  Records  removed  an  officer’s  letter  of  reprimand  when  he  was 
taken to mast without an opportunity to request court-martial even though he had been 
transferred TAD to a shore unit. 

 
Regarding his failure to refute the charges at mast, the applicant alleged that his 
mast representative “directed” him to admit to the charges and that he “felt pressured 
into not defending” himself.  Regarding his request for a spokesperson, the applicant 
alleged that it was verbal and that after denying his request, the CO scheduled the mast 
for the next day, so the applicant had no time to submit a formal written request. 

 
Finally,  the  applicant  stated  that  “it  was  readily  apparent  before  I  was  ever 
placed on report that the [CO] had already determined the outcome of the investigation 
against  me.    After  I  was  assigned  [TAD]  to  a  shore  unit,  the  Command  held  several 
‘closed door’ meetings with all females on board the ship to obtain statements against 
me.  While I understand the need for Commanding Officer’s NJP, there must be some 
sense  of  impartiality  and  undue  influence  [sic]  on  the  investigation.    Therefore,  I  feel 
that my right to due process was violated by failing to provide me with the opportunity 
to consult with my counsel and request courts-martial in lieu of NJP.” 

SUPPLEMENTAL ADVISORY OPINION 

 
 
On June 21, 2005, the BCMR staff asked the Coast Guard to address the following 
factual and legal issues raised in the case: (1) what date the applicant received TAD or 
permanent transfer (PCS) orders to a new post; (2) whether the applicant continued to 
do any work for the cutter after he was removed from it; (3) whether the mast was held 
and the Punitive Letter of Reprimand was delivered on the cutter; and (4) whether the 

applicant’s circumstances met the criteria for when a military service may deny a mem-
ber the right to refuse NJP and demand trial by court-martial enunciated in United States 
v. Edwards, 46 M.J. 41 (C.A.A.F. 1997)—i.e., whether the “vessel exception” applied to 
him.  The BCMR staff noted that in Edwards, the court indicated that the vessel excep-
tion  to  the  right  to  refuse  NJP  and  demand  court-martial  should  be  interpreted  very, 
very narrowly so as to apply to only those members who are (a) actually serving aboard 
the vessel when the mast (not the misconduct) occurs, (b) in the immediate vicinity and 
in the process of boarding the vessel when the mast occurs, or (c) AWOL but attached to 
a vessel in a foreign port.4 
 
On June 29, 2005, the JAG responded to the BCMR’s request.  The JAG stated that 
 
no orders could be found to show that the applicant transferred TAD from the cutter.  
Instead,  the  JAG  alleged,  the  applicant’s  CO  received  permission  from  his  chain  of 
command to send the applicant to work at a shore unit “because of the serious nature of 
the  offenses  and  the  hostile  work  environment  created  aboard  the  [cutter].  …  At  all 
relevant  times  Applicant  was  assigned  [on  a  permanent  basis]  to  the  [cutter]  and 
received  career  sea  pay  and  he  was  credited  with  sea  duty  until  permanently  reas-
signed.”  In support of these allegations, the JAG submitted a copy of the applicant’s 
orders  dated  February  20,  2002,  which  show  that  he  was  transferred  on  a  permanent 
basis from the cutter to a shore unit as of March 20, 2002, and copies of the applicant’s 
Leave and Earnings Statements, which show that he received sea pay until March 20, 
2002.  The JAG also submitted an affidavit from the XO of the cutter, who stated that the 
applicant  was  “expedited”  off  the  cutter  to  maintain  good  order  and  discipline  and 
because three female crewmembers “expressed a credible fear of harassment from him.”  
He stated that the applicant returned to the cutter at least twice thereafter, under escort, 
either for work or to remove personal items. 
 
The JAG stated that after being sent ashore, the applicant did not work directly 
 
for the cutter.  The JAG stated, however, that the mast was held and the Punitive Letter 
of  Reprimand  was  awarded  to  the  applicant  on  board  the  cutter,  as  indicated  in  the 
CO’s endorsement of the applicant’s appeal of his NJP. 
 
The JAG argued that the decisions in St. Clair v. Secretary of Navy, 155 F.3d 848 
 
(7th Cir. 1998), and Bennet v. Tarquin, 466 F. Supp. 257 (D. Haw. 1979), support the Coast 
Guard’s position that the applicant could be denied the right to refuse NJP because he 
had not been transferred TAD, was still permanently assigned to the cutter at the time 
of the mast, and was still drawing sea pay.  The JAG also pointed out the CO of the cut-
ter was “the sole interest in good order and discipline in this matter because the offense 
occurred aboard the vessel and involved members of the crew.”  The JAG also argued 
that  the  NJP  would  have  been  proper  even  if  the  applicant  had  been  assigned  TAD 
because Coast Guard regulations permit NJP either by the CO of the member’s perma-
nent unit or by the CO of the temporary duty station. 

                                                 
4 United States v. Edwards, 46 M.J. 41, 45 (C.A.A.F. 1997) (hereinafter “Edwards”). 

 
The JAG argued that the decision in Edwards is not directly applicable to this case 
 
because the court in Edwards was deciding whether the NJP should be admissible evi-
dence  in  another  proceedings,  not  whether  the  NJP  itself  was  proper.    Moreover,  the 
JAG pointed out, in Edwards, the court looked to the factors analyzed in a previous case, 
United  States  v.  Yatchak,  35  M.J.  379  (C.M.A.  1992),  to  determine  the  meaning  of  the 
phrase  “attached  to  or  embarked  on  a  vessel.”    The  JAG  stated  that  those  factors 
included  where  the  mast  was  held,  where  the  accused  was  assigned,  the  operational 
status of the vessel, and where the sentence was served.  The JAG noted that in Edwards, 
the court cited the following as factors relevant in the determination of a member’s rela-
tionship to a vessel:  “whether he lived aboard, performed duties aboard, was adminis-
tered [NJP] aboard, or served his punishment aboard.”  The JAG argued that because 
the applicant was permanently assigned to and physically on the cutter at the time of 
the misconduct and the NJP, the “vessel exception” applied to him.  The JAG argued 
that the fact that the applicant was sent ashore during the investigation because of the 
hostile  work  environment  he  had  created  for  female enlisted personnel did not mean 
that the vessel exception did not apply. 
 
 
Finally,  the  JAG  stated  that  the  applicant’s  NJP  “is  not  relevant  to  either  [his] 
OER  or  the  revocation  of  his  commission.    [He]  engaged  in  serious  misconduct.    His 
misconduct had three separate consequences—NJP, a derogatory OER, and revocation 
of his commission.  The derogatory OER and decision to revoke [his] commission are a 
direct result of his actions, not his NJP.” 
 

APPLICANT’S RESPONSE TO THE SUPPLEMENTAL ADVISORY OPINION 

 
 
On July 5, 2005, the JAG’s supplemental advisory opinion was faxed to the appli-
cant.  He responded on July 11, 2005.  Along with his response, he submitted a copy of 
TAD  orders  showing  that  on  August  23,  2001,  he  was  reassigned  TAD  “for 
approx[imately] 22 days” to a shore unit on August 24, 2001.  Initially, while TAD, the 
applicant  worked  on  an  xxxxxxxxxxxx  Instruction,  but  after  September  11,  2001,  he 
worked on xxxxxxxxxxxxxxxxxx.  In September, the XO told him that he was to remain 
TAD ashore indefinitely and did not allow him on the cutter except once to remove his 
personal effects.  On September 30, 2001, the applicant stated, he received a telephone 
call  ordering  him  to  appear  on  the  cutter  the  next  day  at  10:00  a.m.  for  the  mast.  
Therefore, he argued, under Edwards, the vessel exception did not apply to him because 
he had been working TAD ashore for 39 days when his mast occurred and so none of 
the criteria provided in the Edwards decision for when the vessel exception should apply 
were met. 
 

The applicant stated that when he received his permanent orders in March 2002, 
his unit and duties did not change.  Regarding sea pay, he pointed out that according to 
the Pay Manual, his eligibility for sea pay should have ended after he was TAD from 

the cutter for 30 days.  Therefore, he argued, if he continued to receive sea pay, it was 
an administrative oversight and irrelevant to this case. 
 
The applicant argued that contrary to the JAG’s statement, his NJP was relevant 
 
to both the derogatory OER and the revocation of his commission.  He alleged that he 
received the derogatory OER because of the NJP and that it was because of the NJP ref-
erenced in the OER that his commission was revoked.  He argued that if the NJP and 
derogatory OER had not happened, his commission would not have been revoked. 
 

APPLICABLE LAW 

 
UCMJ 
 
 
Under  Article  134,  any  officer  who  fraternizes  “on  terms  of  military  equality” 
with a person the officer knows to be an enlisted member in a way that “violated the 
custom” of the officer’s service to the “prejudice of good order and discipline” or that 
“was of a nature to bring discredit upon the armed forces” may be charged with frater-
nization.    MCM,  Part  IV,  Para.  60.    Under  Article  80  of  the  UCMJ,  any  member  who 
commits  an  “act,  done  with  specific  intent  to  commit  an  offense  under  [the  UCMJ], 
amounting to more than mere preparation and tending, even though failing, to effect its 
commission” may be charged with attempt.  MCM, Part IV, Para. 4. 
 
 
Article 133 of the UCMJ provides that “conduct unbecoming an officer and gen-
tleman” is any “action or behavior in an official capacity which, in dishonoring or dis-
gracing the officer’s character as a gentleman, or action or behavior in an unofficial or 
private  capacity  which,  in  dishonoring  or  disgracing  the  officer  personally,  seriously 
compromises the person’s standing as an officer.  MCM, Part IV, Para. 59. 
 
 
Article  92  of  the  UCMJ  provides  that  members  who  disobey  a  lawful  general 
order  or  regulation  or  who  are  derelict  in  the  performance  of  known  duties  may  be 
charged under this article.  MCM, Part IV, Para. 16. 
 
 
 
Under  Article  15  of  the  UCMJ,  commanding  officers,  at  their  discretion,  may 
impose  NJP  for  minor  violations  of  the  UCMJ  to  maintain  good  order  and  discipline 
when  administrative  corrective  measures  seem  inadequate  and  court-martial  seems 
excessive.  MCM, Part V, Para. 1.d.(1).  “[E]xcept in the case of a person attached to or 
embarked in a vessel, punishment may not be imposed upon any member of the armed 
forces under [Article 15] if the member has, before the imposition of [NJP], demanded 
trial by court-martial in lieu of [NJP].”  10 U.S.C. § 815(a).  “A person is ‘attached to’ or 
‘embarked  in’  a  vessel  if,  at  the  time  [NJP]  is  imposed,  that  person  is  assigned  or 
attached  to  the  vessel.”    MCM,  Part  V,  Para.  3.    If  a  member  exercises  his  right  to 
demand trial by court-martial, the NJP is terminated and it “is within the discretion of 
the commander whether to forward or refer charges for trial by court-martial.  MCM, 
Part V, Para. 4.b.(1).  However, “[f]ailure to comply with any of the procedural provi-

sions of Part V of this Manual shall not invalidate a punishment imposed under Article 
15,  unless  the  error materially prejudiced a substantial right of the servicemember on 
whom the punishment was imposed.”  MCM, Part V, Para. 1.h. 
 
Military Justice Manual 
 
 
Chapter 1 of the Military Justice Manual (MJM) contains the Coast Guard’s regu-
lations governing NJP, which is a non-adversarial, administrative procedure that does 
not result in a criminal conviction as does a court-martial.  Chapter 1.B.4. provides that 
members must be given notice of the charges against them and informed of their rights.    
Chapter 1.B.5.f. provides that a “member attached to or embarked in a vessel does not 
have the right to demand trial by court-martial in lieu of NJP.”  Chapter 1.A.4.b. states 
that  “NJP  may  be  imposed  upon  TAD  personnel  by  the  commanding  officer  of  the 
member's permanent unit, or by the commanding officer of the unit to which the mem-
ber is temporarily assigned.  A member should not be assigned TAD from a shore unit 
to a vessel for the primary purpose of thwarting the member's right to demand trial by 
court-martial in lieu of NJP.” 

 
Under Chapters 1.C.3.a. and 1.B.3.b., the XO should appoint an officer of the unit 
of  the  CO  conducting  the  mast  to  serve  as  a  “mast  representative”  for  the  accused.  
Under  Chapter  1.C.3.a.,  the  role  of  the  mast  representative  is  to  “assist the member in 
preparing for and presenting his or her side of the matter and to speak for the member, if the 
member desires.  It is Coast Guard policy that the mast representative may question witnesses, 
submit questions to be asked of witnesses, present evidence, and make statements inviting the 
commanding officer's attention to those matters he or she feels are important or essential to an 
appropriate disposition of the matter.” 

 
Chapter 1.C.1. states that because a mast is not an adversarial proceeding, a member “has 
no  right  to  be  represented  by  an  attorney  at  mast.”    However,  “the  member  may  obtain  the 
services of an attorney or any other person, at no expense to the government, to appear as his or 
her spokesperson.”  Chapter 1.C.4.b. states that a spokesperson, “at the member's election, 
speaks for him or her at those times during the mast when the member's responses are 
invited  by  the  commanding  officer.    A  spokesperson  may  be  anyone,  including  an 
attorney retained by the member.”  Chapter 1.C.4.c. states that the CO “may not exclude 
the  spokesperson  from  the  mast  solely  because  he  or  she  is  an  attorney.”    Chapter 
1.C.4.e. provides that a “spokesperson is not permitted to examine or cross-examine witnesses,” 
except at the discretion of the CO, but “is always permitted to speak for a member when the 
member is otherwise entitled to speak.” 

 
Chapter 1.E. provides that the maximum punishment a captain (O-6) may impose on a 
subordinate officer at mast is an admonition or reprimand and 30 days of restriction.  Chapter 
1.E.2.a. states that a “reprimand is a more severe form of censure than an admonition” and that 
the admonition or reprimand of a commissioned officer “must be administered in writing.” 

 

Chapter 1.F.1. provides that a member may appeal an NJP “if he or she considers 
the  punishment  imposed  ‘unjust’  or  ‘disproportionate’  to  the  acts  of  misconduct  for 
which punished … in writing within 5 calendar days of the imposition of the punish-
ment.”    Chapter  1.F.1.a.  defines  “unjust”  to  include  various  kinds  of  illegality  and 
denial of rights but does not expressly mention an erroneously denied right to demand 
trial by court-martial. 
 
Regulations Concerning Personal Relationships and Sexual Harassment 
 
 
Article 8.H. of the Personnel Manual concerns inappropriate relationships among 
Coast  Guard  personnel.    Article  8.H.1.c.  states  that  “[p]rofessional  interpersonal  rela-
tionships always acknowledge military rank and reinforce respect for authority.”  Arti-
cle  8.H.2.c.,  entitled  “Acceptable  Personal  Relationships,”  states  that  “Service  custom 
recognizes  that  personal  relationships,  regardless  of  gender,  are  acceptable  provided 
they do not, either in actuality or in appearance: 1. Jeopardize the members' impartial-
ity, 2. Undermine the respect for authority inherent in a member's rank or position, 3. 
Result in members improperly using the relationship for personal gain or favor, or 4. 
Violate a punitive article of the UCMJ.”  Article 8.I.2.b. states that in response to sexual 
harassment, COs may avail themselves of discrimination complaint processes, adminis-
trative processes and UCMJ provisions.  These actions are not mutually exclusive and 
two or all three of them may be pursued simultaneously.” 

 
Chapter  1  of  the  Coast  Guard  Equal  Opportunity  Program  Manual  (COMDT-
 
INST 5350.4), issued in March 1999, requires annual training on sexual harassment for 
all members.  Enclosure 1 to Chapter 1 provides the Commandant’s Sexual Harassment 
Policy  Statement  and  states  that  sexual  harassment  “includes  unwelcome  sexual 
advances,  requests  for  sexual  favors  and  other  verbal  or  physical  conduct  of  a  sexual 
nature that is made a condition of employment, affects employee decisions, unreason-
ably interferes with work performance or creates an intimidating or hostile work envi-
ronment. …  Every Commanding Officer … must hold accountable those who commit 
sexual  harassment  and  take  immediate  corrective  action.”    Enclosure  18  to  Chapter  5 
provides  examples  of  offenses  of  sexual  harassment,  including  making  offensive 
remarks about appearance, body, or sexual activities; body language, staring, leering, or 
ogling  that  makes  one  feel  uncomfortable;  attempts  to  establish  a  sexual  relationship; 
and making continual requests for dates even though the respondent says “no.” 
 
Officer Evaluation Reports  
 

Article 10.A.4.c.4. of the Personnel Manual instructs supervisors to assign marks 
and write comments for the first thirteen performance categories on an OER as follows 
(nearly  identical  instructions  appear  in  Article  10.A.4.c.7.  for  reporting  officers,  who 
complete the rest of the OER): 
 

b.    For  each  evaluation  area,  the  Supervisor  shall review the Reported-on Officer's per-
formance and qualities observed and noted during the reporting period.  Then, for each 

of  the  performance  dimensions,  the  Supervisor  shall  carefully  read  the  standards  and 
compare the Reported-on Officer's performance to the level of performance described by 
the standards. … After determining which block best describes the Reported-on Officer's 
performance and qualities during the marking period, the Supervisor fills in the appro-
priate circle on the form in ink. 

•   •   • 

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

 

Article 10.A.4.f.1. prohibits a rating chain from mentioning that an “officer’s con-
duct  is  the  subject  of  a  judicial,  administrative,  or  investigative  proceeding,  including 
criminal and non-judicial punishment proceedings under the Uniform Code of Military 
Justice, … except as provided in Article 10.A.3.c. … These restrictions do not preclude 
comments on the conduct that is the subject of the proceeding. They only prohibit refer-
ence to the proceeding itself.” 
 
 
Article 10.A.4.c.8.a. instructs the Reporting Officer to complete the Comparison 
Scale on an OER by filling in the circle that most accurately reflects his or her ranking of 
the Reported-on Officer in comparison to all other officers of the same grade whom the 
Reporting Officer has known. 
 
 
Article 10.A.4.h. states that any OER which contains a numerical mark of 1 in any 
performance category or an “unsatisfactory” mark on the Comparison Scale is deemed 
“derogatory.”  When derogatory OERs are prepared, the reported-on officers must have 
an opportunity to prepare an addendum to the OER “to explain the failure or provide 
their views of the performance in question.”  The rating chain members must endorse 
the addendum by signature and may address the addendum in a written attachment. 
 
Regulations Regarding Vacation of Temporary Commission 
 

Article 12.A.12.b.1. of the Personnel Manual provides that a CO or a superior in 
the chain of command or the Personnel Command may recommend or initiate vacation 
of any temporary officer’s appointment “based on adverse information about the offi-
cer.”  Article 12.A.11.a. states that “[s]ome officers either are unable to adapt to service 
life  or  their performance indicates it is doubtful whether the time and effort required 
will form them into effective officers.”  Article 12.A.11.b. provides that a CO or a supe-
rior in the chain of command may recommend revoking the commission of an officer 
“based on knowledge of adverse information about the officer.”   When this happens, 
“the officer concerned [must have] an opportunity to review the recommendation and 
… comment as desired by letter endorsement.”  Then a panel of senior officers reviews 
the  officer’s  record  and  makes  a  recommendation  to  the  Commandant,  who  may 
approve, disapprove, or modify the recommendation.  
 

FINDINGS AND CONCLUSIONS 

2. 

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 argued that because he had been assigned TAD to a shore 
unit  for  several  weeks  when  he  was  taken  to mast/NJP and the Coast Guard had no 
intention of allowing him to return to his billet on the cutter, he was erroneously denied 
the right provided under 10 U.S.C. § 815(a) (hereinafter “Article 15”) to refuse mast and 
demand trial by court-martial in lieu thereof.  The form the applicant signed regarding 
his rights at mast was a form created specifically for an officer attached to a vessel and 
did  not  include  a  right  to  consult  counsel  about  NJP  or  a  right  to  refuse  NJP  and 
demand  court-martial.    The  JAG  has  indicated  that  the  applicant  was  not  given  the 
option of refusing NJP.  Therefore, the Board finds that the applicant has proved that he 
was not given the right to demand trial by court-martial in lieu of NJP.   Whether he 
was actually entitled to and erroneously denied that right remains to be answered. 
 

3. 

The JAG argued that the Board should consider the issue of whether the 
Coast Guard erred in denying the applicant the right to demand trial by court-martial 
in lieu of NJP to be waived because the applicant did not appeal his NJP based on this 
issue.    However,  the  form  the  applicant  signed  in  acknowledging  his  rights  at  mast 
shows that he was not entitled to consult an attorney about his mast rights.  Therefore, 
it is not clear how he could have known he should appeal the NJP on this basis, even if 
he knew that other members under other circumstances had been given this right.  Fur-
thermore,  Congress  provided  that  members  should  have  at  least  three  years  to  seek 
relief from an error or injustice via the BCMR,5 and section 205 of the Soldiers’ and Sail-
ors’ Civil Relief Act of 1940 “tolls the BCMR’s limitations period during a servicemem-
ber’s  period  of  active  duty.”6    Although  the  Board’s  rules  do  require  applicants  to 
exhaust available administrative and legal remedies prior to applying to the Board,7 the 
Coast  Guard  has  limited  the  right  to  appeal  NJP  to  within  five  days  of  imposition.8  
Therefore, the remedy is no longer available to the applicant, and deeming him to have 
waived the issue would in effect negate Congress’s determination of how long an active 
duty member should have to seek relief from this Board.  Moreover, under the circum-
stances of this case, the Board is not persuaded that, without counsel, the applicant can 
be considered to have intentionally conceded the right to refuse NJP when submitting 

                                                 
5 10 U.S.C. § 1552(b). 
6 Detweiler v. Pena, 38 F.3d 591, 598 (D.C. Cir. 1994). 
7 33 C.F.R. § 52.13. 
8 Military Justice Manual, Chap. 1.F.1. 

4. 

 

a. 

his  appeal.    Therefore,  the  Board  finds  that  the  applicant  did  not  waive  this  issue  in 
failing to mention it in his appeal.  
 
The JAG argued that denying the applicant the right to refuse NJP was not 
 
an  error  because  of  the  “vessel  exception”  in  Article  15,  which  denies  members 
“attached to or embarked in a vessel” the right to demand trial by court-martial in lieu 
of NJP.  The JAG argued that the vessel exception applied to the applicant because (a) 
the misconduct was committed aboard the cutter and the CO of the cutter was “the sole 
interest in good order and discipline in this matter because the offense occurred aboard 
the vessel and involved members of the crew”; (b) at the time of the mast, the applicant 
was  still  “assigned  or attached to” the cutter, pursuant to Part V, Paragraph 3, of the 
Manual  for  Courts-Martial,  since  the  Coast  Guard  had  not  issued  transfer  orders  to 
make official that which it had done in fact (reassigning the applicant to work at a shore 
unit);  and  (c)  the  applicant  was  brought  back  on  board  the  cutter  to  attend  the  mast.  
These arguments are addressed below: 
 
 
An important purpose of NJP under Article 15 is to enable the CO 
of a vessel to maintain “good order and discipline.”9  Therefore, the logic of allowing 
the  CO  of  a  vessel  to  exert  his  “interest”—as  the  JAG  called  it—and  conduct  NJP  for 
offenses  committed  aboard  the  vessel  is  clear.    However,  the  same  interest  and  logic 
would apply to every CO in every military unit whether on a vessel or not, and yet in 
Article 15 Congress and the President have given the vast majority of military members 
the right to refuse their CO’s NJP and demand trial by court-martial.  In enacting the 
vessel exception, Congress intended “all military members [to have] a right to demand 
trial in lieu of nonjudicial punishment except ‘in some cases where a ship is at sea.’”10  
In deciding whether the vessel exception should apply, the law looks not to the mem-
ber’s assignment and location at the time of the misconduct, but to his assignment and 
location at the time of the NJP.11  Although the applicant was ordered aboard the cutter 
under escort for his mast on October 1, 2001, he had been assigned TAD for more than 
five weeks to a shore unit under a different command, which also had authority to offer 
him NJP.12  Therefore, whether he had a right to demand trial by court-martial in lieu of 
NJP  hinged  not  on  where  the  offenses  took  place  nor  on  who  was  his  CO  when  he 
committed  the  offenses  but  on  whether  he  was  still  “attached  to  or  embarked  in” 
(according to UCMJ Article 15) or “assigned or attached to” (according to the Part V, 
Para. 3, of the Manual for Courts-Martial) the cutter by October 1, 2001, at which time 
he  had  not  worked  on  the  cutter  for  five  weeks.    The  CO’s  interest  in  punishing  the 
applicant aboard the cutter without convening a court-martial may not trump the appli-

                                                 
9 Manual for Courts-Martial, Part V, Para.1.d.(1). 
10 Edwards, at 44 (citing 108 CONG. REC. 17,560 (1962)). 
11 MCM, Part V, Para. 3; see also Robinson v. Dalton, 45 F. Supp. 2d 1, 2-3 (D.D.C. 1998); St. Clair v. Sec’y of 
the Navy, 155 F.3d 848, 853 (7th Cir. 1998); United States v. Edwards, 43 M.J. 619, 621 (N-M.C.C.C.A. 1995), 
rev’d on other grounds, Edwards v. United States, 46 M.J. 41, 44 (C.A.A.F. 1998). 
12 Military Justice Manual, Chap. 1.A.4.b. 

 

b. 

cant’s right to demand trial by court-martial unless he was still “assigned or attached 
to” or “embarked in” the cutter within the meaning of the law on October 1, 2001. 
 
The JAG argued that the applicant was still “assigned or attached 
 
to” the cutter on October 1, 2000, because the Coast Guard had not yet issued orders to 
transfer him to another unit, even though he had worked at the shore unit for several 
weeks and the Coast Guard had no intention of allowing him to return to his billet on 
the  cutter.    The  applicant  has  produced  a  copy  of  the  TAD  orders  by  which  he  was 
assigned  off  the  cutter on August 24, 2001.  According to the record, the TAD orders 
were originally issued for “approximately” 22 days, but the XO told the applicant they 
were  extended  indefinitely,  and  no  other  orders  were  issued  until  February  20,  2002.  
The  JAG’s  argument  about  orders  would  allow  the  Coast  Guard  to  apply  the  “vessel 
exception”  to  any  member  who  had  recently  worked  on  a  cutter  simply  by  delaying 
issuing the orders that would make official a de facto transfer to a shore unit and by con-
tinuing to pay the member sea pay, contrary to regulation,13 as it did in the applicant’s 
case.  Moreover, in United States v. Yatchak, 35 M.J. 379 (C.M.A. 1992), the court found 
that the respondent was not “attached to or embarked in a vessel” even though he was 
a crewmember of the ship.14  Also, in St. Clair v. Secretary of the Navy, 155 F.3d 848 (7th 
Cir.  1998),  the  court  concluded  that  the  appellant  was  “attached  to”  the  vessel,  even 
though  he  was  confined  to  barracks  ashore,  because  “the  Navy  did  not  reassign  him 
until January 24, 1992, when it placed him on temporary duty.”15  Therefore, since the 
applicant had been reassigned TAD for several weeks at the time of his mast, the fact 
that he was officially still a crewmember of the cutter because the Coast Guard did not 
issue permanent transfer orders until several months after his removal from the cutter 
does not prove per se that he was still attached to the cutter for the purpose of Article 15 
by October 1, 2001. 
 
In Edwards v. United States, 46 M.J. 41 (C.A.A.F. 1998), the appellant 
 
had been denied the right to refuse NJP because he was assigned to a ship, even though 
the ship was undergoing repairs throughout his tour of duty.  The Court of Appeals for 
the Armed Forces stated that in extending the right to refuse NJP (which had previously 
applied only to members of the Army and Air Force) to the members of the Navy and 
Coast  Guard,  “both  Congress  and  the  President  intended  the  ‘vessel  exception’  to  be 
limited to situations such as where service members were [a] aboard a vessel, [b] in the 
immediate vicinity and in the process of boarding, or [c] attached to vessels and absent 

 

c. 

                                                 
13 Coast Guard Pay Manual (COMDTINST M7220.29A), Fig. 4-4, Rule 4, states that when a member on sea 
duty  is  assigned  ashore  TAD,  sea  pay  “accrues  for  30  days  past  the  date  of  the  member’s  departure.” 
Note  4  to  Fig.  4-4  states  that  “sea  pay  and  time  terminates  at  2400  the  30th  actual  day  the  member  is 
TD/TAD away from the career sea pay eligible vessel or ashore at a mobile unit.” 
14 United States v. Yatchak, 35 M.J. 379, 380-81 (C.M.A. 1992).  Although the issue in Yatchak was whether 
the respondent was “attached to or embarked in a vessel” for purposes of whether he could be confined 
on bread and water, this phrase in Article 15(b)(2)(A) has the same meaning as in Article 15(a).  Edwards v. 
United States, 46 M.J. 41, 43 (C.A.A.F. 1998). 
15 St. Clair v. Sec’y of the Navy, 155 F.3d 848, 853 (7th Cir. 1998). 

5. 

without authority in foreign ports.”16  Likewise, in Yatchak, the court stated that “Con-
gress devised the term, ‘attached to or embarked in a vessel,’ to cover those actually at 
sea as well as those in port when their ship is about to depart.”17  None of these circum-
stances applied to the applicant during the five weeks prior to his mast on October 1, 
2001.  Although the applicant was ordered to and did return to the cutter for his mast 
on October 1, 2001, a member who is permanently assigned to a shore unit cannot be 
ordered to a cutter just to impose NJP and deny him the right to demand trial by court-
martial in lieu of mast.18  Therefore, although the applicant did not receive permanent 
transfer orders for several months, the Board is not persuaded that the vessel exception 
applied to him simply because the CO ordered him back to the cutter for the mast. 
 
The JAG argued that the decision in Edwards19 does not directly apply in 
 
this case because the court was not determining the correctness of the NJP itself but was 
deciding  whether  evidence  of  the  NJP  was  properly  used  as  evidence  against  the 
appellant  during  the  sentencing  phase  of  his  trial  by  court-martial  for  a  later  crime.  
However, the court in Edwards acknowledged that its jurisdiction “does not extend to 
direct  review  of  [NJP]  proceedings,”20  but  still  focused  the  entire  decision  not  on  the 
admissibility of evidence but on whether the vessel exception was properly applied to 
the appellant given the meaning of the phrase “attached to or embarked in a vessel” as 
it was intended by Congress and the President.  Furthermore, in Robinson v. Dalton, 45 
F.  Supp.  2d  1  (D.D.C.  1998),  the  court  found  that  the  delegate  of  the  Secretary  of  the 
Navy  had  been  arbitrary  and  capricious  in  failing  to  consider  the  limits  to  the  vessel 
exception provided in Edwards.21  The delegate in Robinson had refused to reconsider an 
application to the Board for Correction of Naval Records (BCNR) to remove a punitive 
letter of reprimand received at NJP by the captain of a ship who had been denied the 
right to refuse NJP and demand trial by court-martial even though by the time NJP was 
imposed, he had been transferred TAD ashore.22  After the court remanded the case to 
the BCNR “for a more fully reasoned explanation” in light of the decision in Edwards,23 
the Navy agreed “to remove the punitive letter of reprimand and all references to that 
letter  and  the  nonjudicial  punishment  proceeding  from  Plaintiff’s  military  personnel 

                                                 
16 Edwards, at 45. 
17 Yatchak, at 381 (citing Uniform Code of Military Justice:  Hearings on H.R. 2498 Before a Subcomm. of 
the  House  Armed  Services  Comm.,  81st  Cong.,  1st Sess. 945-46 (1949), reprinted in Index and Legislative 
History, Uniform Code of Military Justice (1949)). 
18 Military Justice Manual, Chap. 1.A.4.b. 
19 In Edwards, the vessel exception had been applied to the appellant at NJP for an unauthorized absence 
and for carrying a concealed weapon even though his ship, the U.S.S. Constellation, was undergoing reno-
vation during his tour.  Edwards, at 42.  The court found that the NJP was incorrectly admitted as evidence 
during the sentencing phase of a court-martial for a later crime because the vessel exception should not 
have applied to the appellant since the ship was not operational at the time of the NJP.  Id. at 45-46. 
20 Edwards, at 43. 
21 Robinson v. Dalton, 45 F. Supp. 2d 1, 4 (D.D.C. 1998). 
22 Id. at 2-3.   
23 Id. at 4. 

record”  and  to  pay  the  plaintiff’s  attorney’s  fees  “for  the  sole purpose of settling this 
case and for no other reason.”24 
 

6. 

The JAG argued that the applicant was attached to the cutter because in 
St. Clair the court found that the Navy properly applied the vessel exception because 
the appellant was still “attached to” the vessel at the time of his NJP, even though he 
had been restricted to barracks ashore after his arrest.25  However, in St. Clair, the court 
based its finding that the appellant was attached to the vessel on the fact that the Navy 
did not reassign him TAD until several months after the NJP.26  In the instant case, the 
Coast Guard assigned the applicant to a shore unit TAD more than five weeks before 
the NJP.  Therefore, the Board is not persuaded by the decision in St. Clair that the ves-
sel exception was properly applied to the applicant.  Furthermore, the Board notes that 
the decision in St. Clair was issued before the Court of Appeals for the Armed Forces 
narrowly defined the circumstances under which the vessel exception should be applied 
in its decision in Edwards. 

 
7. 

The  JAG  argued  that  the  Board  should  find  that  the  applicant  was 
attached to or assigned to the cutter because of the decision in Bennett v. Tarquin, 466 F. 
Supp. 257 (D. Haw. 1979), wherein the court found that the Navy properly applied the 
vessel exception to crewmembers of a two-crew nuclear submarine who were training 
ashore  in  Hawaii  while  the  other  crew  was  at  sea  in  the  submarine  near  Guam.27    In 
Bennett, the court based the decision on (a) the fact that the plaintiffs’ assignment orders 
indicated that they were still crewmembers on sea duty and sea pay; (b) as part of the 
“off-crew,” they were training for further submarine duty; (c) they were subject to recall 
to and expected to return to duty on the submarine; (d) “[a]t no time does the adminis-
tration of discipline over the off-crew fall upon a person other than the Commanding 
Officer”; and (e) the interpretation of the legislative history of Article 15 in Jones v. Frud-
den, 4 MIL. L. REP. 2606 (N.D. Cal. 1976).28  However, by the time of his NJP, the appli-
cant  had  been  assigned  TAD  to  a  shore  unit,  was  performing  no  work  for  the  cutter, 
was not expected ever to return to duty on the cutter, and was subject to the discipline 
of the shore unit command.29  Moreover, the interpretation of the legislative history of 
Article 15 in Jones v. Frudden was relied on in the lower court’s decision in United States 

                                                 
24  Robinson  v.  Danzig,  Civ.  Act.  No.  98-0467  (JR),  Settlement  Agreement  and  Mutual  Release  (D.D.C. 
February 26, 1999). 
25 St. Clair, at 14. 
26 Id. at 15. 
27 Bennett v. Tarquin, 466 F. Supp. 257, 259 (D. Haw. 1979). 
28 In United States v. Edwards, 43 M.J. 619, 622 (N-M.C.C.C.A. 1995), rev’d, Edwards v. United States, 46 M.J. 
41, 44 (C.A.A.F. 1998), the lower court stated that “[t]he District Court [in Jones v. Frudden, 4 MIL. L. REP. 
2606 (N.D. Cal. 1976)] considered congressional hearings and floor proceedings and found them not to be 
definitive,  noting  that  the  measure  had  not  been  controversial,  and  concluded  that  the  broad  language 
used did not suggest that the exception applied only to ships at sea, or that the ‘unique responsibilities of 
the ship’s captain’ are not present even when the ship is in port.” 
29 Military Justice Manual, Chap. 1.A.4.b. 

v. Edwards, 43 M.J. 619, 622 (N-M.C.C.C.A. 1995),30 and rejected when that decision was 
overturned by the Court of Appeals for the Armed Forces in 1998 based on a very dif-
ferent  interpretation  of  the  legislative  history.31    Furthermore,  as  with  St.  Clair,  the 
Board notes that the decision in Bennett was issued before the Court of Appeals for the 
Armed  Forces  narrowly  defined  the  circumstances  under  which  the  vessel  exception 
should be applied in its decision in Edwards.  Therefore, the Board is not persuaded by 
the decision in Bennett that the vessel exception was properly applied to the applicant. 

 
8. 

In  Yatchak,  the  Court  of  Military  Appeals  found  that  “Congress  devised 
the term, ‘attached to or embarked in a vessel,’ [in Article 15] to cover those actually at 
sea as well as those in port when their ship is about to depart.”32  In St. Clair, the Court 
of Appeals for the Seventh Circuit concluded that the appellant was “attached to” the 
vessel because “the Navy did not reassign him until January 24, 1992, when it placed 
him  on  temporary  duty.”33    In  Edwards,  the  Court  of  Appeals  for  the  Armed  Forces 
stated that “both Congress and the President intended the ‘vessel exception’ to be limit-
ed  to  situations  such  as  where  service  members  were  [a]  aboard  a  vessel,  [b]  in  the 
immediate vicinity and in the process of boarding, or [c] attached to vessels and absent 
without  authority  in  foreign  ports.”34    In  addition,  the  court  in  Edwards  held  that  the 
appellant’s relationship to the ship at the time of his NJP depended upon such factors as 
“whether he lived aboard, performed duties aboard, was administered [NJP] aboard, or 
served his punishment aboard.”35  The record is clear that at the time of his mast, the 
applicant had neither lived nor performed duties aboard the cutter for more than five 
weeks, he had been assigned TAD to a shore unit, and there was no expectation that he 
would ever return to his billet on the cutter.  He was ordered back to the cutter just to 
attend  the  mast  under  escort.    The  cutter’s  CO  could  issue  this  order  because,  in  the 
absence  of  permanent  transfer  orders,  the  cutter  was  still  the  applicant’s  permanent 
duty station.  However, in Yatchak, Edwards, and Robinson, the fact that the plaintiffs/ 
appellants were permanently assigned to vessels when NJP was imposed was not dis-
positive of the issue of whether they were “attached to” the vessels for the purpose of 
the vessel exception.  And in St. Clair, the court indicated that TAD orders would have 
been sufficient to sever the attachment.36  Therefore, the Board finds that that by Octo-
ber 1, 2001, the applicant was no longer assigned to, attached to, nor embarked on the 
cutter for the purposes of Article 15, in accordance with the meaning given those terms 
in  Yatchak,  St.  Clair, and Edwards, and he was erroneously denied the right to consult 
with counsel concerning NJP and to demand trial by court-martial in lieu of NJP.   
                                                 
30 United States v. Edwards, 43 M.J. 619, 622 (N-M.C.C.C.A. 1995), rev’d, Edwards v. United States, 46 M.J. 41, 
44 (C.A.A.F. 1998).  See footnote 28, above. 
31 Edwards v. United States, 46 M.J. 41, 44-45 (C.A.A.F. 1998). 
32 Yatchak, at 381 (citing Uniform Code of Military Justice:  Hearings on H.R. 2498 Before a Subcomm. of 
the  House  Armed  Services  Comm.,  81st  Cong.,  1st Sess. 945-46 (1949), reprinted in Index and Legislative 
History, Uniform Code of Military Justice (1949)). 
33 St. Clair, at 853. 
34 Edwards, at 45. 
35 Edwards, at 46. 
36 St. Clair, at 853. 

 

9. 

10. 

The applicant argued that, because he sought and was erroneously denied 
the right to demand trial by court-martial in lieu of NJP, the record of the NJP and the 
Punitive Letter of Reprimand should be removed from his record.  The JAG argued that 
a  “failure  to  comply  with  any  of  the  procedural  provisions  for  NJP  proceedings  isn’t 
grounds for invalidating a punishment unless the error materially prejudiced a substan-
tial right of the servicemember.”37  Although the applicant ultimately pled guilty to the 
charges at mast, the Board finds that his right to refuse NJP and demand trial by court-
martial  was  a  substantial  right  that  was  materially  prejudiced  by  the  Coast  Guard.  
Accordingly, the record of the NJP, the Punitive Letter of Reprimand that he received as 
punishment at NJP, and any other mention of the NJP or Punitive Letter of Reprimand 
should be removed from his record. 
 
 
The applicant alleged that the NJP was unjust because his CO refused to 
allow him to use an attorney as his spokesperson at mast and because he was coerced 
into  pleading  guilty  at  mast.    He  submitted  no  evidence  to  support  these  allegations.  
Moreover, in light of finding 9 above, the Board need not address these issues.  For the 
same reason, his allegation that he should not have been charged with and found guilty 
of  misusing  the  email  system  at  mast  since  the  command  could  find  no  user  form 
regarding Coast Guard email policy with his signature on it need not be addressed. 
 
 
The  applicant  alleged  that  the  disputed  OER  improperly  describes  his 
offenses  as  “sexual  harassment”  and  should  be  removed  from  his  record  because  the 
poor marks and comments are based on the unjust NJP.  However, he has not proved 
that the investigation into his misconduct was erroneous.  His rating chain was entitled 
to base marks and comments in the OER on the information discovered in the investi-
gation whether or not the NJP occurred.38  Article 8.I.2.b. of the Personnel Manual states 
that commands may respond to allegations of sexual harassment with “discrimination 
complaint processes, administrative processes and UCMJ provisions.  These actions are 
not mutually exclusive and two or all three of them may be pursued simultaneously.”  
The  applicant’s  command  responded  to  the  emails  an  enlisted  female  crewmember 
complained about to her supervisor with administrative processes (TAD transfer, inves-
tigation, derogatory OER) and with NJP under Article 15 of the UCMJ.  
 

11. 

12. 

Enclosure 18 to Chapter 5 of the Equal Opportunity Employment Manual 
states that “sexual harassment” may include making offensive remarks about appear-
ance,  body,  or  sexual  activities;  body  language,  staring,  leering,  or  ogling  that  makes 
one feel uncomfortable; attempts to establish a sexual relationship; and making contin-
ual requests for dates even though the respondent says “no.”  The evidence gathered in 
the investigation includes descriptions not only of these sorts of behavior but of a pat-
tern of such behavior by the applicant, which the rating chain reasonably relied on to 

                                                 
37 Manual for Courts-Martial, Part V, Para. 1.h. 
38 Coast Guard Personnel Manual (COMDTINST M1000.6A), Arts. 10.A.4.c.4.d., 10.A.4.c.7.d., 10.A.4.f.1. 

use the term “sexual harassment” in the OER.  Although the applicant now attempts to 
retract his guilty pleas and argue that he was not seeking a sexual relationship or creat-
ing an intimidating or hostile work environment, the preponderance of the evidence in 
the record shows that he was fishing for a sexual, inappropriate relationship with sub-
ordinate  enlisted  members  of  his  command.    In  particular,  the  Board  notes  his  email 
conversation with YN3 B in which he invited her to a party, told her that he’d rather not 
“behave” that night, told her that he had a hotel room reserved, and then—even though 
he realized that she had quickly maneuvered to ensure she would be on duty the night 
of the party so as to avoid his party—pressed the issue by saying that he still wanted to 
“take [her] out.”  His email conversation with BM2 Y is equally incriminating in that, 
after trying unsuccessfully to get her to promise to keep something he wanted to tell her 
secret, he sent her the sexual come-on line “If I said you have a beautiful body would 
you  hold  it  against  me.”    In  a  military  environment,  such  a  fishing  expedition  by  an 
officer in one’s chain of command for a sexual relationship is fraught with danger for 
the enlisted members’ careers as well as for that of the officer.  Unlike in most civilian 
environments, any subordinate who responded positively to the applicant’s behavior or 
who even failed to report his behavior was potentially subject to punishment.  In light 
of  the  email  conversations  and  other  evidence  in  the  record  of  sexually  loaded  com-
ments  and  body  language  by  the  applicant that clearly left some female subordinates 
uncomfortable and wary, the Board finds that his rating chain did not commit error or 
injustice in describing his conduct in the disputed OER as “sexual harassment” or for 
that matter as fraternization, improper use of email, pursuit of inappropriate relation-
ships, unethical behavior, and conduct unbecoming an officer. 
 
 
The disputed OER refers to the NJP and Punitive Letter of Reprimand in 
three places.  The Punitive Letter of Reprimand is cited as an attachment in block 2.  In 
light of finding 9, the reference to the letter should be removed from block 2.  In block 5, 
the low mark of 1 for the performance category “Workplace Climate” is supported by 
the comment, “At CO’s NJP, mbr was found to have committed the offenses of sexual 
harassment & violation of the CG’s human relations policy.”  In block 7, the applicant’s 
reporting  officer  wrote,  “Leadership  potential  now  severely  limited  after  finding  of 
commission of sexual harassment & fraternization.”  As there is ample evidence in the 
report of the investigation to support the rating chain’s comments about sexual harass-
ment  and  fraternization,  the  Board  finds  that  only  the  language  concerning  the  NJP, 
findings, and offenses must be removed.  Therefore, from block 5, the words “At CO’s 
NJP,  mbr  was  found  to  have”  and  “the  offenses  of”  (which  implies  criminal  charges) 
should be removed.  These deletions would leave the comment supporting the mark of 
1  for “Workplace Climate” as “… committed … sexual harassment & violation of the 
CG’s  human  relations  policy.”    From  block  7,  only  the  words  “finding  of”  need  be 
removed.  The applicant has not proved that any other part of the OER is erroneous or 
unjust.    Nor  is  there  reason  to  remove  the  entire  OER  as  the  applicant  requested.    In 
BCMR Docket No. 151-87, the Board held that “an OER will not be ordered expunged 
unless  the  Board  finds  that  the  entire  report  is  infected  with  the  errors  or  injustices 
alleged; unless the Board finds that every significant comment in the report is incorrect 

 13. 

14. 

or  unjust;  or  unless  the  Board  finds  it  impossible  or  impractical  to  sever  the  incor-
rect/unjust material from the appropriate material.”  In the instant case, the Board finds 
that it is both possible and practical to remove the language that refers to the NJP and 
the Punitive Letter of Reprimand from the written comments. 
 
 
The  applicant  asked  the  Board  to  reinstate  his  commission  and  promote 
him to lieutenant with backpay and allowances.  Even if the applicant had never gone 
to NJP and there were no NJP or Punitive Letter of Reprimand in his record, however, 
the Board of Officers and those who reviewed and approved that board’s recommen-
dation would still have seen the derogatory OER with the details of his misconduct and 
condemnatory language from his chain of command.  Therefore, the Board is not per-
suaded that in the absence of the NJP and Punitive Letter of Reprimand he would have 
been allowed to retain his temporary commission.  In his letter dated May 29, 2002, the 
applicant argued that under the Article 12.A.11.a. of the Personnel Manual, an officer’s 
commission should be revoked only when he is unable to adapt to military life or when 
his performance indicates that it is doubtful whether he can be formed into an effective 
leader  and  that  neither  criterion  applied  to  him  given  his  own assessment of his per-
formance and leadership.  However, the derogatory OER contains the same information 
as that in the Punitive Letter of Reprimand and ample evidence on which the Board of 
Officers  and  those  who  reviewed  and  approved  the  board’s  recommendation  could 
base  their  determination  that  his  commission  should  be  revoked  under  the  criteria  in 
Article 12.A.11.a.  The applicant has not proved by a preponderance of the evidence that 
the Coast Guard committed any error or injustice in revoking his commission.  
 
 
15.  Accordingly, the applicant’s request should be granted in part by remov-
ing the documentation of the NJP and the Punitive Letter of Reprimand from his record; 
by  removing  the  reference  to  the  Punitive  Letter  of  Reprimand  from  block  2  of  the 
derogatory OER; by removing the words “At CO’s NJP, mbr was found to have” and 
“the offenses of” from block 5; and by removing the words “finding of” from block 7 of 
the OER.  All other relief should be denied. 

 

The  application  of  xxxxxxxxxxxxxxxxxxx,  xxx  xx  xxxx,  USCG,  for correction of 

The  documentation  of  his  NJP  on  October  1,  2001,  and  the  Punitive  Letter  of 

ORDER 

 
 
his military record is granted in part as follows: 
 
 
Reprimand shall be removed from his record. 
 
 
shall be corrected by  
 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

The derogatory OER covering his service from April 1, 2001, to January 31, 2002, 

a) 

b) 

deleting  the  phrase  “Punitive  Letter  of  Reprimand  (NJP  awarded  on 
2001/10/01)” from block 2; 
deleting  the  words  “At  CO’s  NJP,  mbr  was  found  to  have”  and  “the 
offenses of” from block 5; and  
deleting the words “finding of” from block 7. 

c) 
 
These corrections shall be made to the extant derogatory OER by hand and shall 

be made in all paper and electronic copies retained for his Personal Data Record. 

 
No copy of this decision shall be placed in his Personal Data Record. 
 
No other relief is granted.    

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

        

 
 
 David Morgan Frost 

 

 

 
 Patrick B. Kernan 

 

 

 
 Audrey Roh 

 

 

 

 

 

 

 

 

 

 

 

 



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