Search Decisions

Decision Text

CG | BCMR | OER and or Failure of Selection | 2006-003
Original file (2006-003.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. 2006-003 
 
Xxxxxxxxxxxxxxxxxx 
  xxxxxxxxxxxxxxxx 

 

 
 

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.  The Chair docketed it on October 7, 2005, upon 
the BCMR’s receipt of the applicant’s completed application. 
 
 
members who were designated to serve as the Board in this case. 

This  final  decision,  dated  July  21,  2006,  is  signed  by  the  three  duly  appointed 

 

APPLICANT’S REQUEST AND ALLEGATIONS 

 
 
The  applicant  asked  the  Board  to  correct  his  record  by  removing  a  derogatory 
special officer evaluation report (SOER)1 he received for the period May 1 to September 
22,  2004,  when  he  was  serving  as  a  Deputy  Group  Commander  on  Xxxxxxxx.    The 
Group Commander, his commanding officer (CO) had him removed from his duties as 
Deputy Group Commander on September 22, 2004. The CO served as both the appli-
cant’s supervisor and reporting officer for the SOER.2   
 

The applicant alleged that the SOER “contains inaccuracies, inconsistencies, par-
tial and false statements, negative exaggerations, and a lack of performance trend data.”  
He alleged that the SOER was prepared due to “professional differences” in leadership 
styles and that the comments in the SOER are either unfounded or unrepresentative of 
                                                 
1  Coast Guard officers are evaluated in a variety of performance categories on a scale of 1 to 7, with 7 
being best.  A mark of 1 in any category makes an OER “derogatory,” and entitles the reported-on officer 
to attach an addendum.  Article 10.A.3.c.1.a. of the Personnel Manual allows a command to prepare an 
SOER to document performance that is notably different from the officer’s prior performance. 
2    An  officer’s  rating  chain  normally  consists  of  three  members:  supervisor,  reporting  officer,  and 
reviewer.  However, if a unit CO is an officer’s direct supervisor, the CO may serve as both supervisor 
and reporting officer. 

his overall performance and had no impact on the Group’s operations.  He submitted 
survey  charts  showing  that  Group  members’  opinions  of  many  aspects  of  their  work 
improved  between  2002  and  2004.  The  applicant’s  more  specific  allegations  appear 
below. 
 

SUMMARY OF THE RECORD 

 

 
On November 16, 1987, the applicant enlisted in the Coast Guard, having previ-
ously served in the Army for two years.  He attended Office Candidate School and on 
February  22,  1992,  was  appointed  an  ensign  in  the  Coast  Guard  Reserve.    He  began 
serving on an extended active duty contract at the Headquarters Logistics Management 
Division.  On August 22, 1992, he was promoted to lieutenant junior grade.   

 
From  June  21,  1993,  through  June  6,  1996,  the  applicant  served  at  a  Group  as, 
serially, the Administration and Supply Officer, the Special Operations Officer, the Law 
Enforcement  Officer,  and  finally  the  Assistant  Operations  Officer.    He  received  very 
high marks (primarily marks of 6) on the OERs he received from this Group command, 
was rated an “exceptional officer” in the sixth spot on the comparison scale, and was 
strongly recommended for promotion.  On April 3, 1995, the applicant was integrated 
into the regular Coast Guard.  On August 22, 1995, he was promoted to lieutenant.  On 
his final OER at this Group, dated June 6, 1996, the Deputy Group Commander wrote 
that the applicant “is a superb junior officer whom I trust implicitly to do any job.” 

 
From June 7, 1996, through May 31, 2000, the applicant served as a quality per-
formance  consultant,  ensuring  that  field  units  implemented  leadership  and  manage-
ment models and advising and training them about work performance and workplace 
climate.    He  received very high marks on his OERs in this position and was strongly 
recommended for accelerated promotion.  On three of these OERs, a Rear Admiral who 
served  as  the  OER  reviewer  added  a  page  of  comments  to  the  OER  seconding  the 
reporting officer’s assessment of the applicant.  The words used to describe the appli-
cant in these OERs include “visionary,” “innovator,” “leadership laureate,” “contagious 
can-do  spirit,”  “mature,”  “instant  rapport  with  [diverse]  people,”  “exuding  goodwill 
and  diplomacy,”  “self-disciplined,”  “self-sufficient,”  “mission-oriented,”  “efficiency 
lauded  by  all,”  “on  the  top  of  the  performance  charts,”  “excelled  in  a  job  that  would 
have frustrated less capable people,” and “capable of getting positive results in a wide 
range of operational and managerial areas.” 

 
From June 2000 to June 2002, the applicant served as the commanding officer of a 
training  center.    On  the  two  OERs  he  received  in  this  position,  he  was  assigned  very 
high  marks  and  strongly  recommended  for  promotion.    The  written  comments  com-
mend  him  for  “superlative  planning  and  use  of  resources”  and  “outstanding  results” 
and describe him as “ever progressing and improving” and “extremely well qualified 
for command cadre ashore positions.”  The applicant was promoted to lieutenant com-
mander on August 1, 2001. 

 
On June 17, 2002, the applicant began serving as the Deputy Group Commander 
for a Group on Xxxxxxxx, Xxxxxxxx.  As such, he was second in command at a Group 
with xxx active duty members and xx reservists serving at xx search and rescue (SAR) 
stations,  an  aids  to  navigation  team  (ANT),  a  patrol  boat,  and  xxxx  smaller  boats,  as 
well as the Group staff.  As Deputy Group Commander, the applicant was the Group 
Executive  Officer  (XO),  and  served  as  the  primary  human  resource  manager  for  the 
Group  staff,  and  secondary  human  resource  manager  for  the  subordinate  units,  the 
Safety Officer, the Medical Officer, the Mutual Assistance Representative, the “mayor” 
of the Coast Guard housing, and the chair of the various training and awards boards. 

 
On his OER dated April 30, 2003, the applicant received two marks of 5, fifteen 
marks of 6, one mark of 7 (for “Looking Out for Others”), and a mark of “excellent per-
former; give toughest, most challenging leadership assignments” in the fifth spot on the 
comparison scale.  The Group Commander recommended the applicant for promotion 
and wrote that he “influences others, maintains high expectations, performance & mis-
sion-focused  results  &  is  also  a  natural  catalyst  for  the  integrity-based  decisions  of 
crewmbrs.  HR specialist, systems thinker, & professional relationship builder.” 

 
Strategic  thinker;  developed  holistic  contingencies  to  respond  to  Hurricane  xxx;  incor-
porated lessons learned into updated hurricane plan.  Ensured base, units & housing resi-
dents had backup energy … .  Key player in [the District’s] efforts to align GPs & MSOs 
into Sector Commands …  Used available resources when responding to [anthrax, lead, 
and asbestos problems].  Despite major changeover in sr. personnel, required very little 
guidance  to  ensure  GP  support  met  needs  of  subunits;  corporate  knowledge  alleviated 
potential mistakes; used green/amber/red … model to measure GP’s subunit satisfaction 
levels w/ med, admin, & supply shops; feedback used to alleviate short-comings.  Pro-
vided sound input into operations; ensured aids position was verified after commercial 
vsl grounding … Skillfully adapted [to] SAR cases, …, etc.  Demonstrated superior exper-
tise re personnel issues; acted as sounding brd for COs/OICs/XPOs; tightened relation-
ships. … Provided crewmembers chance to give training. … 
 
Leadership  autodidact;  conducted  2  leadership  self-assessments;  measurable  results  fm 
360-degree  analysis  showed  “effective,  self-actualizing  leader”  w/  followers  having 

 
On his OER dated July 31, 2003, the outgoing Group Commander assigned the 
applicant one mark of 5, thirteen marks of 6, four marks of 7 (for “Planning and Prepar-
edness,” “Results/Effectiveness,” “Looking Out for Others,” and “Responsibility”) and 
a mark in the fifth spot on the comparison scale.  He also strongly recommended the 
applicant for promotion and for a Group Commander assignment. 

 
On his OER date April 30, 2004, the new Group Commander (CO), who like the 
prior Group Commander served as both supervisor and reporting officer, assigned the 
applicant  two  marks  of  4  (for  “Planning  and  Preparedness”  and  “Initiative”),  eight 
marks of 5, five marks of 6, three marks of 7 (for “Looking Out for Others,” “Workplace 
Climate,” and “Health and Well-Being”), and a mark in the fifth spot on the comparison 
scale.  The CO also included the following comments to support the marks: 

“high level of satisfaction & high productivity”; ID’d areas for improvement (AFIs) under 
transformational leadership characteristics; linked AFIs to specific unit needs.  2nd assess-
ment  described  leader  w/  “idealized  influence”  over  subordinates’  “trust,  faith  & 
respect” who is “role model”; assessments suprted by visible relationship w/ crew, team-
work  &  workplace  climate;  vision  reinforced  during  mbr  inbriefs.    Treated  mistakes  as 
learning  opportunities;  led  to  development  &  continuous  performance  improvements; 
prepared mbrs for future success.  Took swift, appropriate action after housing residents 
voiced concern re suspected pedophile; maintained privacy, dignity of mbr; defused situ-
ation discreetly.  Interactions w/ 2 estranged spouses objectively guided by policy; issues 
resolved IAW regs. … Interviewed mbr w/ +cocaine urinalysis; uncovered more poten-
tial  users;  launched  CGIS  investigation;  led to 4 discharges.  Accessible XO w/ sought-
after perspective; counseled jr mbrs.  Evals well-supported by 1st-hand knowledge of per-
formance/potential. 
 
I  continue  to  be  impressed  by  [the  applicant’s]  insightful  human  resource  skills  &  the 
professional relationship that has naturally emerged w/ the crew.  The initiative to con-
duct  a  self-assessment  of  leadership  skills  is  merely  one  aspect  of  [his]  drive  to  under-
stand personal & position power & the resulting effects of a leader’s actions.  An officer 
w/ a positive outlook & an effervescent spirit, [the applicant] not only has a finger on the 
pulse of the GP, but also knows when & how to regulate that pulse. … 
 
Provided  diversity  mngmnt  to  crew;  well-rcvd  as  “best  trng”;  initiated  “Ready  for 
Admin” (RFA) prgm to prep units for upcoming MLC compliance visit; ID’d shortcom-
ings in time to alleviate gigs.  Worked w/ cmd sr. chief to formalize Employee Problem 
Informal  Review  Board  (EPIRB)  into  a  Chief’s  Council;  added  leadership  option  to 
address crew issues.  Turned 4910 charges into a plan to help mbr w/ indebtedness; mbr 
back  on  career  path  w/  clean  record.    Took  appropriate  steps  when  mbr  blew  a  .096 
breathalizer  …  Worked  w/  subunits  to  alleviate  perf.  problems  in  operational  arena; 
admin assigned mbrs to GP for discharge processing or perf. turnaround; worked closely 
w/  D1(d1)  to  ensure  all  avenues  were  considered.    Conducted  investigation into mbr’s 
phenobarbital + urinalysis …  Solved issue re community use of gov’t water at housing; 
created  good  neighbor  environment  while  maintaining  high  ethical  standards  of  self  & 
F&S dept head. … Fitness champion; ran routinely …  
 
Qualified as Group Commander; Acted as CO for 38 days; Met all requirements w/ pro-
fessional sound judgment.  Previous Boat Forces experience combined w/ prior consult-
ant  work  w/  D8  [Marine  Safety  Offices]  make  [the  applicant]  a  qualified  trailblazer  to 
serve in a senior cmd billet at a sector.  [He] has reapplied for the USMC Cmd/Staff Col-
lege; As the first alternate 3 years ago & based on continued performance, [the applicant] 
rates & is highly recommended for selection.  Highly recommended for jobs that require 
an expertise in HR and/or leadership, based on practical leadership experience and on-
going doctoral studies.  Recommended for Group Commander and promotion to O-5.  
 
The CO counseled the applicant about this OER and about his expectations of the 
applicant.  The CO’s written “OER Feedback” concerning the applicant’s strengths and 
weaknesses  cited  areas  in  which  the  CO  wanted  the  applicant  to  improve,  including 
updating the CO regularly about the status of projects; tracking work, awards, and per-
sonnel issues; and “demonstrat[ing] greater operational involvement” by “making sub-
stantial progress toward your boat forces pin,” “participat[ing] in the RFO program,” 
“getting underway with our units on a periodic (monthly) basis,” and “participat[ing] 
in wet drills.” 

 
On  May  19,  2004,  the  CO  provided  the  applicant  with  another  detailed  list  of 
expectations concerning how he should relate to and represent the CO; display leader-
ship; maintain a calendar of events; process awards and arrange award presentations; 
handle  personnel  matters;  and  inspect  materiel  and  resolve  discrepancies,  including 
twelve  “immediate”  maintenance  projects  on  the  Group’s  property,  such  as  washing 
windows,  replacing  carpet,  trimming  hedges,  and  clearing  and  straightening  storage 
space, to be done before the CO’s materiel inspection on June 16, 2004.  

 
After the CO took a week of leave from June 28 to July 2, 2004, he gave the appli-
cant a page of written feedback about work that was not accomplished or was inade-
quately planned or performed during his absence. 

 
On August 13, 2004, the CO wrote a letter to the applicant, stating the following:  
 
[Y]ou still have a ways to go to meet my expectations. … If your performance improves, 
you can continue on in the job and have prospects for a bright future.  If your perform-
ance does not improve, I may be in the unfortunate position of having to write a special 
OER  and  to  revoke  my  recommendations  for  post-graduate  programs,  command,  and 
promotion.  As it stands right now, I cannot recommend you for any one of those three.  
In a worst case scenario, I may be forced to relieve you of your duties as deputy group 
commander.  Although I am not presently satisfied with the quality of your work, I still 
have confidence that you can perform the job in a way that will meet my expectations.  I 
encourage  you  to  continue  to  make  improvements  in  initiative,  decisiveness  (directing 
others), planning, and the overall thoroughness of your work. 
 
Following “feedback sessions” between the applicant and the CO on August 13, 
19,  and  30,  and  September  7  and  13,  2004,  the  CO  gave  the  applicant  short  lists  of 
“things that went well” and long lists of “things that did not go well.”  The applicant 
submitted written responses to several items on the CO’s lists.  For example, 

•  The CO complained that a letter regarding a member’s discharge did not indicate 
whether  he  had  submitted  a  statement  or  waived  his  right  to  do  so.    The  applicant 
responded  that  the  member  had  submitted  an  incomplete  statement  and  that  “[t]he 
letter was for your signature, so if you needed that statement put in, it was an easy fix, 
not a performance issue.” 

 

 

 

•  The CO complained that the applicant had asked him to sign a letter verifying 
that  an  inventory  had  been  conducted  without  showing  him  documentation  of  the 
inventory.  The applicant responded that he was “used to working in an environment 
where  my  character  is  trusted,  and  I  trust  my  department  heads  …  But  again,  if  you 
wanted to see the inventory, it was an administrative issue, not a performance issue. 

•  The CO complained that he had to call the applicant at home one evening to find 
out whether the CO or the applicant would be attending a Sector meeting.  The appli-
cant responded that the CO had left the office first and left before the applicant received 

the answer to that question from the District.  When the CO called him, the applicant 
told him he had nothing to report because the District did not respond to their query 
until Thursday. 

•  The  CO  complained  that  a  form  was  missing from an award recommendation.  
The  applicant  responded  that  at  the  time,  the  form  “was  on  its  way  over”  from  the 
member’s subunit. 

 

 

 

 

 

 

 

•  The  CO  complained  that  he  saw  a  message  from  the  District  Chief  of  Staff 
requiring an EEO report by September 1, 2004, and that the CO did not know if anyone 
was  taking  action  on  the  report.    The  applicant  responded  that  the  “CRO  had  it  for 
action, and we met the deadline.” 
 

•  The  CO  complained  that  he  had  not  been  briefed  about  a  member  being  dis-
charged  due  to  his  second  alcohol-related  incident.    The  applicant  stated  that the CO 
was misinformed because the member had not had a second “alcohol incident” and was 
not being discharged.  Therefore, “there was nothing to brief you on re this (non)inci-
dent.” 

•  The CO complained that the Group still had no ball caps although they had run 
out more than five weeks previously.  The applicant responded that the Morale Officer 
had not alerted him and that he had ensured that new ball caps were ordered as soon as 
he  discovered  the  problem.    Moreover,  the  applicant  stated  that  a  ball  cap  is  only  a 
token and that his staff used other ways to “incorporate new members into the fold.” 

•  The CO complained that he had not been briefed about something on the calen-
dar.  The applicant responded that this complaint contradicted a prior statement by the 
CO that he had been briefed. 

•  The  CO  complained  that  a  FedEx  package  for  an  administrative  investigation 
into  a  mishap did not contain finalized radio logs, as the applicant had promised the 
investigator.    The  applicant  responded  that  the  oversight  had  been  corrected  by  the 
Operations Division. 

•  The  CO  complained  that,  two  months  earlier,  he  had  asked  the  applicant  to 
mediate a conflict between two subordinate officers and that the applicant had delayed 
doing so until the CO reminded him in writing.  The applicant responded that he had 
“engaged” both officers promptly but that their operational and annual leave schedules 
had not permitted them to meet together for mediation for several weeks.  The appli-
cant stated that the CO’s written reminder had not affected the timing of the mediation. 

•  The CO complained that neither he nor the Engineering Officer knew about the 
conflict  until  they read a monthly report.  The applicant stated that the situation was 

handled  at  a  lower  level  and  was  properly  communicated  to  the  CO  through  the 
monthly report. 

•  The  CO  complained  that  when  he  returned  from  a  week’s  leave,  the  applicant 
did  not  present  him  with  a  list  of  things  that  had  occurred  in  his  absence  “as  almost 
anyone would do for his boss.”  The applicant responded that the CO had been absent 
for 58 days during the prior year and had never yet requested such a list.  Instead, there 
was a “staff brief” the morning the CO returned and the applicant and each department 
head orally briefed the CO. 

 

 

 

 

 

•  The CO complained that before going on a week of leave, he gave the applicant a 
list  of  questions  and  concerns  but  that  the  applicant  did  not  respond  until  four  days 
after the CO returned.  The applicant responded that their “scheduled status update” 
had been delayed from Tuesday to Thursday due to the CO’s own busy schedule upon 
returning  from  leave  and  that  Thursday  was  the  “earliest  break  in  the  catch-up 
schedule.”    The  applicant  stated  that  if  the  CO  had  requested  an  earlier  briefing,  the 
applicant would have provided one. 

•  The CO complained that although before he left he had prepared a comprehen-
sive list of things that needed to be done concerning a certain seaman, he had received 
no update upon his return.  The applicant responded that that seaman’s situation was 
being handled by the subunit chain of command and that the applicant did “not expect 
my Commanding Officer to doubt the effectiveness of the chain of command in hand-
ling an E3’s performance issues, and therefore did not provide you, or think you expect-
ed, an update.” 

•  The  CO  complained  that  planning  for  the  Coast  Guard  Day  picnic  had  only 
begun  after  the  CO  reminded  the  applicant  and  just  two  days  before  the  event.    The 
applicant responded that planning had begun three months early. 
 

•  The  CO  complained  that  after  asking  the  applicant  to  make  repairs  of  obvious 
materiel  discrepancies  a  top  priority  and  mentioned  the  lack  of  “non-skid”  on  some 
steps, the steps were not fixed during the week and the CO was embarrassed when his 
supervisor noted the condition of the step when she visited the following week.  The 
applicant  responded  that  there  was  a  “manpower  issue,”  that  the  non-skid  had  been 
removed because the step had been repaired and needed to be painted. 

•  The CO complained that although they had two months’ warning of the depar-
ture of an ensign, there was no one qualified to fill his duties as EKMS alternate.  The 
applicant responded that he and the Operations Officer “had this under control with a 
plan  to  get  the  EKMS  alternate  identified  well  before  [the  ensign’s]  departure.”    The 
applicant  stated  that  “it  appears  as  if  your  negative  opinion  of  me  and  my  abilities 
preempted a discussion that would have alleviated your concern not only in the hand-
ling of a personnel issue, but in my personal ability to handle my responsibilities.”   

•  The CO complained that the applicant botched a drug-use investigation by fail-
ing to read a member his rights “even though [the applicant] suspected [the member] of 
a UCMJ offense.  The applicant stated that he did not suspect the member of anything 
but, with a witness present, was merely counseling a member “who was having prob-
lems at home,” when the member “confessed … that he had a positive drug urinalysis.”  
The applicant had the member clarify what he had said and then stopped the interview. 

•  The CO complained that the applicant had not included a retirement party that 
was mandatory for all hands on a “plan of the week.”  The applicant stated that he did 
include it but that the person who wrote up the plan overlooked it. 

 
From  September  14  to  16,  2004,  the  Maintenance  and  Logistics  Command  con-
ducted  an  Administrative  and  Financial  Compliance  Inspection  at  the  Group  for  the 
first time in five years.  The Group’s financial, administrative, and personnel programs 
were found to be satisfactory.  The inspector reported that no follow-up reports were 
required  because  the  Group’s  “evaluation  in  each  area  was  satisfactory  or  better  and 
you are compliant in all areas.”  The inspector also noted that the morale account was 
not ready for inspection because the newly appointed (September 8) Morale Officer was 
away due to operational commitments and had not had time to prepare for inspection. 

 
On  September  22,  2004,  the  CO  removed  the  applicant  from  his  position.    To 

 

 

document this event, the CO prepared the SOER as follows: 

 

MARKS AND COMMENTS IN DISPUTED SOER 

(The bold numbers inserted in the text refer to correspondingly lettered allegations and supporting evidence below.) 
# 
CATEGORY 
3a  Planning and 
Preparedness 

MARK  WRITTEN COMMENTS 

3 

3b  Using 

Resources 

3c  Results/ 

Effectiveness 

3d  Adaptability 

3e  Professional 
Competence 

4a  Speaking and 

Listening 

4b  Writing 

5a 

Looking Out for 
Others 

5b  Developing 

Others 

5c  Directing 

Others 

5d 

Teamwork 

5e  Workplace 

Climate 

5f 

Evaluations 

4 

3 

3 

4 

5 

5 

5 

5 

4 

4 

6 

3 

8a 

Initiative 

8b 

Judgment 

8c  Responsibility 

8d  Professional 

Presence 

8e  Health & Well-

Being 

3 

4 

4 

5 

6 

Weak planning/preparedness: [1] despite frequent prompting, did not initiate tickler for tracking 
assignment/due dates, resulting in missed deadlines (late OERs, evals, hurricane plan, train-
ing); [2] instituted command calendar, worklist, personnel tracking system, awards tracking, 
only after supervisor directed/provided model; [3] virtually unresponsive to materiel dis-
crepancies: [4] 1 yr to complete fitness trail, [5] 2 fences falling down, weeds, painting, dilapi-
dated floating docks; [6] not prepared for quarters—left mess for EO, resulting in EO/CO 
embarrassment in front of crew; [7] MLC Compliance criticized urinalysis program for lack of 
year-round testing; [8] no one available to present morale account to inspectors, resulting in 
lenient “not ready for inspection” result; [9] ill-prepared for transfer season (no unit ball caps, no 
plan for comms watch rotation, last minute/ late awards), [10] no plan developed for departure 
of LTJG (EKMS relief, morale); [11] released “possible compromise” message without briefing 
CO.  [12] Failed to adapt/ respond: in midst of difficult fatality case/mishap, relieved as 
President, Local MAB (failed to pull radio tapes, develop inventory, or provide investigator with 
comprehensive evidence package); [13] even after red-flag warning by admin officer for morale 
1 month in advance, account in poor shape for MLC inspector; [14] neglected to pass written MI 
discrepancies from CO to department heads; [15] unresponsive to clear guidance by CO after 
frequent oral & written feedback. 
Entertaining speaker w/ keen, multi-layered sense of humor; addressed issues facing unit COs/ 
OICs; advice was clear/supportive of policy/well-rcvd; w/ short notice, cancelled his leave & 
presided over BM1 retirement ceremony; speech was lauded by mbr, family, guests.  Drafted 
endorsements, memos, ltrs; edited awrds; used measures system for 3-wk period that revealed 
96% signature-ready rate on documents; drafted STA change of cmd speech for CO; e-mails; 
helped subordinates tailor correspondence (flt school/OCS requests); edited SRO’s war college 
application. 
Focused inbrief msg on mbr ownership & development; attended trng sessions w/ crew; demon-
strated commitment to unit’s work climate; challenged officers w/ transactional leadership styles 
to be more inspirational than directive; w/out imposing will, demonstrated skills as coach.  
Separated person fm performance; counseled mbrs on personal & professional issues; 
supported personal needs of 2 mbrs facing courts martial; maintained mbrs’ dignity; effort kept 
both engaged in daily work; worked with ISC to get mbr a domestic violence assessment.  
Teamed w/ YNCS & YN1 to help F&S w/ contracting background acclimate to admin supervi-
sory duties, CWO showed exponential growth in admin world of work.  Worked w/ two 
estranged spouses after a/d mbr admitted to adultery; ensured child support req’s were met; 
ensured extra duty/ restriction was executed.  Helped STA process mbr for discharge after 
admitting to bisexual activities; ensured mbr got legal counseling re admin discharge brd.  Took 
fast, appropriate steps to work w/ unit cmds; processed personnel issues (alcohol, 
performance, police charges, drug incidents, etc); policy-guided; description of Group as 
“support unit” appreciated by unit cmd cadres.  [16] OER’s submitted in good quality, but some 
late due to poor tracking; [17] enlisted evals accurate, requiring minor changes, but Group staff 
E-6 marks 45 days late. 

[18] [The applicant] has been passively stubborn in not adjusting to or meeting my expectations 
for my Deputy Group Commander.  [19] Despite frequent and forthright feedback (both oral and 
written), [he] has been slow or unresponsive to tasking, deadlines, and expectations.  [20] He is 
good at responding to crises, but not at planning to prevent them, turning normal military events 
into fires to put out (awards, personnel transfers, reports, evaluations, District Commander 
visit).  [21] Chooses “inspirational” leadership model, but lacks ability to adapt where it falls 
short. 
[22] Lacked initiative/career development: [23] did not set foot on a CG boat during entire 
reporting period; [24] did not participate in Ready for OPS (RFO)/STAN visits; [25] took no 
steps to develop plan for himself or subordinates to earn boat forces pin; [26] took no remedial 
area familiarization action when, as acting CDO, did not know location of Xxxx xxxx (xxx Group 
is located on); [27] failed to flag important message traffic while CO on leave (COMDT Sector 
impl., D1(dcs)).  At times, demonstrated sound judgment: acting CO for 20 days (18 during 
busy SAR season) while CO TAD/leave; acting CDO 5 days; worked w/ GDOs to ensure cases 
ran smoothly; responded well to complicated family case at housing; formal actions ensured 
mbrs’ safety/accountability; de-escalated spouse’s anger w/ calm demeanor; worked w/ family 
advocate to defuse/rectify source of family disturbance.  Always looked good in uniform, 
established “best boot Tuesday,” inspiring members to polish boots; [28] sponsored fancy work 
contest; rendered proper military courtesies.  Excellent physical shape; regular distance runner; 
rated excellent in physical fitness assessment; planned physical fitness assessment for entire 
Group staff to encourage overall well-being. 

6 
7 

Signed by the CO on September 22, 2004, as supervisor 
Reporting 
Officer’s 
Comments 

NA 

9 

Comparison 
Scale 

1 

[Performance unsatisfactory for grade or billet.] 

10  Potential 

NA 

[29] While he was successful as the personnel officer in many respects, he failed to grasp the 
breadth of his duties as the Deputy Group Commander, falling short on operational matters, 
accountability, and unit planning.  [30] As a result, I can only recommend him for administrative 
positions.  [31] He possesses an extensive educational background and concern for junior 
members that should be considered in the assignment process.  With enhanced dedication and 
an opportunity to perform in a non-operational assignment, he has the potential to earn a rec-
ommendation for promotion to O-5 at a later time. 

11  Signature of the CO dated September 22, 2004, as reporting officer 
12  Signature of the Chief of the District Search and Rescue Branch dated September 28, 2004, as reviewer  
 
 

 
Because the OER was derogatory, the applicant was entitled to submit an adden-
dum.    He  wrote simply, “I stand by my record, my experience, my understanding of 
leadership,  my  reputation,  and  my  adherence  to  the  organization’s  emphasis  on  peo-
ple.”  This addendum was forwarded by the rating chain without comment. 
 
 
On October 22, 2004, the applicant submitted an OER Reply in which he alleged 
that the CO provided no “command vision” and may not have understood his “trans-
formational leadership approach [which] is not understood or readily accepted in tradi-
tional  (transactional)  units,  but  it  is  tactically  based  on  the  Commandant’s  diversity 
policy and its support of ‘people first’ initiatives to maintain retention while balancing 
work life.”  The applicant alleged that it was “a personality-driven evaluation conduct-
ed in a transactional, throw-back environment that allowed [him] to go from ‘Qualified 
as Group Commander’ to not being recommended for graduate school or promotion in 
145 days.”  He pointed out that during the evaluation period, he was a “doctoral stu-
dent in organizational development, but [he] ‘did not set foot on a CG boat,’ so [the CO 
wrote that he] ‘lacked initiative/career development.’” 
 
 
On October 29, 2004, the CO forwarded the OER Reply to the reviewer.  The CO 
wrote that the SOER was not “personality-driven” and “was based solely on perform-
ance.” 
 

On  November  10,  2004,  the  reviewer  forwarded  the  OER  Reply  to  the  Coast 
Guard  Personnel  Command  (CGPC).    He  noted  that  the  applicant  had  submitted  a 
memorandum requesting redress against his CO under Article 138 of the UCMJ but that 
it was returned to him because he had not first sought redress directly from the CO and 
because the “redress of an OER is not cognizable under Article 138.”  The reviewer fur-
ther stated that he was “confident that the [SOER] was based solely on observed per-
formance.”  
 
 
On November 22, 2004, CGPC rejected the applicant’s OER Reply because of the 
comments  concerning  interpersonal  relationships  and  his  opinion  of  the  abilities  or 
qualities of the CO, which are not permitted in an OER Reply under Article 10.A.4.g.2. 
of the Personnel Manual. 

VIEWS OF THE COAST GUARD 

 

 
 
On  December  1,  2004,  the  applicant  submitted  a  revised  OER  Reply  with  a 
bulleted list of 36 projects or tasks he had completed or contributed to during the evalu-
ation period.  Most of those listed are included with his allegations summarized below. 
 
 
On December 21, 2004, the CO forwarded the OER Reply to the reviewer, stating 
that  he  was  aware  of  all  of  the  performance  documented  therein  and  took  it  into 
account  when  preparing  the  SOER.    However,  he  stood  by  the  SOER.    He  wrote, 
“Although  I  agree  that  [the  applicant]  performed  the  tasks  listed  in  his  OER  Reply,  I 
don’t think they paint a complete picture of his performance.  For example, regarding 
the bullet about ‘admitted drug possession/use,’ [the applicant] neglected to read the 
member his rights before questioning him, and we were unable to use his confession for 
a discharge.  The member remains on active duty at this time.” 
 
 
On  June  10,  2005,  the  PRRB  denied  the  applicant’s  request  to  have  the  SOER 
removed from his record.  The views of the PRRB are summarized with the applicant’s 
allegations below. 

 
 
On February 22, 2006, 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 merit, except to the extent of removing the SOER comment about the fancy 
work contest. 
 
 
The  JAG  argued  that  the  applicant  failed  to  submit  “clear  and  convincing  evi-
dence  to  overcome  the  presumption  of  regularity  afforded  rating  officials.”    The  JAG 
also  argued  that  the  record  before  the  Board “clearly establishes that the [SOER] was 
properly prepared in accordance with the Personnel Manual; that it represents the hon-
est  professional  judgment  of  the  group  commander;  and  that  it  accurately  reflects 
Applicant’s actual performance during the period of the report.”  The JAG attached to 
and adopted as part of his advisory opinion a memorandum on the case prepared by 
the Coast Guard Personnel Command.  CGPC argued that each of the disputed com-
ments, except the date of the fancy work contest, are supported in the record.  CGPC’s 
findings regarding specific disputed comments are summarized below with the appli-
cant’s specific allegations. 
 
 
Regarding the applicant’s allegations about professional differences and leader-
ship styles, CGPC stated that transformational leaders typically have great passion and 
confidence  but  sometimes  “passionately  lead  their  followers  to  ruin”  and  are  “apt  to 
spend most of their energy and attention selling the big picture while overlooking man-
agement of the details.”  CGPC stated that the applicant’s  
 

stubborn insistence that his own leadership style was the far more superior style and/or 
more  successful way to lead the unit was not convincing.  The Applicant’s opinions on 
leadership styles are trivial compared to the inescapable fact that Commanding Officers 
are uniquely qualified for command, are hand-selected by higher authority, and are the 
sole legitimate command authority.  Executive Officers are bound by CG Regulations to 
implement the CO’s vision in the most effective manner, not to supplant it with their own 
vision.    Furthermore,  Applicant’s  supporting  documentation  and  numerous  admissions 
paint  a  credible  picture  of  deliberate  discord  on  the  part  of  the  Applicant  towards  the 
Group Commander’s leadership.  It is clear that professional differences existed between 
the  Applicant  and  the  Group  Commander,  but  mostly  (if  not  solely)  due  to  misplaced 
leadership arrogance on the part of the Applicant. 

 APPLICANT’S RESPONSE TO THE VIEWS OF THE COAST GUARD 

 
 
 

On  March  20,  2006,  the  applicant  responded  to  the  views  of  the  Coast  Guard.  
The applicant objected to CGPC’s “tirade explaining leadership styles” as it was flawed 
in several respects and did not focus on his actual performance.  The applicant argued 
that he could not implement the CO’s “vision” because the CO had not provided one.  
Therefore,  he  continued  “perpetuating  the  vision  of  reciprocal  leadership  and  owner-
ship among the crew,” for which the CO had praised him in his prior OER.  The appli-
cant stated that to his own misfortune, the CO “measured all others by his own model, 
… did not make his expectations clear for the first ten months of his tour, and … never 
formulated a vision for his command.” 
 
 
The  applicant  stated  that  he  understood  that  the  CO  had  an  “absolute  right  to 
ask for things to be done differently, and by all evidence I incorporated those changes 
(tickler  files).”    However,  within  145  days,  the  CO  was  busy  creating  a  “paper  trail.”  
The applicant alleged that “nowhere in that paper trail are there redundancies.  In other 
words, there was never a defined deficiency that had to be corrected more than once.”  
Therefore,  he  argued,  the  CO  was  documenting  mere  “one-time  events”  with  no 
adverse  impacts  simply  because  he  was  personally  affronted  that  the  applicant  had 
deviated from the way the CO would have handled a particular task. 
 

SUMMARIES OF EVIDENCE AND ARGUMENTS ABOUT SOER COMMENTS 

 
The following summaries group (a) the applicant’s evidence and allegations con-
 
cerning each of the negative comments in the disputed OER with (b) any statements by 
the  CO  or  reviewer  regarding  disputed  comments,  (c)  the  findings  of  and  statements 
considered by the PRRB, (d) the opinions of CGPC in the advisory opinion, and (e) the 
applicant’s responses. 
 
COMMENT  [1]:    “despite  frequent  prompting,  did  not  initiate  tickler  for  tracking 
assignment/due  dates,  resulting  in  missed  deadlines  (late  OERs,  evals,  hurricane 
plan, training)” 
 

Applicant’s Arguments 
 
 
The applicant alleged that “he did not miss deadlines because of weak planning.”  
He  stated  that  he  “used  the  Coast  Guard  Personnel  Manual  which  clearly  outlines  a 
‘tickler’ for on-time submission for OERs and evaluations. … I used the tickler already 
provided  by  the  organization  thus  reducing  redundancy.”    Moreover,  the  applicant 
stated,  the  Group’s  OER  initial  and  due  dates  were  included  on  the  Group  Worklist, 
which was generated in response to the CO’s request.  He provided a copy of the Group 
Worklist  dated  September  September  17,  2004,  which  shows  OER  entries  with  initial 
and due dates included.  He also alleged that there had been a 100% turnover on the 
administrative staff, and the new staff had to “come up to speed.” 
 
 
The  applicant  stated  that  he  had  three  “direct  reports,”  and  of  those  officer’s 
OERs, he signed only one late and its delay was not due to lack of a tickler list but to the 
fact that it was that officer’s first OER, and the applicant had to help him document his 
performance.    Moreover,  he  stated,  the  CO  himself  signed  all  three  of  the  OERs  late.  
Therefore, he argued, his CO arbitrarily held the applicant to a higher standard than the 
standard to which he held himself, in violation of Article 138 of the Uniform Code of 
Military Justice (UCMJ). 
 
 
The applicant stated that all other OERs and enlisted evaluations were submitted 
on time, except those of for E-6s, which were submitted late “by design.”  He referred to 
his arguments regarding comment [17] (below).  In addition, the applicant submitted a 
copy of a Coast Guard publication, which stated that in 2004 only 45% of all OERs were 
submitted to CGPC timely within the 45-day deadline.  
 
 
Regarding  the  hurricane  plan,  the  applicant  stated  that  there  was  one  in  place 
and  that  it  was  reviewed  annually  upon  receipt  of  an official hurricane message.  He 
stated  that  having  a  tickler  would  therefore  have  been  redundant.    However,  in 
response  to  “the  CO’s  request,  a  worklist  was  generated,  and  the  hurricane plan was 
added.”  The applicant alleged that the CO slowed down review of the plan by rejecting 
his suggestion that the CO review it concurrently while others reviewed it because he 
“wanted everyone to see it before he did.” 
 
The applicant stated that the Group training officer provided an annual training 
 
plan and posted it on the bulletin board.  He submitted a copy of a training schedule for 
FY2004, which shows the title, date, and instructor’s name for twenty training sessions 
offered at the Group throughout that fiscal year. 
 
CO’s Arguments 
 
The CO stated that during the evaluation period, only two of eight members of 
 
the administrative office were transferred out and replaced.  He stated that both he and 
the District expected the hurricane plan to be revised prior to the season, but it was not 

to 

certify 

the 

train 

and 

a  plan 

junior  officers 

done.  Regarding training, the CO stated that the applicant “assumed no responsibility 
for  developing 
as 
comms/controller/CDO/  boat  crew/BTM/BO.    He  did  not  monitor  the  operations 
department training, [which is] perhaps the most important training on the Group staff, 
and he provided no oversight of reserve training.” 
 
COMMENT [2]:  “instituted command calendar, worklist, personnel tracking system, 
awards tracking, only after supervisor directed/provided model” 
 
 
The  applicant  alleged  that  this  comment  is  analogous  to  “answered  the  phone 
only after it rang” because his three prior OERs “reflect positive actions and account-
ability without having a piece of paper to track deadlines.”  He stated that he generated 
the lists for the CO’s use, not his own, when the CO requested them ten months after he 
took command.  The applicant stated that he himself had “operated successfully for two 
years  without  these  tickler  systems”  but  that  he  generated  the  lists  mentioned  in this 
comment  in  May  and  June  2004,  when  the  CO  asked  for  them,  and  updated  them 
weekly until he was removed in September.  Therefore, he promptly responded to the 
CO’s  request  during  the  evaluation  period,  and  the  tickler  lists  were  in  place  for  the 
majority of the marking period.  For example, “the awards tracking model was in place 
in May, and 31/32 awards (97%) were delivered to the receiving members before they 
departed. 
 
 
In  support  of  his  allegations,  the  applicant  submitted  copies  of  a  “personnel 
issues” spreadsheet, a Group Worklist, an Award Status spreadsheet, and a nine-page 
materiel discrepancy list with (very few marked as “completed”), all of which the CO 
authorized a Group staff member to email the applicant on December 27, 2004. 
 
The  CO  stated  that  “after  months  of  us  failing  to  meet deadlines, I tasked [the 
 
applicant]  with  developing  and  maintaining  a  tickler  system.  …  He  did  not  develop 
them; I did” by providing templates. 
 
COMMENT [3]:  “virtually unresponsive to materiel discrepancies”  
 
Applicant’s Arguments 
 
 
The  applicant  stated  that  he  “delegated  the  materiel  discrepancies  to  the  Engi-
neering  Officer,”  in  accordance  with  the  CO’s  expectations.    He  stated  that  the  Engi-
neering  Officer  was  not  unresponsive  but  was  busy  providing  support  for  the  opera-
tional units.  The applicant pointed out that the evaluation period happened during the 
Group’s  busy  SAR  season  and  that  he  therefore  “prioritized  the  discrepancy  list 
accordingly with plans to correct the discrepancies after the search and rescue season.”  
He  stated  that  in  August  2004,  the  engineering  staff  had  to  perform  450  hours  of 
unscheduled  boat  maintenance,  which  was  more  important  than  whether  a  step  was 
painted or a hedge trimmed. 

 

The applicant submitted a copy of the discrepancy list, generated three months 
after his departure, and pointed out that all 19 of those discrepancies accounted for on 
the list had been handled before his departure and that nothing had been done since his 
departure.  Therefore, he argued, the CO was holding him to a higher standard than he 
held himself. 
 
PRRB’s Arguments 
 
 
The PRRB argued that materiel discrepancy list submitted by the applicant sup-
ports this comment because the list indicates that only 21 out of the 415 discrepancies 
shown were completed. 
 
CO’s Arguments 
 
 
In his declaration for the PRRB, the CO stated that due to the lack of a materiel 
discrepancy list, he had scheduled a CO’s materiel inspection, but the applicant “took 
virtually no steps to prepare for that inspection. …  [He] had clearly told [the applicant] 
that  [he]  expected  him  to  ensure  the  unit was ready for [him] to inspect.”  “The goal 
was for him to generate the list and fix/improve as many things as possible so I could 
walk around and compliment the crew on their good work.  Instead, the list was gener-
ated during my inspection.  The [Engineering Officer] played a big part in generating 
this list, partly because [the applicant’s] hands were full of trash that he was picking up 
during the inspection.” 
 
Reviewer’s Comment 
 

In a declaration for the PRRB, the reviewer wrote that he learned from the CO 
during their telephone conversations over the summer that the applicant “paid insuffi-
cient  attention  to  detail  and  missed  several  deadlines.    We  specifically  discussed  late 
enlisted  evaluations  and  OERs,  lack  of  ballcaps  for  newly  arrived  members,  and 
delayed  awards.  …  [The  CO]  was  typically  disappointed  that  [the  applicant]  had  not 
adequately prepared for an awards ceremony or all hands meeting. …  [The CO] was 
also disappointed in the material condition of the Group and expressed his frustration 
to me several times that [the applicant] was not working quickly enough to correct dis-
crepancies.”  The reviewer stated that the positive comments of the District Commander 
in the inspection log were simply “to raise crew morale [and] not necessarily intended 
to convey the material condition of the unit.” 
 
Applicant’s Rebuttal 
 
The applicant submitted a statement by a member of the Group, who stated that 
 
the  Group’s  materiel  inspection  process  involved  the  XO  inspecting  one  department 
each week for safety and structural integrity and general cleanliness.  The administra-

tive  staff  would  prepare  a  list  of  each  discrepancy  found  and  forward  the  list  to  the 
department  head.    Throughout  the  month,  the  XO  would  follow  up  with  the  depart-
ment  head  “to  ensure  the  items  were  being  rectified,”  and  the  XO  would  re-inspect 
those discrepancies the following month.  The member stated that the XO would report 
any urgent problems or safety issues to the CO. 
 
COMMENT [4]:  “1 yr to complete fitness trail”  
 
 
The applicant stated that the fitness trail was completed in the summer of 2003, 
before the CO’s arrival, and was used until May 2004, when it was “rearranged into a 
fitness pod.”  The rearrangement was delayed due to a “water line that had to be fixed” 
and frozen ground that prevented digging.  The applicant stated that he discussed the 
matter with the CO, who agreed with his proposed layout, and alleged that it should 
not be a point of criticism.  He alleged that the CO first criticized the trail during his 
inspection on June 16, 2004. 
 
In support of his allegations, the applicant submitted a statement signed by the 
 
Group  Corpsman,  who  said  that  in  June  2003,  the  fitness  trail  ran  along  the  Group’s 
perimeter  fence.    In  the  summer  of  2003,  the  fitness  equipment  was  moved  beside  a 
volleyball  court,  and  plans  were  made  to  lay  a  path  between  the  trail  and  the  equip-
ment.  However, when the stones were delivered, the delivery truck broke a water main 
under the site where the path was to be, which delayed the building of the path.  How-
ever, the fitness trail continued to be usable, and he himself used it several times a week 
until he left the Group in May 2004. 
 
 
The  CO  stated  that  he  defined  “finishing  the  trail”  to  include  installing  equip-
ment,  borders,  and  signs;  putting  down  gravel;  and  cleaning  up.    He  wrote  that  the 
applicant “knew [the CO] was not satisfied with the condition of the fitness trail, even if 
he was.” 
 
COMMENT [5]:  “2 fences falling down, weeds, painting, dilapidated floating docks” 
 
 
The applicant stated that four fence posts in all were repaired during the evalua-
tion  period  although  they  were  not  on  the  discrepancy  list.    In  addition,  he  alleged, 
fence  rails  fell  down  “anytime the unit dog ran under the rails.”  He alleged that the 
weeds  were  taken  care  of  as  “grounds  maintenance  was  a  steady  occurrence  in  the 
summer.”  However, the weeds were on the discrepancy list because inclement weather 
had prevented weed treatment during the spring.  The applicant stated that the paint-
ing “was going to require funding that the Admin officer could not identify until the 
end  of  the  Fiscal  Year  so  it  was  prioritized  as  a  discrepancy  to  complete  later.”    The 
dilapidated  docks  were  not  on  the  discrepancy  list  and  were  discovered  late  in  the 
summer.  When he noted the Search and Rescue Detachment, whose docks they were, 
that detachment “promptly disposed of the docks.”  Finally, the applicant alleged, the 
District Commander “remarked that the base was ‘well-maintained’ … during his visit” 

on September 13 and 14, 2004.  He submitted a copy of the District Commander’s note 
in the Group’s inspection log. 
 
COMMENT  [6]:    “not  prepared  for  quarters—left  mess  for  EO,  resulting  in  EO/CO 
embarrassment in front of crew”  
 
 
The applicant alleged that he was always prepared for quarters (the weekly staff 
meeting).  He complained that the word “mess” is subjective.  He submitted a copy of a 
letter from a crewmember, who stated that on the morning awards were handed out, 
everything and everyone was in place for the ceremony.  In support of his allegations, 
the applicant submitted a statement from a lieutenant commander, who wrote that the 
applicant invited him to attend quarters at the Group on July 2, 2004, to receive a Com-
mendation  Medal  from  the  Group  Commander.    He  arrived  just  five  minutes  before 
quarters and was greeted by the CO and the applicant.  The applicant had to leave to 
attend a meeting in the CO’s stead so that the CO could present the awards.  Therefore, 
the Engineering Officer read all the award citations while the CO pinned on the medals.  
The  lieutenant  commander  stated  that,  “In  my  opinion,  the  entire  day  was  well 
planned, well coordinated and the Command had no reason to be embarrassed.” 
 
 
The CO stated that he came to the Group while on leave to present awards and 
found  that  the  applicant  was  not  prepared  to  conduct  quarters  and  “with  only  five 
minutes notice he dumped the presentations on the [Engineering Officer].”  The appli-
cant  had  known  about  the  routine  teleconference  well  in  advance  but  made  no  prior 
arrangements to have someone else conduct quarters.  The applicant asked the CO, who 
had  come  in  just  to  present  the  awards,  if  he  wanted  to  handle  the  teleconference 
instead.  In addition, there was no inscription at all on a plaque intended as the Sailor of 
the Quarter award. 
 
 
The  CO  alleged  that  “on  numerous  occasions,  quarters  did  not  go  smoothly.  
New members would be in the audience and we would be surprised by that fact and 
would  have  no  ballcap  to  present.    We  would  have  awards  to  present  that  weren’t 
mounted for presentation, didn’t have “o” devices attached, and were not engraved.  In 
addition, we had no Officers Call so no one knew what anyone was going to [say].” 
 
In rebuttal, the applicant alleged that the “CO came in off leave with what was 
 
evidently an unrealistic expectation of quarters.”  He alleged that he was prepared for 
both  quarters  and  the  teleconference  but  the  CO,  who  came  in  because  of  the  large 
number of awards being presented, was not prepared to conduct quarters.  The appli-
cant also stated that he personally put the “o” devices on the awards. 
 
COMMENT  [7]:    “MLC  Compliance  criticized  urinalysis  program  for  lack  of  year-
round testing” 
 

The applicant alleged that the verbal outbrief was not more critical than the writ-

 
The  applicant  submitted  the  MLC  Inspection  Report,  which  contains  a  recom-
mendation  that  the  Group  conduct  one-quarter  of  its  annual  allotment  of  urinalysis 
testing each quarter of the fiscal year.  The applicant also submitted a copy of an email 
showing that the Group’s urinalysis program met 131% of its goal in FY2004, up from 
119% the year before, even though they had no health services technician until late June.  
The applicant argued that the CO chose to take the recommendation as criticism. 
 
 
The CO stated that in the fall of 2003, a few crewmembers had tested positive for 
drug  use  so  he  “tasked  [the  applicant]  with  pursuing  the  urinalysis  program  aggres-
sively.”  He stated that this SOER comment was based on the MLC Compliance team’s 
verbal outbrief on the urinalysis program, which was more critical than the final report, 
which recommended spreading out urinalyses as only a recommendation.  The report 
showed that the Group’s urinalyses had been “crammed” prior to the inspection as 42% 
of  the  samples  were  collected  during  the  month  before,  while  during  the  prior  five 
months, only three samples had been collected. 
 
 
ten report. 
 
COMMENT [8]: “no one available to present morale account to inspectors, resulting 
in lenient ‘not ready for inspection’ result”  
 
 
The  applicant  stated  that  at  the  time  of  the  inspection,  the  morale  officer  was 
attending  very  important  training  out  of  state  and  could  not  present  the  paperwork.  
The applicant stated that “[a]dmittedly, there had been shortfalls in the morale account, 
but  the  morale  officer  relief  had  been  conducted  and  the  paperwork  and  the  account 
funds were all in order.”  He submitted copies of the paperwork.  Although the Group’s 
Administrative Officer was ready to present that paperwork, because of the morale offi-
cer’s  absence,  the  inspector  “decided  it  was  more  efficient  to  give  a  ‘not  ready  for 
inspection due to operational commitments’” rating.  The applicant stated that the CO 
“had received three briefs on the shortcomings of the morale account” and that five of 
the documents the inspector could not locate were on the CO’s desk awaiting his signa-
ture. 
 
The CO stated that the applicant had been XO for two and one-half years at the 
 
time  of  the  MLC  inspection  and  that  the  records  were  in  such  poor  shape  that  the 
inspector could not “make sense of them.”  The CO stated that there “was no account-
ing of funds coming from the coffee machine” and “no budgetary breakdown by unit, 
allowing  the  Group  staff to spend money that rightfully belonged to our subordinate 
units.”  In addition, the morale officer had “bounced a check” written to a subordinate 
unit.    The  CO  stated  that  if  morale-related  paperwork  was  in  his  in-box  during  the 
inspection,  the  applicant  should  have  asked  him  to  sign  the  paperwork  before  the 
inspection. 
 

The  PRRB  argued  that  the  MLC  Compliance  Inspection  Report  verified  this 

 
comment. 
 
COMMENT  [9]:    “ill-prepared  for  transfer  season  (no  unit  ball  caps,  no  plan  for 
comms watch rotation, last minute/ late awards)”  
 

The applicant stated that during the transfer season, he was “fully engaged” and 
worked with the Operations Officer “to ensure departmental manpower shortages were 
addressed.”  In addition, he “monitored situation and worked w/ OS assignment offi-
cer to consider all possible resources” and “to ensure we got relief as timely as possi-
ble.”    Regarding  the  awards,  the  applicant  stated  that  he  personally  processed  32 
awards for departing staff and that 31 were delivered before the staff members left the 
Group.  Only one had to be mailed to the member’s new unit.  The applicant alleged 
that such mailings are so common that he did not even consider criticizing the person 
from one of the Group’s subordinate units who submitted the award late.  Regarding 
the ball caps, the applicant stated that the Coast Guard Exchange System had ball caps 
that referred to their unit as “Station Xxxxxxxx,” rather than “Group Xxxxxxxx,” even 
though  there  is  no  “Station  Xxxxxxxx.”    As  soon  as  he  learned  of  the  problem,  he 
ensured ballcaps were ordered and “by September every new member had a new cap 
and there were twelve more in stock.”  He submitted an email from second class petty 
officer regarding the problem with the Exchange. 
 
 
The CO stated that the applicant’s planning was inadequate.  The ballcaps were 
delayed and there was “no planning for going-away get-togethers.”  In addition, there 
were “last minute awards (a couple signed within 15 minutes of presentation).” 
 

COMMENT  [10]:    “no  plan  developed  for  departure  of  LTJG  (EKMS  relief, 

The PRRB argued that the documentation of the “feedback sessions” shows that 
the  CO  “had  provided  clear,  written  expectations  and  that  Applicant  failed  to  meet 
those expectations.” 
 
 
morale)”  
 
Applicant’s Arguments 
 
 
The applicant stated that “the initial plan was for morale to go to an Ensign on 
staff.”  However, a new chief petty officer took over morale, instead, before the LTJG 
left.  Moreover, the applicant stated, there was a plan in place for the Operations Center 
supervisor to become the EKMS alternate.  Therefore, the applicant alleged, this SOER 
comment is false and punishable under Article 107 of the UCMJ.   
 

In support of his allegations, the applicant submitted a statement signed by the 
Operations Center Supervisor, who wrote that when the EKMS alternate was selected 

for  flight  school  in  August  2004,3  the  Operations  and  Communications  Centers  were 
understaffed and so no one could attend EKMS manager school to qualify as the alter-
nate EKMS manager.  Moreover, the Group was “unable to obtain an emergency quota 
to [have someone at the Group attend] EKMS manager school.”  Therefore, before the 
EKMS alternate left, he himself “began the process of learning the EKMS alternate posi-
tion by both completing training on the EKMS computer system self study guide and 
beginning the completion process of the JQR instruction.”  So that he could balance that 
self  study  with  his  regular  SAR  duties,  the  applicant  and  the  CO  agreed  to request a 
waiver contingent upon him completing the JQR instruction by October 15, 2004.  The 
waiver  was  requested  before  the  EKMS  alternate  left  but  granted  by  Headquarters 
afterward. 
 
 
The CO stated that because the applicant did not plan adequately the relief for 
these  positions  did  not  go  smoothly.   He stated that the “reliefs were haphazard and 
reactionary.” 
 
 
The PRRB argued that the state of the morale account documents submitted by 
the  applicant,  the  MLC  Compliance  Inspection  Report,  and  the  documentation  of  the 
feedback sessions show that the applicant failed to meet the CO’s clear, written expecta-
tions with respect to relief of departing personnel. 
 
COMMENT [11]:  “released ‘possible compromise’ message without briefing CO”   
 
 
The applicant stated this was a one-time event that the CO apparently took as a 
usurpation  of  his  authority  rather  than  a  pragmatically  efficient  show  of  initiative  on 
the applicant’s part.  The applicant stated that his action “followed [the District] secu-
rity  manager’s  guidance”  and  that  there  was  no  “evidence  of  operational  impact  or 
importance.” 
 
 
The CO stated that he had no problem with the applicant releasing the message 
as  he  had  “by  direction”  authority  to  do  so  but  that  the  applicant  failed  to  brief  him 
first.  “In other words, my boss at the District would know that I had a possible com-
promise of classified material at my unit before I did.” 
 
In rebuttal, the applicant stated that although he “did not brief the CO, [he] was 
 
under the impression that the Chief had briefed him.”  Therefore, it was an issue of mis-
communication and “not a usurpation of the CO’s authority.” 
 
COMMENT [12]:  “Failed to adapt/respond: in midst of difficult fatality case/mishap, 
relieved  as  President,  Local  MAB  (failed  to  pull  radio  tapes,  develop  inventory,  or 
provide investigator with comprehensive evidence package)”  
 
                                                 
3  However, in written feedback dated August 13, 2004, the CO noted that the officer had been selected for 
flight school”[a]lmost two months ago.” 

Applicant’s Arguments 
 
 
The  applicant  stated  that  he  was  first  to  debrief  the  members  involved  in  the 
mishap.  Moreover, following the mishap, he personally conducted a full inventory and 
did most of the work himself, and the CO used this fact to relieve him as president.  The 
applicant stated that he had the tapes copied as soon as manpower was available but 
“had to actually intervene and point out to the CO that we were operating dangerously 
close  to  missing  distress  calls  because  the  tapes  were  being  pulled  in  the  Operations 
Center.”  Even after he was relieved as president, the Mishap Analysis Board (MAB) got 
everything they needed from him. 
 
 
In support of his allegations, the applicant submitted a statement signed by the 
commander  appointed  by  the  Commandant  to  serve  as  president  of  the  MAB.    He 
wrote that the applicant “provided me excellent support with all administrative issues 
and requirements.  Upon arriving at the Group office, I was met with a complete pack-
age  of  all  related  material  regarding  this  mishap.    Statements,  radio  logs,  Group/Sta 
Chrono  Logs,  press  releases,  pictures  and  local  coast  pilot  information  were  all  gath-
ered, neatly packaged and awaiting my arrival.  During my time at the Group, I was 
provided all the support I requested by [the applicant] immediately upon my asking.  
The  on-site  investigation  went  very  well,  in  large  part,  [due]  to  the  organization  and 
initiative demonstrated by [the applicant]. …  His support was always very timely, very 
professional and greatly appreciated.”  The applicant also submitted a letter from the 
District  Commander  to  the  Commandant  stating  that  in  July  2004,  the  Group’s  “pre-
mishap plan worked exceptionally well during this mishap.” 
 
CO’s Arguments 
 
The CO stated that he removed the applicant as president of the MAB because 
 
the applicant failed to collect all required blood samples; notified the Safety Officer but 
told him not to come to the office; had no emergency child care plan, contrary to the 
CO’s direction and so had to bring his pre-school children to the office; waited until the 
morning to collect urine samples and sent them directly to the lab, instead of holding 
them for the investigating officer, so no subsequent testing could be done; failed to pull 
the DVL (radio) tapes in accordance with standard practice; did not prepare an inven-
tory  of  evidence  until  the  CO  called  him  several  days  later  at  home  about  it;  left  the 
office on the day of the mishap without checking in with the CO; failed to delegate tasks 
so that he photocopied hundreds of pages himself and “sat in the pump house by him-
self filling out an inventory sheet”; did not keep the CO adequately informed; did not 
timely issue a required 72-hour report; and failed to check the radio logs before a pack-
age  was  sent  to  the  investigator.    The  CO  stated  that  ultimately  the  evidence  was  in 
good  shape  for  the  safety  investigator  because  the  administrative  investigator  “spent 
about a week at the unit collecting data and interviewing people.” 

 
Reviewer’s Comment 
 
The  reviewer  stated  that  following  a  mishap,  the  local  MAB  was  supposed  to 
 
gather  evidence  and  data  to  hand  over  to  a  Commandant-appointed  MAB  when  it 
arrived.  On the day after the mishap, the CO “reported that [the applicant] had been 
unable to devote his full attention to the MAB duties overnight because he was simul-
taneously caring for his children while his wife was away.”  The CO later told him that 
he  had  replaced  the  applicant  as  MAB  president  because  the  applicant  “had  not 
performed all of the duties expected of the MAB president and particularly that he had 
not  secured  the  radio  tapes  or  developed  a  chain-of-custody  inventory  of  the  mishap 
evidence.”  The applicant later assisted the officers appointed to conduct the adminis-
trative and mishap investigations, “using evidence that both he and [the officer the CO 
chose to replace him] had collected during their respective periods as MAB president.”   
 
CGPC’s Comment 
 
CGPC states that the commander who wrote on behalf of the applicant did not 
 
arrive  at  the  Group  until  several  weeks  after  the  mishap  occurred  and  so  could  not 
address the reasons for the applicant’s removal as president of the MAB. 
 
Applicant’s Rebuttal 
 
 
The  applicant  stated  that  he  did  not  immediately  order  blood  tests  because 
Headquarters told him that it “was not so much an issue and that the urine would tell 
them the same information.”  He stated that he could not hold onto the urine specimens 
because  the  Group  did  not  have  anywhere  to  store  them.    He  stated  that  he  told  the 
safety officer that he would check the mishap plan to see if he needed him and later had 
the safety officer come in to assist.  The applicant stated that he “did not delegate [MAB 
duties such as photocopying] because [he] wanted to keep positive control” and he did 
not  report  back  to  the  CO  because  the  CO  had  told  him  they  would  keep  the  MAB 
duties and SAR duties, which the CO was overseeing, separate and the applicant “had 
no reason to believe that autonomy had been rescinded.” 
 
In  support  of  these  allegations,  the  applicant  submitted  a  statement  from  the 
 
Reserve captain who took over as president of the MAB at the direction of the CO.  The 
captain stated that the mishap occurred on a reserve drill weekend.  As president of the 
MAB, the applicant was busy “preparing for the arrival of the Headquarters-assigned 
MAB, making copies, organizing manuals, [and performing inventory on] the contents 
of  the  boat.”    The  CO,  however,  did  not  think  that  the  applicant  was  working  fast 
enough or delegating enough work or was in full control.  When the CO asked the cap-
tain’s opinion, the latter stated that he thought “everything was going just fine” but he 
“accepted  the  challenge”  when  the  CO  later  asked  him  to  take  over.    Therefore,  he 
stayed on active duty for an extra four days, though he “honestly did not see the need,” 

and the applicant helped him whenever he asked for assistance.  The captain stated he 
does not believe that he himself “added any significant value to the process” because 
the  applicant  “had  compiled  most  of  the  information  himself.”    He  stated  that  he 
admired the applicant’s willingness to assist and stoic and pragmatic reaction to being 
relieved as MAB president.  He stated that both the applicant and the CO were very fine 
officers who “did not get along.” 
 
COMMENT [13]:  “even after red-flag warning by admin officer for morale 1 month 
in advance, account in poor shape for MLC inspector”  
 
The applicant stated that the “red flag” was that “the units were not keeping re-
 
cords  of  their  sales.”    Therefore,  in  accordance  with  guidance  from  the  District,  he 
stopped all sales and had the subordinate units’ morale officers collect and account for 
funds.    Further,  he  argued,  since  the  morale  account  was  “not  ready  for  inspection,” 
there is no documentation that it was actually in “poor shape for MLC inspector.” 
 
 
The  CO  stated  that  the  account  was  in  poor  shape  if  it  was  “so  disorganized 
[that] the MLC inspector [could not] make sense of it.”  He also noted that cups of quar-
ters from the coffee machine sat in the applicant’s office for a couple of weeks. 
 
COMMENT  [14]:    “neglected  to  pass  written  MI  discrepancies  from  CO  to  depart-
ment heads”  
 
 
The applicant alleged that the Engineering Officer kept the discrepancy list and 
that he himself “started using the CO’s work list as a notification tool for tasks/actions 
required by department heads.” 
 
The CO stated that this was a list of immediate repair issues that he had given 
 
the applicant on May 19, 2004.  He did not expressly tell the applicant to pass the list to 
the department heads but assumed that he would as there was no other way to accom-
plish  the  tasks.    However,  about  a  month  later,  the  Engineering  Officer,  who  was 
responsible for many of the items on the list, had not received it from the applicant. 
 
 
In rebuttal, the applicant stated that he did not pass any of the information in the 
CO’s written feedback dated May 19, 2004, to the department heads but that they “were 
directed to conduct a thorough cleanup of their respective areas.” 
 
COMMENT [15]:  “unresponsive to clear guidance by CO after frequent oral & writ-
ten feedback” 
 
 
The applicant submitted an email from the CO in which the latter wrote, “you 
were acting Group Commander last week and held down the fort well in my absence.”  
He further stated that the CO’s “written feedback and counseling sessions” started on 
August 13, 2004, just forty days before he was relieved as XO.  The applicant submitted 

The CO stated that he gave the applicant “frequent oral and written feedback” 

two “feedback sheets” he received from the CO.  He stated that when he tried to explain 
the circumstances around certain matters listed on those sheets, the CO was not inter-
ested in “the full story” and formed negative opinions of his performance and respon-
siveness instead of acquiring “a comprehensive understanding of the situations.” 
 
 
and submitted copies of some of his written feedback. 
 
COMMENT  [16]:    “OER’s  submitted  in  good  quality,  but  some  late  due  to  poor 
tracking” 
 
 
The  applicant  referred  to  his  arguments  concerning  comment  [1]  above.    He 
stated that his tracking was not poor and did not cause any OERs to be late, since he 
“knew exactly were [the] OERs were and why they were there.”  He repeated his allega-
tion that during his entire time at the Group, only one OER for which he was responsi-
ble  was  late  and  that  was  because  he  had  to  help  the  reported-on  officer  prepare  his 
documentation as it was that officer’s first OER. 
 
 
The CO stated that, according to the District, thirteen OERs for officers working 
at the Group or its subunits arrived late during the evaluation period.  The CO stated 
that  while  he  himself  is  “solely  responsible  for  this  miserable  record,”  the  applicant 
“never seemed to assume ownership for all OERs (active and reserve).” 
 
 
The applicant stated that he was not responsible for any OERs but the three he 
mentioned but still put the other officers’ OERs on the Group Worklist “as a reminder 
for those responsible for their submission.” 
 
COMMENT [17]:  “enlisted evals accurate, requiring minor changes, but Group staff 
E-6 marks 45 days late” 
 
Applicant’s Arguments 
 
 
The applicant stated the CO had told him that “it was acceptable for things to be 
late as long as [he] provided an explanation” but that the CO provided him with “no 
adequacy measure” to determine whether his explanations would be acceptable.  The 
applicant further stated that he was neither the supervisor nor marking official for any 
E-6, but simply reviewed the E-6 evaluations prior to putting them on the CO’s desk for 
signature as the approving official.  He stated that he “knew the evals were late, but it 
was more important to follow the Commandant’s Standing Orders and ‘lean forward’ 
and  ‘take  risks’  for  the  professional  growth  of  our  people  (specifically,  the  new  YNC 
who needed to get onboard and learn the in-house process of routing evaluations), and 
in this case, for the benefit of the unit’s automated process.  No E-6 lost any professional 
opportunities because of the slow routing of the evaluations.” 
 

In  support  of  his  allegations,  the  applicant  submitted  a  statement  by  a  senior 
 
chief yeoman, who wrote that when he was preparing to leave the Group in May 2003, 
he  and  the  applicant  discussed  how  he  would  turn  over  his  duties  to  the  new  chief 
yeoman (YNC).  They discussed how the “enlisted evaluation tracking spreadsheet … 
was an effective and innovative tracking system to ensure that 100% of the evals were 
tracked and properly accounted for. …  [The applicant] and I had agreed to let the new 
YNC handle the May E-6 evals since it was close to his report date … .  Also, I was there 
to assist to launch the process with him.  I had understood that [the new] YNC under-
stood  the  program.    However,  as  with  any  new  program,  it  may  have  prolonged  its 
completion since he was still learning it.” 
 
CO’s Arguments 
 
 
The  CO  stated  that  while  the  applicant  may  have  agreed  to  a  delay  in  the  E-6 
evaluations, he himself had not agreed to any such plan.  He further stated that he does 
not see what leaning forward and taking risks have to do with late performance evalua-
tions.  The CO submitted copies of memoranda showing that the evaluations were late 
due to “1) input from departments; 2) hand off of YNC(S) duties; 3) familiarization w/ 
[Group] process for YNC.” 
 
PRRB’s Arguments 
 
 
marks were submitted late” and that therefore the comment is supported. 
 
Applicant’s Rebuttal 
 
 
eleven months and had not been told that his autonomy was rescinded.  
 
COMMENT [18]:  “[The applicant] has been passively stubborn in not adjusting to or 
meeting my expectations for my Deputy Group Commander.”   
 
Applicant’s Arguments 
 
 
The applicant argued that the CO had no basis for this comment since he met all 
of the written expectations provided to him by the CO on May 19, 2004.  The applicant 
stated  that  he  developed  all  of  the  tickler  lists  and  status  sheets  as  soon  as  the  CO 
requested them; used “empowerment initiatives [which] led to positive results/signifi-
cant change in every area of [the] Organizational Assessment Survey”; and “[r]esource-
fully captured Active Duty/Reserve/Auxiliary capabilities to finalize CO’s concept of a 
seasonal mobilization plan.”  The applicant stated that he himself completed and priori-
tized an SAR response plan conceived by the CO and yet he was unfairly criticized for 
not being aware of or overseeing SAR.   

The  applicant  stated  that  he  had  been  granted  autonomy  in  such  matters  for 

The PRRB stated that the senior chief yeoman’s statement “is verification that the 

 
 
The applicant stated that he “looked to the CO for more visionary leadership, but 
what [he] got was ‘pull the prongs out on the presentation medals.’  Which … he did.  
With the lack of communication re his command vision, [the applicant] continued [his] 
leadership  initiatives  seeking  unit  transformation  base  on  crew  ownership.    [The  CO 
saw that as passive stubbornness not to adjust to his expectations, and could not see the 
positive outputs the crew was producing for him.” 
 
CO’s Arguments 
 
In his declaration to the PRRB, the CO provided numerous documents concern-
 
ing feedback he had provided the applicant during the reporting period.  He stated that 
he provided the applicant with “a great deal of feedback in hopes that [his skills] would 
changed.    I  needed  improvement  in  his  performance,  but  his  performance  remained 
virtually unchanged.”  The CO noted that during a counseling session in August 2004, 
the applicant had told him that the counseling was “of no use and [that he] saw no rea-
son to continue.” 
 
 
The CO further stated that the applicant frequently spoke of himself as a “trans-
formational leader.”  The CO, however, “did not care about his methods as much as I 
cared about results.  When [the applicant] clearly knew that I wanted things to get done 
and he would not get them done, I viewed his actions as stubborn. … [H]e was stub-
born about meeting only his own expectations and not mine.”  The CO stated that dur-
ing their counseling session on May 19, 2004, “[i]nstead of saying that he would buckle 
down and get the job done, [the applicant] said that if necessary, he would ‘take the hit.’  
This does not sound like a Deputy Group Commander who is interested in getting the 
job done.” 
 
Reviewer’s Comment 
 
 
In his declaration for the PRRB, the reviewer stated that he “would use the same 
phrase to describe [the applicant]. … His resistance to change was especially evident in 
[his] unwillingness to become more involved in the operational aspects of Group … .  
[The CO] was extremely involved in Group Xxxxxxxx’ operations and saw that as the 
key  function  of  the  Group.    He  told  me  that  in  order  to  be  an  effective  Deputy  (and 
potential Acting CO), [the applicant] also needed to be more involved in Group opera-
tions.  Station OINCs and XPOs were required to spend some time each month under-
way on their small boats and [the CO] asked for the same commitment from [the appli-
cant].    However,  [the  applicant]  espoused  his  belief  that  the  Group  was  ‘non-opera-
tional’  and  evidently  saw  his  role  as  purely  administrative.    [The  CO’s]  continued 
attempts  to  gain  his  participation  in  underway  operations  and  RFO/Stan  visits  were 
unsuccessful.” 
 

The CO stated that his written feedback to the applicant shows that the applicant 

Applicant’s Rebuttal 
 
 
The  applicant  stated  that  the  reviewer  never  once  spoke  to  him  about  his  per-
formance or relief as Deputy Group Commander.  Therefore, the applicant alleged, it is 
not surprising that the reviewer echoed the CO since the reviewer and CO had worked 
together at the District for some time. 
 
COMMENT [19]:  “Despite frequent and forthright feedback (both oral and written), 
[he] has been slow or unresponsive to tasking, deadlines, and expectations.”   
 
The applicant stated that this comment is false since he fulfilled each of the CO’s 
 
requests during the evaluation period.  He stated that he discussed the deadlines on the 
work list with the CO, who “said they would/could slide, but the important issue was 
to capture the tasks” and acknowledged that everyone in the chain of command would 
need the timelines to be adjusted.  The applicant complained that when he responded to 
the CO’s feedback, the CO did not listen or respond.  Moreover, “[t]here were no recur-
ring  issues  in  any  of  the  feedback.    Each  feedback session was a new list of the CO’s 
perceived shortcomings.” 
 
 
was not meeting his expectations. 
 
COMMENT [20]:  “He is good at responding to crises, but not at planning to prevent 
them, turning normal military events into fires to put out (awards, personnel trans-
fers, reports, evaluations, District Commander visit).”   
 
 
The applicant stated that 31 of 32 awards were delivered to the member before 
departure, that personnel transfers that summer “had no detrimental impact on mission 
capability,” and that all reports were submitted on time.  Regarding the District Com-
mander’s visit, the applicant alleged that it was “not a crisis situation” even though they 
were given only four days’ notification and that he made positive comments about the 
Group.  
 
 
The  CO  stated  that  the  applicant  did  not  hold  regular  meetings  of  department 
heads or have “officers call prior to quarters. …  Consequently, the staff did not have 
coordinated, planned direction.  We got things done, but frequently it was reactive, not 
pro-active.” 
 
COMMENT  [21]:    “Chooses  ‘inspirational’  leadership  model,  but  lacks  ability  to 
adapt where it falls short.” 
 
The applicant alleged that “there is no evidence of instances where [his] leader-
 
ship fell short.”  He noted that in prior OERs, he had been commended for his leader-
ship  style.    He  submitted  a  copy  of  the  results  of  the  Group’s  Organizational Assess-

 

ment Survey, which, he alleged, “show the value a transformational/inspirational lead-
ership  style  can  provide  a  unit  (i.e.,  results  and  effectiveness).    The  across-the-board 
improvements in the OAS results are a direct indication of the work climate [the appli-
cant]  built  in  [his]  two  years  [at  the  Group]  through  [his]  leadership,  initiative,  and 
planning.” 
 
 
The  CO  stated  that,  while  he  likes  inspirational  leadership,  “at  times,  the  XO 
needs to be tough on the crew.  Not once did I see [the applicant] be tough on a crew-
member” during the evaluation period. 
 
COMMENT [22]:  “Lacked initiative/career development.” 
 
Applicant’s Arguments 
 

The applicant stated that this comment is false.  He pointed out that he was tak-
ing  classes  towards  a  doctoral  degree  that  summer  and  received  a  3.85  grade  point 
average.    He  alleged  that  this  comment  is  indicative  of  the  CO’s  “under-appreciation 
and/or  lack  of  understanding  for  the  working  environment  and  the  effort  it  takes  to 
make it optimum.”  He stated that his “boat forces days” and “operational expertise” 
were acquired as a junior officer and that his career path is “human resource and orga-
nizational development.”  Therefore, while being on the boats it fun, it was not neces-
sary  since  that  department  was  being  managed  well  and  did  not  need  to  be  micro-
managed, although the CO “obviously expected” it.  Instead, he focused his efforts and 
initiatives on “[r]etention, morale, rewards and recognition, people first initiatives and 
stewardship [which] were all being pointed out as organizational leadership concerns, 
needing local intervention.”  The applicant alleged that his initiatives “were simply not 
recognized as such.” 
 
CO’s Arguments 
 
 
The CO stated that he had spelled out both verbally and in writing to the appli-
cant  that  he  expected  the  applicant  to  be  able  to  assume  his  operational  duties  in  his 
absence.  The CO stated that such directions are usually unnecessary because most XOs 
want to become COs and so seek skills in operational areas.  The CO had told him to 
have a plan for emergency child care when his wife was out of town on long business 
trips, but the applicant did not do so.  The CO further argued that he “should not have 
had to tell [the applicant] to read a member his rights”; “should not have had to provide 
him with templates for ticklers and worklists”; “should not have had to conduct a mate-
riel inspection”; and “should not have had to conduct weekly feedback sessions with an 
O-4.”  Therefore, the CO stated, “I stand by my comment that [the applicant] lacked ini-
tiative.  Further, he took few steps to improve himself professionally on the operational 
side.    I  recognize  that  he  had  given  up  on  the  operational  mission,  but  since  he  was 
acting CO in my absence, I could not allow him to stop learning about the operational 
mission.” 

 
Applicant’s Rebuttal 
 
The applicant alleged that “by making and maintaining his assumption [that the 
 
applicant wanted to command], the CO … totally discount[ed] my aspirations.  Having 
already been a commanding officer, I was not interested in the CO’s recommendation 
for command, and told him that in many of our discussions.  My career aspirations are 
toward assignments in Human Resources and leadership policy, but the CO considered 
my career intentions invalid, and used his own aspirations to evaluate my initiative and 
career development plans.” 
 
COMMENT [23]:  “did not set foot on a CG boat during entire reporting period” 
 
 
The applicant stated that this comment is a false exaggeration as he did a “bow-
to-stern inventory” onboard the boat involved in the mishap on July 20, 2004.  More-
over, he argued, the busy SAR season, which the SOER covered, is hardly the time to 
ask the Operations Division to take the Group XO (himself) on a boat ride, as it was not 
a  responsibility  or  expectation  that  he  (or  any  XO)  do  so.    Getting  on  a  boat  that 
summer  would  not  have  developed  his  career  “in  a  way  that  can’t  be  done  through 
communicating  with  crews,  Officers-in-Charge,  and  [subordinate]  unit  COs  …  which 
[he]  did  routinely.”    The  applicant stated that this SOER comment “does not support 
any performance dimension or any organizational expectation/standard and does not 
support a mark of three in initiative.”  He argued that there was no need for him to step 
on a boat and that whether he did so that summer is irrelevant to whether he showed 
initiative and interest in his career development. 
 
 
The applicant also argued that he showed initiative during the evaluation period 
by “[c]oordinating an workplace climate diagnosis w/ George Washington University 
and STA OIC [the Station Officer in Charge] based on symbolic space and power theory 
to help OIC institutionalize professionalism.” 
 
 
The CO stated that his “OER feedback” to the applicant in early May 2004 stated 
the expectation that the applicant “get underway with our units on a periodic (monthly) 
basis.”  The CO stated that setting foot on a boat that has capsized in the surf “is not the 
type  of  operational  involvement  that  I  expect  from  my  deputy.    I  prefer  operational 
leadership to prevent mishaps, not to investigate them.” 
 
COMMENT [24]:  “did not participate in Ready for OPS (RFO)/STAN visits” 
 
 
The applicant stated that there “was no expectation presented for [him] to con-
duct any aspect of the Ready for Operations program” and that he trusted the Opera-
tions Officer to do his job.  He argued that whether he participated in the RFO/STAN 
visits  is  irrelevant  to  whether  he  showed  initiative and interest in his career develop-
ment and that his decision not to participate in the visits did not support a mark of 3 in 

the performance dimension “Initiative.”  He argued that his participation would have 
been a “wasteful use of human resource capacity.”  However, he edited the RFO result 
letters  sent  back  to  the  subordinate  units  and  therefore  gained  operational  readiness 
oversight through routine interactions with the unit command cadres. 
 
 
The “OER feedback” counseling that the CO provided to the PRRB indicates that 
he  told  the  applicant  in  May  2004  pursuant  to  his  prior  OER  that  the  applicant  was 
expected to “participate in the RFO program.” 
 
COMMENT [25]:  “took no steps to develop plan for himself or subordinates to earn 
boat forces pin” 
 
Applicant’s Arguments 
 
 
The applicant alleged that during the evaluation period, he drafted a memoran-
dum  to  have the CO authorize officers and chiefs to sign off on boat forces qualifica-
tions standards; he got a chief boatwain’s mate and a chief machinery technician to pre-
pare the curriculum; and he laid the “groundwork to develop a block of instruction for 
boat  forces  qualifications  to  be  implemented  after  SAR  season.”    Therefore,  the  com-
ment  that  he  “took  no  steps”  is  absolutely false.  The applicant further stated that he 
was  the  only  officer  on  staff  who  was  eligible  for  the  boat  forces  pin  because  he  had 
served at a boat force unit for at least five years.  The applicant submitted a copy of a 
memorandum  from  the  CO  dated  June  15,  2004,  in  which  he  designated  the  Group’s 
officers and chiefs as “instructor[s] authorized to verify certification of members work-
ing  on  the  Boat  Forces”  qualifications.    The  letter  also  states  that  “[a]s  a  designated 
instructor,  you  will  prepare  blocks  of  instruction  and  present  the  information  to  boat 
forces personnel. …  The Deputy Group Commander will prepare a training/presenta-
tion schedule and will help you prepare your respective training blocks.” 
 

In  support  of  his  allegations,  the  applicant  also  submitted  a  statement  from  a 
chief  boatswain’s  mate  (BMC),  who  wrote  that  to  the  “best  of  my  recollection,  [the 
applicant] and myself did in fact have conversations pertaining to the construction and 
implementation of a boat force qualification process at Group … .  Soon after I checked 
in on July 01, 2004, [the applicant] discussed using my experience as a Boatswain’s Mate 
to  come  up  with  a  formal  training  program  for  those  members  wishing  to  qualify  as 
boat crew and compete for the Boat Forces Pin.  On a separate occasion, we revisited 
this  idea  and  decided  to  set  it  aside  until  the  Ready  For  Operations season on the 47 
MLB was complete.”   
 
CO’s Arguments 
 
The  CO  stated  that  his  OER  feedback  to  the  applicant  in  early  May  included 
 
“mak[e]  substantial  progress  toward  your  boat  forces  pin.”    The  CO  stated  that 
although  he  signed  the  designation  letter  that  the  applicant  prepared,  nothing 

happened thereafter, and he believes that the applicant “was simply trying to placate 
me.”  The CO stated that after he signed the letter “there was not one step forward on 
quals  or  PQS  toward  the  boat  forces  pin  [for  the  applicant  and  four  other  officers 
assigned  to  the  Group]  with  the  exception  of  a  comms/controller  qual”  for  one  lieu-
tenant junior grade. 
 
CGPC’s Comment 
 
 
directions given him in CO’s designation letter. 
 
Applicant’s Rebuttal 
 

CGPC noted that there is no evidence that the applicant followed through on the 

The applicant stated that none of the four officers mentioned by the CO had time 
that summer to qualify for a Boat Forces Pin, so he took steps to have the training con-
ducted in the fall.  The applicant submitted an email from a BMC who wrote that he 
had brought the boat crew guide to the applicant and explained to him that most of the 
qualifications  could  be  done  in  the  office.    An  email  from  another  BMC  states,  “I 
remember that you were in the process of crewman qualification.” 
 
COMMENT [26]:  “took no remedial area familiarization action when, as acting CDO, 
did not know location of … Xxx (xxx Group is located on)”  
 
 
The  applicant  stated  that  when  he  was  asked  where  a  particular  xxx  was,  he 
knew and stated its general location only.  He stated that the Group is always referred 
to as being located on the bay itself, not the xxx.  Moreover, the CO’s question was not 
related to any case, and as Command Duty Officer, he always “use[d] the local Marine 
Atlases to ensure [he] was well-informed during the prosecution of operational cases.” 
 
 
The CO stated that the point of this comment was that the applicant knew he was 
not  familiar  with  the  geography  of  the  area  and  “should  have  had  the  initiative  and 
sense of responsibility to review his area fam.”  The CO’s feedback notes dated August 
30,  2004,  indicate  that  the  issue  arose  when  the  applicant  informed  the  CO  that  the 
police had reported that a man had committed suicide by “walking off a dock in Xxxx 
xxxx.”  The applicant pointed west and “said it was somewhere near the Forge River.”  
The  CO  pointed  out  that  “[i]f  the  crew  took  three  steps  backward  at  quarters,  they 
would  fall  into  Xxxx  xxxx.    The  fact  that  you  did  not  know  that  is  disconcerting.    I 
attribute that lack of knowledge to your lack of underway time.” 
 
 
In  his  declaration,  the  reviewer  stated  that  the  applicant’s  “lack  of  familiarity 
with  the  Group  Xxxxxxxx  area  of  responsibility,  including  the  name  of  the  body  of 
water  that  the  Group  offices  are  located  on,  called  into  serious  question  his  ability to 
perform as Acting CO.  Although administrative and personnel functions are certainly 

The CO stated that he verbally directed the applicant to flag important message 

primary  duties  for  an  XO,  I  do  not  believe  that  a  Deputy  Group  Commander  should 
exclude himself from the reason that a Group exists:  to execute operational missions.” 
 
In rebuttal, the applicant claimed that there “was no expectation for me to have 
 
any area familiarization” and that it was his practice to rely on the GDOs and the mari-
time atlas. 
 
COMMENT  [27]:    “failed  to  flag  important  message  traffic  while  CO  on  leave 
(COMDT Sector impl., D1(dcs))” 
 
The applicant stated, “I have no proof that he told me not to, but he told me not 
 
to.”  The CO had told him to “stand down from the practice,” which was in place and 
his  standard  practice  when  the  CO  first  took  command.    The  applicant  submitted  a 
statement from the prior Group Commander who wrote that during his tenure, “it was 
common  practice  for  [the  applicant]  to  flag  important  messages  for  me  while  I  was 
away from the office.  This was initiated by the two of us, and was in place when I left.  
I cannot speak to any conversations that went on between [the applicant and the next 
Group Commander/CO] after the change of command, but [the applicant] was in the 
practice of ensuring the CO was informed of important messages upon returning to the 
office while I was the Group Commander.” 
 
 
traffice and “should not have even needed to say it.” 
 
COMMENT [28]:  “sponsored fancy work contest” 
 
 
The applicant alleged that this contest happened during the previous evaluation 
period  and  so  should  not  have  been  mentioned  in  the  SOER.    The  CO  stated  that  he 
cannot remember the date of the contest.  The JAG and CGPC recommended that the 
Board remove this comment from the SOER since the CO does not remember. 
 
COMMENT [29]:  “While he was successful as the personnel officer in many respects, 
he failed to grasp the breadth of his duties as the Deputy Group Commander, falling 
short on operational matters, accountability, and unit planning.” 
 
Applicant’s Arguments 
 
 
The  applicant  stated  that  he  took  advantage  of  a  storm  warning  to  test  and 
improve the Group’s hurricane plan; that he was first to debrief members after a boat 
mishap; that he personally conducted the inventory following the mishap and worked 
with Navy personnel to have the data on the radio tapes transferred to a CD; and that 
he  “captured  lessons  learned  to  improve  [the  Group’s]  mishap  plan.”    The  applicant 
alleged that “[a]ll unit plans were in place, and the hurricane and MISHAP plans were 
put to use/tested during this period.  [He] was engaged with the breadth of [his] XO 

duties, but [he] did not have to duplicate the work of the Operations Officer (i.e., con-
duct  RFO,  get  underway,  etc.)  to  show  that  [he]  was  maintaining  [his]  competencies 
that were documented in three previous OERs in the XO role.”  
 
 
Group Commander, who wrote the following: 
 

In support of his allegations, the applicant submitted a statement from the prior 

[The applicant] did an exceptional job as Deputy Group Commander during my time as 
Group Commander … .  He consistently exemplified outstanding leadership as Deputy 
and  is  the  primary  reason  that  we  not  only  improved  readiness  in  my  last  year  but 
improved morale dramatically as well.  His creative leadership and focus on encouraging 
the crew to assume ownership of our successes led to numerous personnel turnarounds 
… .  [H]is performance and sound judgment provided me the utmost confidence in his 
abilities to run the group in my absence—which he successfully did on numerous occa-
sions.  Based on a little over a year with him, I came to the conclusion that he was quali-
fied … to be successful as a Group Commander … [H]is innovative leadership and skill 
at  utilizing  the  expertise  of  those  around  him,  combined  with  his  robust  enthusi-
asm/engagement on operational issues reflected the maturity and judgment of someone 
with  far  more  operational  experience  than  he  had  upon  arrival.    In  addition,  I  ensured 
that he was involved with or briefed thoroughly on every operational issue I dealt with to 
guarantee he had the depth of knowledge necessary to be successful in that role.  I had no 
reservations at that time and have no knowledge of any information that would change 
that opinion today. …  

 
CO’s Arguments 
 
 
The CO stated that the applicant “viewed his responsibilities as extending only 
to  the  Group  staff  and  not  the  six  subordinate  units.    At  times,  he  even  viewed  his 
duties as solely those things that came across his desk.  In other words, because there 
was an operations officer, he was not responsible for operations.  As the Deputy Group 
Commander,  he  was  responsible  for  all  the  missions  and  people  of  Group  Xxxxxxxx, 
whether he felt that way or not.” 
 

The  CO  stated  that  while  the  applicant  called  the  Group  a  “non-operational 
unit,” this perception was wrong as the CO made decisions “about launching boats and 
aircraft,  directing  searches,  making  risk  assessments,  and making next-of-kin notifica-
tions.”    The  CO  stated  that  the  applicant’s  divergent  views  and  priorities  “ultimately 
led  [the  CO]  to  relieve  him  of his duties and write a derogatory OER.”  The CO also 
alleged that before the applicant interviewed the member who confessed to drug use, 
the applicant knew that there was a drug-use allegation against that member. 
 
Reviewer’s Comment 
 

In a declaration for the PRRB, the reviewer stated that he did not directly observe 
the applicant’s performance during the evaluation period.  However, when he visited 
the Group in mid May, he “had an in-depth discussion with [the CO] concerning [the 
applicant]”  and  that  he  spoke  with  the  CO  over  the  phone about the applicant many 

times that summer.  Following that meeting, the CO gave the applicant clear, written 
expectations  as  well  as  verbal feedback.  The CO “sought [his and others’] advice for 
ideas on improving [the applicant’s] performance.”  Based on those conversations with 
the CO, the reviewer stated that he does not believe that personal feelings affected the 
SOER or the decision to relieve the applicant.  He alleged that the CO “worked hard to 
share his performance expectations, to mentor his Deputy, and to raise [the applicant’s] 
performance to an acceptable level.  In the end, he concluded that Group … would be 
best served with a more competent XO, so he relieved him.”  The reviewer wrote that 
even after reviewing all of the applicant’s rebuttals to the SOER, he does “not think that 
personal  feelings  biased  the  [SOER],  and  [he]  believes  that  it  accurately  portrays  [the 
applicant’s] performance during the period of that report.” 

FINDINGS AND CONCLUSIONS 

 
 
The  Board  makes  the  following  findings  and  conclusions  on  the  basis  of  the 
applicant's military record and submissions, the Coast Guard's submission, and appli-
cable law: 
 

 

Applicant’s Rebuttal 
 
 
The  applicant  alleged  that  this  comment  is  contradicted  by  the  fact  that  he 
received a mark of 4 for the performance category “Professional Competence,” since a 
mark of 4 is supposed to signify that the officer has shown the “high level of perform-
ance expected of all Coast Guard officers.” 
 
COMMENT  [30]:    “As  a  result,  I  can  only  recommend  him  for  administrative  posi-
tions.”   
 
 
The applicant stated that the “majority (if not all) of the XO’s day-to-day job is 
administrative”  and  that  many  of  the  criticisms  in  the  SOER  concern  administrative 
matters.  He stated that this comment therefore contradicts the rest of the OER. 
 
 
mend him for any operational positions.” 
 
COMMENT  [31]:    “He  possesses  an  extensive  educational  background  and  concern 
for junior members that should be considered in the assignment process.” 
 
 
The  applicant argued that this comment unreasonably suggests that the Group 
had no need for someone with “an extensive educational background [or] concern for 
junior  members.”    The  CO  responded  that  he  values  education  but  “being  educated 
does not negate the need to perform.”  
 

The CO stated that “[b]ased on [the applicant’s] performance, I could not recom-

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

The application was timely.   

3. 

The applicant requested an oral hearing before the Board.  The Chair, act-
ing pursuant to 33 C.F.R. § 52.51, denied the request and recommended disposition of 
the case without a hearing.  The Board concurs in that recommendation. 
 
 
Article  10.A.1.b.1.  of  the  Personnel  Manual  provides  that  “Commanding 
officers must ensure accurate, fair, and objective evaluations are provided to all officers 
under their command.”  The applicant alleged that the SOER is erroneous and unjust 
and asked the Board to remove it from his record.  To establish that an OER is errone-
ous or unjust, an applicant must prove that the challenged OER was adversely affected 
by a “misstatement of significant hard fact,” factors that “had no business being in the 
rating process,” or a “clear and prejudicial violation of a statute or regulation.”4  The 
Board  must  begin  its  analysis  by  presuming  that  the  disputed  SOER  is  correct  as  it 
appears in the record, and the applicant bears the burden of proving by a preponder-
ance of the evidence that it is erroneous or unjust.5  Absent evidence to the contrary, the 
Board presumes that the applicant’s rating officials prepared the SOER “correctly, law-
fully, and in good faith.”6  With these standards in mind, the Board has carefully con-
sidered  all  of  the  evidence  presented  regarding  the  SOER  disputed  in  this  case  and 
draws the following conclusions with respect to the evidence: 

1. 

 
2. 

 
a. 

COMMENTS [1] & [2]:  The applicant has not proved by a prepon-
derance of the evidence that these comments are false or unjust.  He has not proved that 
poor tracking on his part did not cause certain deadlines to be missed.  The fact that the 
CO may himself have signed OERs late does not disprove these comments.  The appli-
cant has not proved that given the number of missed deadlines, he did not unreasona-
bly  delay  using  “ticklers”  and  lists  to  help  prevent  missed  deadlines.    Although  the 
record  shows  that,  after  the  CO  provided  templates  for  such  tools,  the  applicant  did 
develop them during the evaluation period, the applicant’s ultimate preparation of the 
ticklers  and  lists  does not persuade the Board that the CO’s criticism and implication 
that they were needed earlier is inaccurate or unfair.  The Board notes that the CO did 
not mention missed deadlines in the applicant’s prior OER, but his silence on the matter 
in the prior OER may have been a matter of forbearance and does not disprove Com-
ments [1] and/or [2]. 
 
COMMENTS [3], [4], [5], & [14]:  The record indicates that on May 
19, 2004, the CO provided the applicant with a list of twelve “immediate” materiel dis-
crepancies  that  he  wanted  fixed.    He  also  forewarned  the  applicant  that  he would be 
                                                 
4 Germano v. United States, 26 Cl. Ct. 1446, 1460 (1992); Hary v. United States, 618 f.2d 704 (Cl. Ct. 1980); 
CGBCMR Dkt. No. 86-96. 
5 33 C.F.R. § 52.24(b). 
6 Arens v. United States, 969 F.2d 1034, 1037 (Fed. Cir. 1992); Sanders v. United States, 594 F.2d 804, 813 (Ct. 
Cl. 1979). 

 
b. 

c. 

conducting a CO’s inspection and asked him to have things ready for inspection.  The 
applicant  admitted  that  he  did  not  forward  the  list  of  twelve  discrepancies  to  the 
department heads who would have ensured that the repairs were performed.  The CO 
stated that very little was done to prepare for his materiel inspection on June 16, 2004.  
In  addition,  the  Board  notes  that  very  few  of  the  discrepancies  that  were  identified 
during that inspection and included on the discrepancy list were completed during the 
evaluation period.  Likewise, the applicant has not proved that maintenance issues such 
as falling fences, weeds, painting, and dilapidated docks were promptly taken care of 
under his direction or that, although the fitness trail was apparently usable, he ensured 
timely completion of the associated amenities in accordance with the CO’s request.  The 
applicant  stated  that  he  planned  to  wait  and have many or most of the discrepancies 
corrected in the fall after the busy SAR season.  This plan was obviously contrary to the 
CO’s  clear  request  and  expectations  that  materiel  discrepancies  be  addressed.    The 
description  of  his  weekly  XO’s inspections and purported responses does not explain 
the  extensive  list  of  unaddressed  discrepancies  he  submitted.    The  Board  is  not  per-
suaded that Comments [3], [4], [5], and/or [14] are erroneous or unjust. 
 
COMMENT  [6]:    The  applicant  alleged  that  he  was  prepared  for 
 
quarters.  However, the record shows that he asked the Engineering Officer to take his 
place at quarters just before it began even though he was previously aware that he had 
a scheduled conference call during quarters.  In addition, the CO stated that some of the 
awards were unfinished in significant ways that made it very difficult for them to con-
duct the ceremony smoothly.  The fact that one of the honorees submitted a statement 
indicating that he did not notice a problem and thought that the event was well planned 
does not disprove the difficulties encountered by the CO and the Engineering Officer.  
The Board finds that the applicant has not proved by a preponderance of the evidence 
that Comment 6 is inaccurate or unfair.  
 
 
COMMENT  [7]:    The  MLC  Compliance  team  labeled  this  issue  a 
“recommendation” in its report rather than a criticism.  The CO stated that that the tone 
of the inspector’s verbal outbrief on this subject was more critical than the report.  In 
addition, the record indicates that in the fall of 2003, the CO asked the applicant to con-
duct the urinalysis program aggressively after some members tested positive for drug 
use.  However, the Group collected 42% of its samples during the last 31 days before the 
team’s inspection.  In light of these facts, the Board cannot conclude that Comment [7] is 
erroneous  or  unfair  even  though  the  Group  ultimately  conducted  more  than  enough 
urinalyses to comply with the program requirements.  
 
 
COMMENTS  [8]  &  [13]:    The  record  indicates  that,  though  fore-
warned  of  the  upcoming  MLC  Compliance  inspection,  the  applicant  failed  to  ensure 
that he himself or someone else present could explain the morale account documents or 
that  those  documents  were  sufficiently  clear  for  the  inspector  to  understand  without 
verbal explanations.  Therefore, the Board finds that the applicant has not proved that 
Comments [8] and [13] are erroneous or unjust. 

d. 

e. 

 

 

 

 

f. 

 

 

g. 

 
 
COMMENTS [9] & [10]:  The applicant has not submitted proved 
by a preponderance of the evidence that Comments [9] and [10] are erroneous or unjust.  
The record indicates that the Group lacked ballcaps during the period they were most 
needed and that several of the awards were arranged at the last minute or late.  While 
the  applicant  may  have  worked  with  the  Operations  Officer  to  cope  with  manpower 
shortages, as he alleged, such actions would not disprove the comment that he had no 
plan for the communications watch rotation at some point when one was needed.  In 
addition,  the  record  supports  the  allegation  that  the  relief  of  the  morale  and  EKMS 
alternate officers were “haphazard and reactionary” as the CO alleged.  The Operations 
Center Supervisor appears to have based his opinion of the timeliness of the applicant’s 
relief plan on the supposition that the outgoing EKMS alternate was accepted to flight 
school  in  August  2004.    However,  the  CO’s  written  feedback  dated  August  12,  2004, 
states that the outgoing EKMS alternate had been accepted to flight school in June. 
 
 
COMMENT  [11]:    The  applicant  seems  to  have  presented  contra-
dictory arguments concerning his release of the message concerning the “possible com-
promise” of classified information.  In his original application, he indicated that his act 
in releasing the message without discussing it with the CO beforehand was a pragmati-
cally efficient show of initiative on his part.  In his response to the advisory opinion, the 
applicant stated that when he released the message he thought that a chief petty officer 
had already informed the CO.  The applicant has not addressed the CO’s concern that 
he could easily have been blindsided and embarrassed if someone had called him about 
the message.  The Board finds that the applicant has not proved that Comment [11] is 
erroneous or unfair. 
 
 
COMMENT  [12]:  The applicant stated and presented supporting 
evidence to show that the radio tapes were eventually pulled—though not timely and 
not necessarily by him or at his direction—and that he eventually completed the inven-
tory.  He admitted that the first package he sent to the investigator was incomplete.  The 
CO argued that the applicant did not timely pull the tapes in accordance with standard 
practice or complete the inventory until several days after the mishap and after the CO 
asked  him  about  it.    Although  Comment  [12]  would  be  more  accurate  if  the  word 
“timely” were included, the Board is not persuaded that it is an inaccurate description 
of  critical  deficiencies  in  his  performance  during  the  most  critical  period—the  hours 
after the mishap.  The Reserve captain stated that the CO asked his opinion of the appli-
cant’s performance during the weekend of the mishap, and the captain replied that he 
thought  it  was  “fine”  and  did  not  understand  why  he  was  later  asked  to  take  over.  
However,  the  CO  did  not  relieve  the  applicant  as  MAB  president  until  several  days 
after the mishap, when he discovered that the applicant had not pulled the radio tapes 
or completed the inventory.   
 
 
COMMENTS  [15],  [18],  &  [19]:    The  applicant  alleged  that  he 
always responded to the CO’s guidance and met his expectations but that the CO sub-

h. 

 

i. 

 

j. 

mitted new and different expectations each week.  He argued that there were no redun-
dancies in the CO’s written feedback to him.  The Board notes, however, that most of 
the CO’s written criticisms during the evaluation period had common themes, such as 
inadequate preparation, insufficient attention to detail, failure to timely update the CO, 
and  a  lack of involvement in operational matters.  The Board finds that the applicant 
has not proved that Comments [15], [18], and [19] are erroneous or unjust. 
 
 
COMMENTS  [16]  &  [17]:   The applicant alleged that only one of 
the three OERs for which he was responsible was late during the reporting period.  The 
CO indicated that several OERs from the subunits were late and that he expected the 
applicant to track all of the OERs at the Group and so help to ensure their timeliness.  
The  applicant  has  not  shown  that  as  the  Group  XO  with  primary  responsibility  for 
human resources and administrative matters, it was unreasonable for the CO to criticize 
him  because  of  late  OERs  from  the  Group  subunits  even  if  the  applicant  was  not  in 
those  officers’  rating  chains.    In  addition,  although  the  applicant  alleged  that  the  E-6 
evaluations were 45 days late “by design,” he has not shown why such a long delay was 
necessary or that it was reasonable for him to make this plan without the CO’s agree-
ment.   The Board finds that the applicant has not proved by a preponderance of the 
evidence that Comments [16] and [17] are erroneous or unjust. 
 

 

 

l. 

k. 

COMMENTS  [20]  &  [21]:    The  applicant  has  not  proved  that 
Comments  [20]  and  [21]  are  erroneous  or  unjust.    They  echo  and  elaborate  on  other 
comments  in  the  SOER concerning inadequate preparation and results that the Board 
has already addressed.  Although the applicant alleged that the SOER is the result of a 
conflict  in  leadership  styles  rather  than  of  poor  performance  by  him,  the  Board  finds 
that the CO clearly put the applicant on notice that the applicant’s style was not produc-
ing the results the CO wanted.  The record supports the CO’s claim that the applicant 
failed to adapt his style to ensure those results.   
 
 
COMMENT  [22]:    Although  the  CO’s  feedback  provided  some 
examples  of  how  the  applicant failed to show initiative during the evaluation period, 
the Board cannot see how the CO concluded that the applicant took no initiative for his 
“career development” during the period.  The applicant was taking classes toward his 
PhD  in  organizational  development  that summer.  Although he apparently displayed 
little initiative to increase his operational skills, the applicant has apparently chosen to 
pursue  a  non-operational  career.    Ignoring  the  CO’s  urging  to  be  more  involved  in 
operational matters may not have been wise and may have greatly harmed the appli-
cant’s career, but that would be because the applicant failed to meet the CO’s expecta-
tions, not because he was not actively engaged in developing a career path.  The Board 
finds that the applicant has proved that the phrase “career development” in Comment 
[22] in the SOER is erroneous and misleading and should be removed from his record. 
 
 
COMMENT  [23]:    The  CO  admitted  that,  contrary  to  Comment 
[23], the applicant did “set foot on a CG boat” during the evaluation period when he 

m. 

 

 

 

n. 

boarded the boat that had capsized to perform inventory.  In saying that the applicant 
“did not set foot on a CG boat,” the CO apparently meant to indicate that the applicant 
did not get underway on a Coast Guard boat.  However, the Board finds that the appli-
cant has proved by a preponderance of the evidence that Comment [23] is a “misstate-
ment of significant hard fact”7 that should be removed from the SOER. 
 
 
COMMENTS  [24]  &  [26]:    The  applicant  alleged  that  these  com-
ments  are  unfair  because  he was not expected to participate in the Ready For Opera-
tions  visits  and  that  he  did  not  need  to  be  very  familiar  with  the  operational  area 
because he could rely on maritime atlases and GPOs when the need arose.  In respond-
ing to the PRRB, the CO submitted “OER Feedback” indicating that he told the appli-
cant  that  he  was  expected  to  participate  in  RFO  visits  and  to  increase  his  overall 
involvement in operational matters.  Moreover, the Board is not persuaded that a Dep-
uty  Group  Commander  does  not  need  to  be  very  familiar  with  the  Group’s  area  of 
operations.  The Board finds that the applicant has not proved by a preponderance of 
the evidence that Comments [24] and [26] are erroneous or unfair. 
 
COMMENT  [25]:    The  applicant alleged that he did take steps to 
 
develop a plan for himself and others to earn boat forces pins.  He submitted statements 
from members showing that he talked to them about it and that he requested informa-
tion about it from a BMC.  He also admitted, however, that he decided that the training 
could wait until the fall because he decided that his subordinates did not have time to 
work on their qualifications that summer.  Therefore, it appears that the CO was correct 
in  believing  that  by  drafting  the  letter,  the  applicant  was  “simply  trying  to  placate 
[him]” and did not intend to prioritize the matter as the CO had directed.  Although the 
applicant may have spoken to BMCs about the CO’s request, the Board finds that he has 
not proved that he took the actual “steps”—such as preparing a training schedule and 
making  substantial  progress  toward  qualifying  himself—that  the  CO  expected  and 
directed.  He has not proved by a preponderance of the evidence that Comment [25] is 
erroneous or unjust.  
 
 
COMMENT [27]:  The applicant claimed that the CO verbally told 
him not to flag important messages soon after the CO took command.  The CO stated 
that  he  expressly  asked the applicant to flag important messages while he was away.  
Recognizing  that  it  is  difficult  if  not  impossible  to  disprove  the  CO’s  allegation,  the 
Board finds that the applicant has not overcome the presumption of regularity afforded 
the CO with respect to Comment [27]. 
 
 
COMMENT  [28]:  The applicant alleged that the fancy work con-
test  occurred  during  the  prior  reporting  period.    The  CO  admitted  that  he  cannot 
remember  when  it  occurred,  and  the  JAG  and  CGPC  have  recommended  removal  of 

p. 

 

 

o. 

q. 

                                                 
7 Germano v. United States, 26 Cl. Ct. 1446, 1460 (1992); Hary v. United States, 618 f.2d 704 (Cl. Ct. 1980); 
CGBCMR Dkt. No. 86-96. 

 

r. 

this  comment.    The  Board  finds  that  the  preponderance of the evidence in the record 
indicates that Comment [28] is erroneous and should be removed from the SOER. 
 
COMMENTS [29], [30] & [31]:  The applicant’s prior OERs as Dep-
 
uty Group Commander and the declaration of the prior Group Commander show that 
the prior Group Commander believed that he “did an exceptional job” in that position.  
It is therefore hard to understand how the new Group Commander could have evalu-
ated the applicant’s performance so differently and concluded that the applicant “failed 
to  grasp  the  breadth  of  his  duties  as the Deputy Group Commander, falling short on 
operational  matters,  accountability,  and  unit  planning.”    However,  the  new  Group 
Commander was entitled to have very different expectations as to what work the Dep-
uty Group Commander would be involved in and how and when he would perform it.  
The  documentation  of  the  CO’s  feedback  in  the  record  shows  that  he  expected  more 
operational  involvement  by  the  applicant,  which  the  applicant  resisted.    The  written 
feedback  also  shows  that  the  CO  was  very  dissatisfied  with  some  of  the  results  pro-
duced  by  the  applicant’s  administrative  efforts.    The  applicant  has  not  proved  that 
Comments [29], [30] and [31] are products of a personality conflict or clash in leadership 
styles.  Though the CO may have had a very different leadership style, the record sup-
ports CGPC’s claim that these comments are the CO’s honest, professional assessment 
of the applicant’s performance.  The Board finds that the applicant has not proved that 
Comments [29], [30], and [31] are erroneous or unfair. 
 
 
The applicant alleged that the examples of poor performance in the SOER 
were  one-time  events  rather  than  performance  trends  that  should  have  been  docu-
mented.  However, Article 10.A.4.c.4. of the Personnel Manual instructs raters to pro-
vide comments that cite “specific aspects of the Reported-on Officer’s performance and 
behavior” and that “identify specific strengths and weaknesses in performance.  Com-
ments must be sufficiently specific to paint a succinct picture of the officer’s perform-
ance  and  qualities.”    Therefore,  the  CO  was  required  to  describe  specific  instances  of 
poor performance, rather than providing only general opinions of the applicant’s per-
formance trends.  Moreover, the applicant has not proved that the events described in 
the SOER were atypical of his performance that summer. 
 

4. 

5. 

 Therefore, the Board finds that the only relief the applicant is entitled to 
with  respect  to  the  SOER  is  removal  of  the  phrases  “career  development:  did  not  set 
foot on a CG boat during entire reporting period” and “sponsored fancy work contest” 
from  block  8.    The  mark  of  3  that  the  applicant  received  for  “Initiative”  is  amply 
supported by the remaining Comments [24] and [25] and so need not be corrected. 
 
 
The applicant made numerous allegations with respect to the actions and 
attitudes  of  his  CO  and  reviewer.    Those  allegations  not  specifically  addressed  above 
are considered to be not dispositive of the case. 
 

6. 

7. 

 
Accordingly, the Board finds that the applicant is entitled to only partial 
relief—the removal of the comments quoted in Finding 5 from the SOER—because they 
constitute “misstatement[s] of a significant hard fact[s].”8  The applicant has not proved 
that the SOER contains other factual errors or that is was adversely affected by factors 
that “had no business being in the rating process” or a “clear and prejudicial violation 
of a statute or regulation.”9  

 

ORDER 

 
 
The application of xxxxxxxxxxxxxxxxxxxxxx, USCG, for correction of his military 
record is denied, except that the Coast Guard shall remove the following phrases from 
block 8 of the special OER he received for the period May 1 through September 22, 2004: 
 

•  “career  development:  did  not  set  foot  on  a  CG  boat  during  entire  reporting 

period”; and 

•  “sponsored fancy work contest.”  

 

 
 
 
 
 
 
 
 
 
 
 
 
 
 

All other relief is denied. 

 
 
 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

        

 
 
 Toby Bishop 

 

 
 Jordan S. Fried  

 

 

 

 

 
 
 Nancy L. Friedman 

 

 

 

 

 

 

 

 

 

 

                                                 
8 Germano v. United States, 26 Cl. Ct. 1446, 1460 (1992); Hary v. United States, 618 F.2d 704 (Cl. Ct. 1980); 
CGBCMR Dkt. No. 86-96. 
9 Id. 



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