Search Decisions

Decision Text

CG | BCMR | OER and or Failure of Selection | 2007-160
Original file (2007-160.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. 2007-160 
 
xxxxxxxxxxxxxxxxxxxxx 
xxxxxxxxxxxxxxxxxxxx   

FINAL DECISION 

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 the case on July 20, 2007, upon receipt of 
the applicant’s completed application, and assigned it to staff member J. Andrews to prepare the 
decision for the Board as required by 33 C.F.R. § 52.61(c). 
 
 
appointed members who were designated to serve as the Board in this case. 

This  final  decision,  dated  April  30,  2008,  is  approved  and  signed  by  the  three  duly 

 

APPLICANT’S REQUEST 

 

 
 

 

 

 

The applicant, who resigned his commission as a lieutenant junior grade (LTJG) in the 

Coast Guard on August 1, 2004, asked the Board to correct his record by  

(a) removing two officer evaluation reports (OERs) covering his service aboard a cutter as a deck 
watch officer from October 1, 2002, to January 31, 2003, and from February 1, 2003, to July 
13, 2003; 

(b) removing all documentation of an investigation of his conduct aboard the cutter, as well as 
any documents regarding and references to alleged offenses, such as having an inappropriate 
relationship; 

(c) removing all documentation of his non-judicial punishment (NJP) at mast aboard the cutter; 
(d) invalidating and expunging any administrative actions taken in whole or in part because of 

the NJP and disputed OERs; 

(e) either removing an April 11, 2003, referral to a Naval hospital for alcohol screening or, in the 
alternative,  inserting  the  hospital’s  response  to  the  command,  which  states  that  he  did  not 
have an alcohol problem and admonishes the command for wasting the hospital’s time; 

(f)  rescinding and removing his letter of resignation; 
(g) removing all documentation of and references to administrative actions to revoke his commis-

sion or otherwise terminate his Coast Guard career;  

(h) allowing him an opportunity “to return to active duty and rejoin his year group, without loss 
of numbers or precedence” and, if he accepts the opportunity, to be awarded all back pay and 
allowances from August 1, 2004, to the date of his return to active duty; and 

 
In the alternative, the applicant asked the Board to correct his DD 214 to change his nar-
rative  reason  for  separation  from  “Substandard  Performance”  to  “Miscellaneous/General  Rea-
sons” and his separation code from BHK, which means “resignation allowed in lieu of further 
administrative separation proceedings or board actions when a member’s performance is below 
acceptable standards,” to FND, which means that the resignation was allowed for “miscellane-
ous/general reasons.” 
 

APPLICANT’S ALLEGATIONS 

(i)  removing his DD 214. 

 
 
The applicant alleged that on January 3, 2003, while stationed aboard the cutter, he was 
wrongly  accused  of  having  an  inappropriate relationship with a female officer, LTJG X.  The 
applicant stated that the woman had been his classmate at the Coast Guard Academy and that 
they  had  been  friends  for  some  time,  which  is  not  a  violation  of  Coast  Guard  policy.    After 
accusing him, the commanding officer (CO) of the cutter illegally confined him to his stateroom 
and deprived him of access to a telephone or email.  The applicant submitted copies of the Rules 
for  Courts-Martial  concerning  pre-trial  restraint  and  pre-trial  confinement  but  failed  to  cite 
exactly the rule that his CO violated.  However, he alleged that he could only talk to personnel 
sent by the CO and was not allowed to contact counsel.  Although he repeatedly asked to speak 
to counsel, he was repeatedly and illegally questioned by senior officers on the cutter, and he was 
threatened with additional charges if he did not sign a false statement confessing to the alleged 
offenses.  The applicant alleged that his confinement constituted unlawful detention. 
 

On January 7, 2003, the applicant alleged, the CO took him to mast but denied him legal 
assistance or representation as well as the right to speak or present evidence and witnesses in his 
own defense or in mitigation or extenuation.  The CO imposed NJP under Article 15 of the Uni-
form Code of Military Justice (UCMJ), including thirty days of restriction to be served at the 
nearby xxxxxxxxxxxxxxxx. The CO failed to inform him of his right to appeal, and when the 
applicant asked about a right to appeal, the CO threatened him with additional punishment if he 
exercised that right.  The applicant alleged that the CO also forced him to sign an illegal docu-
ment waiving his right to appeal the NJP.  Immediately after the mast, the CO had the applicant 
removed from the cutter to the Xxxxx by helicopter, which the CO had arranged in advance of 
the mast since the cutter was underway.  While in restriction at the Xxxxx, the applicant alleged, 
the XXX of the Xxxxx continued to deny him access to a telephone or email, so he could not 
contact his family or an attorney. 
 
 
The applicant stated that after his father, a retired Coast Guard captain, heard about what 
was happening through a third party, his father threatened the officer who ultimately served as 
the Reviewer for the first disputed OER with legal action and was allowed to telephone him at 
the Xxxxx.  After learning about his rights from his father, the applicant appealed the NJP on 
January 27, 2003.  When the CO received the appeal, he called the applicant and again threatened 
him with additional punishment if he did not withdraw the appeal.  The CO “tried to leverage a 
retraction from [the applicant] by threatening to write an inaccurate and derogatory OER that was 
due on his performance aboard the vessel.”   
 

On  February  2,  2003,  the  applicant  submitted  a  request  for  his  punishment  to  be  sus-
pended, but the CO denied the request even though the law requires such requests to be approved 
if an NJP appeal is not adjudicated within five days of filing.  Therefore, the applicant remained 
unlawfully incarcerated at the Xxxxx for thirty days.  In fact, he was incarcerated for thirty-three 
days because the CO failed to include transit time in the calculation of his thirty-day sentence, as 
required  by  the  Military  Justice  Manual.    On  March  24,  2003,  the  Area  Commander,  a  vice 
admiral, nullified the NJP, “rescinded the punishment, ordered all trace of the proceedings to be 
removed from [his] record, and verbally reprimanded the CO.”   
 
Allegations about the Page 7 

 
On April 11, 2003, the CO of the cutter, which was still the applicant’s permanent duty 
station, referred him to a Naval hospital for alcohol dependence screening.  Hospital personnel 
determined  that  he  was  not  alcohol  dependent  and  sent  the  CO  a  letter  admonishing  him  for 
wasting their time.  The applicant stated that because the screening referral is in his record but 
the hospital’s response is not, his record falsely indicates that he had an alcohol problem, which 
is  false.    Therefore,  he  argued,  either  the  referral  should  be  removed  from  his  record  or  the 
hospital’s reply should be added to his record. 

 

Allegations about the Disputed OERs  
 
 
After his release from confinement, the applicant was assigned to the Xxxxx on a tem-
porary basis as a Planning Officer.  Within days of his release, he learned that his rating chain 
aboard the cutter—which included the Operations Officer, the Executive Officer (XO), and the 
CO—was preparing a derogatory OER for him.  The applicant concluded that this rating chain 
was biased against him, and so on April 9, 2003, he asked that they be disqualified so that his 
OER for the evaluation period October 1, 2002, through January 31, 2003, would be prepared by 
other officers.  The applicant alleged that although his request was granted, his substitute rating 
chain prepared a derogatory OER based on information that the Area Commander had already 
ordered stricken from his record.  The applicant alleged that the substitute rating chain should 
have  marked  all  of  the  performance  categories  on  the  first  disputed  OER  as  “not  observed” 
because none of them observed his actual performance.  Instead, they created a derogatory OER 
based on information from the biased rating chain and from the NJP documents.  The applicant 
alleged  that  the  Reporting  Officer  and  Reviewer  who  prepared  the  first  disputed  OER  were 
biased  against  him  because  his  father  had  threatened  the  Reviewer  with  legal  action  and  had 
reported both officers to Headquarters officials in 2001 for “manipulating Xxxxxx Area Cutter 
Performance Records to show better performance than actual.”  However, the Area Command 
refused to remove the derogatory information from the first disputed OER, and the Coast Guard 
Personnel Command (CGPC) refused to allow him to submit an effective response to the OER.  
The applicant stated that upon receipt of the first disputed OER, he submitted an OER Reply to 
respond to the OER.  However, CGPC rejected it because of its content and he was required to 
revise it twice and was not allowed to address the most important issues in his Reply. 
 
 
Regarding the second disputed OER, the applicant stated that it was simply an attempt by 
the substitute rating chain to insert negative information in his record.  The applicant stated that 
throughout the evaluation period from February 1 to July 13, 2003, he never worked aboard the 
cutter.  He stated that because his performance during that period is adequately described on the 

concurrent OER prepared by his chain of command at his temporary duty station, the second dis-
puted OER “serves no useful purpose and should be removed.”   
 
Allegations about the Proposed Revocation Board 
 
 
The  applicant  stated  that  even  though  the  Area  Commander  overturned  his  NJP  and 
ordered its removal from his records, CGPC added insult to injury by threatening to convene a 
panel of senior officers under Article 12.A.11. of the Personnel Manual (hereinafter “Revocation 
Board”) to determine whether his commission should be revoked.  The applicant was informed 
that he would not be granted a hearing or allowed to question his accusers.  He would only be 
allowed to submit a written statement on his own behalf.  When he was provided a copy of the 
documents to be considered by the Revocation Board, he discovered that the report of investiga-
tion was wrongfully included even though the Area Commander had already ordered the docu-
mentation of the NJP to be removed from his record.  Although he asked for the report to be 
removed from consideration by the Revocation Board, CGPC refused to do so, thereby violating 
his right to due process.  The applicant argued that the reporting of the investigation was part of 
the mast proceedings and not a part of his record so the report should not have been among the 
documents to be considered by the Revocation Board.  He alleged that Coast Guard regulations 
state that only an officer’s record can be considered by a Revocation Board.  He noted that on the 
letter forwarding him the documents to be reviewed by the board, his Headquarters Personal Data 
Record  (PDR)  is  listed  separately  from  the  report  of  the  investigation  and  that  Coast  Guard’s 
regulations prohibit filing such a report in a member’s PDR.  Therefore, he argued, the report 
was not a proper part of his record and should not have been included for consideration by the 
Revocation Board.  The applicant further argued that the report was part of the mast proceedings 
and so should have been removed from his record as documentation of the mast pursuant to the 
Area Commander’s order.  He also argued that it was completely unjust for CGPC to include the 
report of the investigation or parts thereof in the record before the Revocation Board without also 
including the fact that his NJP had been overturned due to insufficient evidence. 
 

The applicant stated that when CGPC illegally refused to remove the report of the inves-
tigation from the documents to be considered by the Revocation Board, he realized that the out-
come  of  the  board  was  a  “foregone  conclusion.”    He  noted  that  LTJG  X,  with whom he was 
wrongly accused of having an inappropriate relationship, ultimately had her commission revoked 
pursuant to a Revocation Board, and therefore concluded that his assumption about the outcome 
was correct.  In addition, he realized that the board’s proceedings would become a part of his 
record  and  therefore  reintroduce  into  his  record  the  negative  information  that  the  Area  Com-
mander had ordered removed, which might adversely affect his ability to obtain highly skilled or 
clearance-sensitive employment.  Therefore, the Coast Guard’s illegal actions coerced him into 
resigning his commission, which was the only way he could avoid the reintroduction of false, 
negative information into his record via the proceedings of the Revocation Board.   
 

Allegations about the DD 214 
 
 
Regarding  the  separation  code  and  narrative  reason  for  separation  on  his  DD  214,  the 
applicant stated that they were based on the erroneous information in the first disputed OER.  All 
his other OERs are excellent.  Therefore, the notation “Substandard Performance” is clearly erro-
neous.  The applicant also alleged that the DD 214 was based on an inaccurate database entry by 
CGPC.    He  submitted  a  “Case  Status”  printout  from  a  database  concerning  CGPC’s  special 
boards.  The printout, dated May 20, 2004, shows as the status of the case that the applicant’s 
resignation had been approved in lieu of board action.  However, the database entry concerning 
the issue that would have been before the Revocation Board is described as “8-H [which means 
inappropriate relationship] with [LTJG X] at [name of applicant’s last duty station].”  He sub-
mitted an affidavit from the CO of his last unit attesting to the fact that the applicant “was not 
involved  in  any  8-H  incident  [inappropriate  relationship],  while  under  my  command.”    The 
applicant  further  alleged  that  the  DD  214  is  unjust  because  it  has  caused  him  to  be  denied 
employment by the Federal Bureau of Investigation. 
 
Allegations about the DRB Testimony, Recommendation, and Decision 
 
Finally,  the  applicant  alleged  that  although  the  Discharge  Review  Board  (DRB)  found 
 
that the Coast Guard had committed serious errors resulting in great injustice to him and recom-
mended  the  rescission  of  his  resignation  and  restoration  of  his  commission,  the  Commandant 
disapproved the DRB’s recommendation without explanation.   
 

The applicant alleged that during his DRB hearing, he and his father, who represented 
him, persuasively argued that his command scrutinized his conduct and wrongly accused him of 
having an inappropriate relationship after he “observed a situation during a migrant interdiction 
which resulted in deaths” and subsequently reported it, which caused his chain of command to be 
reprimanded by a three-star admiral.  The applicant stated that in December 2002, the cutter was 
preparing to unload Haitian immigrants from an overloaded sailboat when the sailboat capsized 
and quite a few people drowned, but the CO reported that only three had drowned. Moreover, the 
applicant alleged, he told the DRB that at the cutter’s next stop, he heard an investigator ask the 
CO why the ship’s log did not show that they had searched the sea for survivors and searched the 
sailboat for hideaways before sinking it.  When the CO stated that they had not done either of 
those things, the investigator advised him to change the log so that it would look as if they had or 
they would be in a lot of trouble.  The CO then changed the ship’s log accordingly.  The alleged 
that he told the DRB that he had informed his father of these events in an email and asked if he 
should report the matter.  He also told them that he believes his email may have been seen by the 
CO because the XO and the Operations Officer periodically checked the crew’s outgoing emails 
for security purposes.  Within a week, he was unjustly accused of having an inappropriate rela-
tionship. 
 
As further evidence of bias, the applicant alleged, he told the DRB that in January 2003, 
another female officer, LTJG Y, was caught sharing a hotel room with two enlisted men, but she 
was never placed on report, reprimanded, or counseled on a Page 7.  He argued that it was unfair 
that he and his friend were “cashiered for doing nothing,” while an officer on the same cutter 
who clearly violated the UCMJ by fraternizing with enlisted members was not punished at all. 

 

The applicant alleged that he also argued at the hearing that his receipt of one poor OER, 
written by officers who never observed his performance and got their information from biased 
sources,  was  not  an  adequate  basis  for  CGPC  to  threaten  to  revoke  his  commission  and  that 
CGPC had acted arbitrarily  and capriciously in initiating the board.  In addition, the applicant 
stated that his relationship with the LTJG X was not romantic and that even if it had been roman-
tic, it would not have been an “inappropriate relationship” under Article 8.H. because they were 
both officers and they were of the same rank, seniority, and level within the cutter’s command 
structure.  He stated that if the CO had considered it an “unauthorized relationship,” he need only 
have transferred one or both of them without prejudice.  The applicant told the DRB that during 
his  pre-mast  confinement,  the  command  took  away  his  cell  phone  and  terminated  his  email 
privilege.  The XO told him that if he admitted to one count of violating Article 92 of the UCMJ, 
he was get light punishment, such as a non-punitive letter.  At the mast, he and LTJG X were not 
allowed to speak in their own defense, and the CO refused to conduct the extenuation and miti-
gation phase because a helicopter that the CO has previously ordered to take them to confinement 
at the Xxxxx had already arrived.  Yet the CO gave them the maximum punishment.  Instead of 
informing them of their right to appeal, the CO “warned us that if we tried to appeal, it would not 
be approved and we would only get more punishment.”  The applicant further alleged that he told 
the DRB that the many mistakes the CO made in conducting the mast should be considered signs 
of bias because the CO was an experienced captain/O-6 who must have known how to conduct a 
mast  properly  but  may  have  thought  he  was  untouchable  and  could  get  away  with  anything 
because his own chain of command had reason to dislike the applicant’s father. 

 
The applicant also told the DRB that after his appeal was upheld, the Area Commander 
was “furious” with the CO and “gave him a major league dressing down.”  The CO relieved the 
XO and the OPS, who left the ship, and the CO himself was relieved of command shortly there-
after.  The applicant’s father testified to the DRB that the officers who served on the applicant’s 
substitute rating chain may also have been criticized because they presumably approved the mast.  
The father stated that these officers had good reason to dislike him and that when they saw that 
his son might get NJP, “their desire for some form of revenge overcame their common sense.”  
He noted that the Area Commander also overturned LTJG X’s NJP and she did not even file an 
appeal.  Yet in planning the Revocation Board, CGPC intended to show the board the NJP pack-
age without his appeal or the Area Commander’s letter overturning the NJP. 
 

SUMMARY OF THE RECORD 

 

On May 8, 2001, the applicant was commissioned an ensign upon graduating from the 
Coast Guard Academy.  Thereafter, he was assigned to a cutter as a deck watch officer.  On his 
first OER, for the period May 21, 2001, to March 31, 2002, he received primarily marks of 4 (on 
a  scale  of  1  to  7,  with  7  being  best)  in  the  various  performance categories and a mark in the 
fourth spot on the comparison scale, denoting him as “one of the many competent professionals 
who form the majority of this grade.”  The XO of the cutter, who served as the Reporting Officer 
for the OER, noted that the applicant was “on track” for promotion with his peers.  On his second 
OER, for the period April 1, 2002, to September 30, 2002, the applicant received marks of 4 and 
5 in the various performance categories and a mark in the fourth spot on the comparison scale.  
The Reporting Officer again recommended him for promotion.  The applicant was promoted to 
lieutenant junior grade on November 23, 2002.  
 

Report of the Investigating Officer1 
 
 
 The record indicates that in late December 2002 or early January 2003, the CO of the 
cutter appointed a lieutenant commander who was not a member of the applicant’s rating chain to 
conduct an investigation of allegations that the applicant and a female LTJG were involved in an 
unacceptable relationship.  The CO’s letter and the written findings and recommendations of the 
investigating officer (IO) are not in the record before the Board, but CGPC submitted copies of 
many statements gathered by the IO and attached to his report with the advisory opinion.   
 

The IO’s attachments show that on January 3, 2003, he informed the applicant in writing 
that  he  was  suspected  of  violating  Article  92  of  the  UCMJ  twice  (failure  to  obey an order or 
regulation)  and  Article  133  (conduct  unbecoming  an  officer  and  gentleman).    On  the  written 
acknowledgement of his rights, the applicant acknowledged the right to remain silent and not to 
answer questions; the right to consult with a lawyer before deciding whether to answer questions 
or make a statement; and the right to stop answering questions at any time.  He also acknowl-
edged  that  any  statement  he  made  could  be  used  against  him  in  any  court-martial,  NJP,  or 
administrative proceeding.  The applicant checked boxes on this form indicating that he did not 
desire to consult a lawyer but did desire to make a statement and to answer the IO’s questions.  
LTJG X, who was also accused, signed the same acknowledgement and also indicated that she 
did not desire to consult a lawyer but desired to make a statement and answer questions.  The 
applicant ultimately signed four statements for the IO: 

 
1. 

2. 

On  January  5,  2003,  the  applicant  signed  and  submitted  a  statement  for  the 
investigation “to give amplifying information to the questions answered for [the IO] on 3 JAN 
03.”    His  statement  began  with  the  following  claim:  “With  full  understanding  of  my  rights,  I 
make the following statement freely, voluntarily, and without any promises or threats made to 
me.”  He claimed that he had been friends with LTJG X for five years, “since being in the same 
company together at the Academy” and he had grown very close to her while stationed on the 
cutter.  However, their kiss at the Xxx Bar had “caught [him] completely off guard.”  He admit-
ted that he relished her attention and began “not to care how other people looked at it, and … to 
pay more attention to her as well,” even though he “realized the perception was negative.” 
 

On January 6, 2003, after answering more questions posed by the IO, the applicant 
signed the IO’s summary of his answers as “true and accurate.”  He admitted to having kissed 
LTJG X and LTJG Y at the Xxx Bar on December 18, 2002, in the presence of many people, 
including several petty officers.  He admitted to drinking shots of tequila and becoming ill due to 
his alcohol consumption.  The next day, his Supervisor, LT L, who was the Operations Officer, 
counseled him about the improper perceptions of their conduct.  LT L told him that although the 
kissing may have been done in jest, it was the perception that mattered, and that a rumor had 
started.  LT L told him that he did not care as long as it stayed off the boat.  The applicant also 
told the IO that on December 28, 2002, they rented a three-bedroom hotel suite.  He and LTJG C 
were to share one bedroom, LTJG X and LTJG Y the second bedroom, and the BMC and BM1 
the third bedroom.  When the applicant and LTJG X returned to the hotel after the wetting down 
party, he could not find the key for his own room and LTJG C was not there.  They found LTJG 
Y asleep in the petty officers’ room and tried to wake her but were unsuccessful.  The applicant 
                                                 
1 The documents summarized in this section were submitted by CGPC as attachments to the advisory opinion. 

3. 

4. 

and LTJG X went to LTJG X’s room, chatted for a while, and then slept in the single beds that 
were already arranged pushed together.  The applicant had lost his shirt at the party but otherwise 
did not disrobe.  The applicant told the IO that he did not have sex with LTJG X and has never 
had sex with her aboard the cutter.  He knew she was married and denied having a romantic rela-
tionship with her.   
 
 
Three hours later, the applicant went to the IO’s stateroom and said he thought he 
could save LTJG X’s marriage but that, after learning what LTJG Y had related, he “needed to 
come clean morally and professionally.”  Although LTJG Y and LTJG X had been ordered not to 
discuss any issue in the case with the applicant, LTJG Y had told him to “tell the truth and do the 
right thing.”  The applicant then told the IO that he and LTJG X had done “everything other than 
vaginal  intercourse,”  including  oral  sex.    He  signed  this  addendum  to  his  prior  statements  on 
January 6, 2003, and agreed to sign a fourth, more formal statement.   
 

On January 6, 2003, the applicant signed a fourth statement for the IO, beginning 
with the following: “With full understanding of my rights, I make the following statement freely, 
voluntarily, and without any promises or threats made to me.”  He stated that after the wetting 
down party, he and LTJG X found LTJG Y asleep in the petty officers’ room.  She went with 
them to her and LTJG X’s room but later insisted on going back to the petty officers’ room for 
the night.  Since he could not find the key to his own room, he “opted to stay with” LTJG X in 
her room.  They kissed and “performed oral sex on each other.” 

 
LTJG X admitted to the IO that she kissed the applicant in front of several petty officers 
after they drank shots of tequila at the Xxx Bar on December 18, 2002.  The applicant got sick, 
vomited, and had to be helped back to his rack.  The next day, LT L counseled her about her 
inappropriate conduct and the problem of perception.  LT L said that they could be together as 
long as they were in a group with other junior officers or petty officers.  Then on December 28, 
2002, they rented a hotel “villa,” including a “main house” with one main bedroom with a lock 
and two other, separate bedrooms with locks.  She and the applicant were the last to leave the 
wetting down party and had been drinking most of the evening.  At the villa, they found LTJG Y 
asleep in the petty officers’ bedroom, woke her, and told her to come to her own room, but LTJG 
Y would not leave.  Because the applicant could not find the key to his room, they slept in the 
adjoining  beds  in  her  room.  She wore pajamas  and the applicant wore gym shorts.  LTJG X 
stated that their relationship was “purely platonic” and denied ever having had oral or vaginal sex 
with him.  She also stated that she had never held hands with the applicant but that he sometimes 
covered her hands with his to make her stop picking at her nails.  She recalled that he did this on 
December 29, 2002, as they returned to the cutter in the van. 

 
LT L, the Operations Officer of the cutter and the applicant’s supervisor, told the IO that 
he counseled the applicant after hearing that he and LTJG X had kissed in a bar in front of many 
crewmates, some of whom believed they were involved in an inappropriate relationship.  Since 
the  applicant  and  LTJG  X  were  both  in  other  long-term  relationships,  he  thought  they  were 
merely friends who had drunk too much alcohol and behaved improperly.  He told the applicant 
about the crew’s perception of impropriety and about how they could remain friends without cre-
ating the perception of an inappropriate relationship.  LT L stated that had seen them holding 
hands once before when the applicant got drunk and LTJG X helped him back to the cutter.  On 
that occasion, he had told them it was not a good idea to behave like that before him.   

 
LTJG Y told the IO that at the Xxx Bar on December 18, 2002, she and LTJG X drank 
shots of tequila and kissed each other.  After they drank more shots, LTJG X grabbed the appli-
cant by the ears and kissed him.  Later, the applicant got ill and vomited twice.  Regarding the 
incident on December 28, 2002, LTJG Y stated that she left the party with the BMC and BM1 to 
show them the way to the villa.  She waited in the petty officers’ room for LTJG X to return 
because she did not have the key to the room she was sharing with LTJG X.  The applicant and 
LTJG X arrived shortly thereafter, and the three of them went to the women’s bedroom.  As she 
prepared for bed, the applicant and LTJG X went out onto the balcony and LTJG X put her head 
on the applicant’s shoulder.  LTJG Y “did not feel right” so she went back to the petty officers’ 
room.  The applicant and LTJG X came looking for her, but she told them that she did not want 
to go back to her own room with them.  They left and she fell asleep in the petty officers’ room.  
Early the next morning, LTJG X let her into their room when she knocked.  LTJG X and the 
applicant were both in pajamas.  LTJG Y took a shower and was getting ready to leave when the 
BMC walked “through the house to see the layout that was in it.  As he walked thru the kitchen, 
towards the bedroom, he noticed [the applicant and LTJG X] lying in bed.  He decided not to go 
any further.”  Later, LTJG Y saw the applicant and LTJG X holding hands together in the van. 

 
BMC M told the IO that at the wetting down party, the applicant and LTJG X danced 
close together for most of the evening.  BMC M stated that he is “not entirely sure why [LTJG Y] 
stayed in the room he shared with the BM1 but “can only speculate that she felt a little uncom-
fortable given the obvious ‘couple nature’ of the two; ‘a third wheel.’”  The next morning, he 
walked around the villa with LTJG Y and heard her speaking with the applicant and LTJG X.  As 
he walked toward their bedroom, he saw a woman’s undergarment or bathing suit bottom on the 
floor and so decided to leave.  On his way back to his room, he noticed that no one had used the 
bedroom that the applicant and LTJG C were supposed to share because the beds were still made. 

 

 
BM1 B told the IO that he saw LTJG X kiss the applicant at the Xxx Bar when they were 
all “impaired.”  After the party on December 28, 2002, he walked to the hotel with LTJG Y and 
BMC M.  LTJG Y had the key to one of the three bedrooms so they waited there for the others.  
All three of them “racked out and attempted  to get some sleep.”  He recalled speaking to the 
applicant and LTJG X when they returned to the hotel but did not see them the next morning. 

 
LTJG C told the IO that he did not witness the kiss in the Xxx Bar but found LTJG X sit-
ting on the edge of the applicant’s rack later that night when the applicant was lying in the rack.  
On the night of the wetting down party, he left the party and went to a club.  Later, instead of 
going to the hotel room he was supposed to share with the applicant, he went back to his rack on 
the cutter because it was closer.  He never saw the hotel villa.   

 
The IO also gathered signed statements from several other crewmembers and one contrac-
tor serving aboard the cutter.  Some had witnessed or heard about the kissing incident at the Xxx 
Bar; some reported having seen the applicant and LTJG X holding hands, dancing closely, and 
acting like a couple; and some had heard that they had shared a hotel room.  Other crewmembers 
told the IO that they did not observe any inappropriate behavior between the applicant and LTJG 
X but had heard rumors of such. 

Non-Judicial Punishment 

 
On January 7, 2003, the applicant was taken to mast and awarded NJP by his CO, which 
included restriction for 30 days and a letter of reprimand.  The Court Memorandum that would 
have documented the mast and the letter of reprimand that he was awarded at mast are not in his 
record because his appeal of the NJP was approved by the Area Commander.  The Area Com-
mander’s letter dated March 24, 2003, upholding the appeal and overturning the NJP states the 
following  in  pertinent  part  (the  full  text  of  letter  was  received  from  CGPC  with  the  advisory 
opinion after the applicant submitted a copy of it with his application but redacted the parts that 
are shaded below): 

 
1.  … Your appeal is granted and the punishment accordingly overturned. … 
3.  On January 7, 2003, the Commanding Officer of the USCGC … conducted Captain’s Mast and 
found that you violated UCMJ Article 92 (two counts), Article 125, Article 133 and Article 134.  
Your commanding officer awarded a written reprimand and restriction to the Coast Guard Xxxxx 
for  30  days.    In  your  appeal,  you  assert  that  you  were:    denied  a  representative,  coerced  into 
making a statement, not permitted to offer matters in extenuation or mitigation, and placed in con-
finement prior to mast.  You also claim that the elements of Articles 92 (both counts), 133 and 134 
were not met, and that the elements of Article 125 were not explained to you. 
4.  After a thorough review of the record, I find that there is insufficient evidence to establish the 
reported  misconduct  for  both  the  orders  violations  under  Article  92  and  the  adultery  charge  in 
Article 134.  Therefore, I am dismissing those charges.  
5.  I am convinced from the record before me that you committed the misconduct as charged in 
Article 133 and Article 125.  However, I am deeply concerned about the way this matter was han-
dled by your command.  Specifically, I am concerned about the restrictions that were place on you 
before the mast, your inability to obtain a mast representative, and the circumstances that led to 
you  providing  an  incriminating  statement  to  the  investigating  officer.    As  a  result,  I  believe  it 
would at least appear to be unjust to let this mast stand.  I am therefore dismissing the remaining 
charges against you and your appeal is granted.  
6.  I am directing the withdrawal of the letter of reprimand and all references to the nonjudicial 
punishment from your record.  [The cutter’s command] shall take the administrative action neces-
sary to effect these changes. 
7.  Finally, I want you to understand clearly that my decision to grant your appeal does NOT mean 
I believe you did not commit any offenses under the UCMJ.  As I stated above, I am convinced 
that you violated both Articles 125 and 133, UCMJ.  I am deeply concerned about your actions and 
expect your Officer Evaluation Report to document your misconduct. 

 
Page 7 Regarding Alcohol-Related Situation 
 

On April 11, 2003, the XO of the cutter entered a Page 7 in the applicant’s record stated 
that he had been referred to a Naval hospital for alcohol screening.  The Page 7 further states that 
“[a]lthough no alcohol incident was documented, your behavior during the XXXXXXXX port 
call in December 2002 indicated that you may have a problem with alcohol abuse.  this is not 
considered  an  alcohol  incident,  but  is  entered  for  documentation  purposes  only  as  an  alcohol 
situation as outlined in Chapter 20 of the Personnel Manual … any further alcohol incidents may 
result in your separation from the U.S. Coast Guard.” 
 
First Disputed OER 

 
The applicant’s first disputed OER in this case covers his performance from October 1, 
2002, through January 31, 2003.  The rating chain included the Assistant Chief for Major Cutter 

Forces as the Supervisor, the Chief for Major Cutter Forces as Reporting Officer, and the Chief 
of Operational Forces as the Reviewer.  The Supervisor marked most of the performance catego-
ries as “not observed,” rather than assigning a numerical mark.  The “not observed” marks are 
explained in block 3 with the following comment:  “Not Observed marks reflect Reported On 
Officer’s  approved  request  to  disqualify  the  regular  shipboard  rating  chain.”    However,  the 
Supervisor assigned the applicant one low mark of 2 for the category “Workplace Climate” and 
supported  the  mark  with  the  following  comment:    “Failed  to  support  or  enforce  Coast  Guard 
human resources policies.  Despite prior counseling about his conduct, [the applicant’s] actions 
during two separate port calls created the perception of an inappropriate relationship and were 
detrimental  to  unit  good  order  and  discipline.”    Moreover,  the  Reporting  Officer  assigned  the 
applicant marks of 2 in four categories:  “Judgment,” “Responsibility,” “Professional Presence,” 
and “Health and Well-Being.”  He supported these marks with the following comments: 

 
Displayed flawed judgment during two separate port calls; misuse of alcohol contributed to par-
ticipation in an inappropriate relationship.  Failed to heed command warnings/advice about per-
sonal conduct.  Failed to hold self accountable for inappropriate conduct and failed to demonstrate 
personal courage; submitted OSF [Officer Support Form] materials that did not discuss known port 
call incidents or inappropriate relationship.  Misuse of alcohol conveyed poor self image.  Actions 
served to undermine respect for officers and undercut wardroom cohesiveness. 
 
The Reporting Officer did not assign the applicant a mark on the comparison scale in the 
first  disputed  OER.    He  wrote  that  he  was  “[u]nable  to  comment on overall performance and 
comparison to other officers due to majority of actions not being observed.  However, the two 
separate incidents of inappropriate conduct indicate a serious lapse in judgment and a complete 
disregard for core values of honor, respect and devotion to duty.” 

 
The  first  disputed  OER  was  prepared  in  November  2003  and  validated  by  CGPC  in 
December 2003.  In February and March 2004, the applicant submitted two OER Replies that 
were rejected by CGPC for not complying with the regulations for such replies.  In letters dated 
March 2 and April 28, 2004, CGPC informed the applicant that many of his comments in the 
Reply were not authorized because they were not performance related and concerned his personal 
opinions of the raters.  (In particular, he accused the cutter’s command of having provided false 
information to the substitute rating chain.)  On May 7, 2004, he submitted a revised OER Reply 
that was entered in his record.  In this Reply, the applicant wrote that the OER was based on 
incorrect  information.    He  alleged  that  there was no “inappropriate relationship” between him 
and another junior officer.  He stated that the comments about alcohol abuse were improper since 
he had never been counseled about alcohol abuse or charged with any violation of Coast Guard 
policy regarding the use of alcohol.  He stated that the comment about “counseling” was false 
because what the Operations Officer said to him following their port call in Xxxxxxxx was, “my 
policy is, and I realize this is not in line with Commandant, is to simply keep it off the ship.”  
The applicant stated that there was not wrongdoing during the port call and he had no idea what 
the  Operations  Officer  was  trying  to  tell  him.    The  applicant  also  objected  to  the  Reporting 
Officer’s comment that he lacked personal courage for not discussing the port calls on his OSF.  
He argued that he was not required to discuss port calls on his OSF.  The Area Commander for-
warded the Reply to CGPC with an endorsement stating that the OER “is accurate as submitted.” 
 

Second Disputed OER 
 

The second disputed OER, covering the period February 1 to July 13, 2003, was also pre-
pared by the substitute rating chain.  All the performance categories are marked “not observed” 
and block 3 contains the following comment:  “Not observed marks reflect Reported On Offi-
cer’s  approved  request  to  disqualify  the  regular  shipboard  rating  chain.    Mbr  TAD  to  Coast 
Guard Xxxxxxx for duration of period.” 

 
The applicant’s record also contains a “concurrent OER” covering the period February 1 
to June 30, 2003.  This concurrent OER, which was prepared by his chain of command while 
TAD at the Xxxxxxx, contains primarily marks of 5 in the various performance categories, a few 
marks of “not observed,” and a mark in the fourth spot on the comparison scale.  All of the writ-
ten comments are quite positive and the Reporting Officer recommended the applicant for pro-
motion with his peers. 
 
 
The  applicant  received  two  more  OERs  based  on  his  performance  as  the  Officer  in 
Charge of a xxxxxxxxxxxxxxxxxxxxn with nine subordinates before he was separated from the 
Coast Guard.  On these OERs, he received primarily marks of 5 in the performance categories, 
marks in the fifth spot on the comparison scale, and strong recommendations for promotion to 
lieutenant. 
 
Initiation of Revocation Board 
 
 
On January 20, 2004, CGPC informed the applicant that it had initiated action under Arti-
cle 12.A.11. of the Personnel Manual “to convene a board to recommend whether or not [his] 
commission  should  be  revoked.”    CGPC  stated  that  it  was  authorized  to  “initiate  such  action 
when information of an adverse nature is discovered.”  CGPC cited the first disputed OER as the 
adverse information that triggered the initiation of the board.  CGPC informed the applicant that 
he had a right to submit comments on his own behalf within twenty-one days.   
 
 
stated that he would submit a statement on his own behalf. 
 
 
On February 17, 2004, CGPC forwarded to the applicant the documents to be considered 
by the proposed Revocation Board.  CGPC stated that the board would review the applicant’s 
PDR and the complete report of the POI dated January 6, 2003, with its enclosures. 
 
 
On March 2, 2004, the applicant submitted an objection to the IO’s report being consid-
ered by the proposed Revocation Board.  He claimed that in overturning the applicant’s NJP, the 
Area  Commander  had  ordered  the  removal  of  all  paperwork  associated  with  the  NJP,  which 
included the IO’s report.  On March 5, 2004, CGPC responded, stating that after reviewing the 
Area Commander’s order overturning the NJP and consulting with legal counsel, CGPC would 
remove from consideration by the Revocation Board the IO’s memorandum with its recommen-
dations, as well as enclosures 1, 2, 3, 4, and 35 of the IO’s report, but that enclosures 5 through 
34 would be considered by the board.  On March 18, 2004, the applicant objected again through 
his counsel, stating that because the IO’s report could not be entered into the applicant’s PDR, it 
could not be considered by the Revocation Board and that the IO’s report in its entirety was part 

On  January  29,  2004,  the  applicant  acknowledged  receipt  of  CGPC’s  notification  and 

of the NJP proceedings and so were ordered removed from the applicant’s record by the Area 
Commander.  On March 30, 2004, CGPC responded, stating that upon further review, enclosures 
1 and 2 as well as 5 through 34 would be submitted to the Revocation Board for consideration 
because  enclosures  1  and 2 were official records.  On April 19, 2004, the applicant’s counsel 
submitted a third objection to the enclosures to be reviewed by the board, emphasizing that under 
Article 12.A.11.b.3. of the Personnel Manual, only the applicant’s record could be reviewed by 
the Revocation Board and the IO’s report could not be entered in his PDR and so should not be 
reviewed by that board.  On May 6, 2004, Commander, CGPC responded to the third objection, 
stating that Article 12.A.11. does not specify that only the documents in an officer’s PDR can be 
considered by a Revocation Board.  He stated that what is considered an officer’s “record” varies 
depending upon the purpose for which it is being used.  He noted that an officer’s “record” is 
defined  one  way  for  the  purposes  of  promotion  boards  but  may  include  other  documents  and 
information for the purposes of making billet assignments or separation decisions.  He stated that 
because “the purpose of a revocation panel is to determine whether one should continue to serve 
as an officer, an officer’s record for this purpose may contain information relevant to  that deci-
sion that does not appear in the PDR, provided the information is otherwise trustworthy and reli-
able.”    He  also  noted  that  the  Area  Commander’s  letter  dated  March  24,  2003,  required  the 
removal of only the letter of reprimand and references to the NJP.   Therefore, enclosures 1, 2, 
and 5 through 34 to the IO’s report could properly be included as relevant information because 
they did not mention the letter of reprimand or the NJP. 
 
Resignation and DD 214 
 
 
On  May  18,  2004,  the  applicant  submitted  a “Request for Unqualified Resignation” to 
resign his commission as of August 1, 2004, which would negate the need for the Revocation 
Board, which was slated to convene on May 25, 2004.  He wrote that the “difficulty in correcting 
misinformation contained in an OER, and a disagreement over what material is appropriate to be 
presented  to  the  [Revocation  Board]  has  prompted  this  request  for  resignation.”    On  May  19, 
2004, CGPC approved his request as a resignation in lieu of special board action for reason of 
substandard performance. 
 
 
The  applicant’s  DD  214,  dated  August  1,  2004,  indicates  that  he  was  honorably  dis-
charged under Article 12.1.15. of the Personnel Manual.  (There is no such article.)  The separa-
tion  code  is  BHK  and  the  narrative  reason  for  separation  is  “Substandard  Performance.”    On 
August 22, 2006, the Coast Guard issued a DD 215 to correct the citation on the DD 214 to Arti-
cle 12.B.15. of the Personnel Manual.  However, Article 12.B.15. concerns only the disability 
discharges of enlisted members.2 
 
Discharge Review Board 
 
On June 26, 2006, the President of the DRB forwarded the recommendation of the DRB 
 
to the Commandant.  The DRB based its recommendation on the documents in an applicant’s 
PDR, a letter from the applicant, the applicant’s testimony at a hearing, and documentation of his 
                                                 
2 It appears that the Coast Guard intended to correct the separation authority to Article 12.A.15., which concerns the 
separation of officers “for cause.”  However, because the applicant has not requested correction of the DD 215 or the 
separation authority on the DD 214 and such a correction is not clearly in his interest, the Board will not address the 
matter unless a correction of the separation authority is necessitated by other corrections to the DD 214. 

dismissed  mast  and  the  disqualification  of  his  rating  chain,  which  he  showed  the  DRB  at  the 
hearing.  Based on these records, the DRB found no basis for the negative OER in the case file 
and concluded that the substitute rating chain must have based the disputed OER on information 
from  the  disqualified  rating  chain,  which  was  biased.    The  DRB  found  that  the  applicant’s 
discharge  was  both  improper  and  inequitable.    It  recommended  that  the  separation  code  and 
narrative reason for separation on the applicant’s DD 214 be changed to reflect a discharge for 
“miscellaneous/general  reasons.”    The  DRB  also  recommended  that  the  disputed  OER  be 
replaced with a continuity OER and that the applicant be offered reinstatement on active duty or 
in the Reserve without loss of precedence.  The DRB argued that “all actions were based on a 
Captain’s Mast that was found to be improper and was eventually removed from the record, all 
negative actions as a result of that improper action, including the OER mentioned above, should 
be remedied.” 
 

The President of the DRB advised the Commandant that he agreed with the recommend-
ed changes to the separation code and narrative reason for separation on the applicant’s DD 214 
but  that  he  did  not  concur  with  the  DRB’s  conclusions  about  the  propriety  and  equity  of  the 
applicant’s discharge.  He stated that the issues the DRB raised about the applicant’s OER “do 
not mitigate the fact that [he] requested, and was subsequently granted, a voluntary resignation in 
lieu of a Revocation Board.  Since he received the separation he requested, I believe that the dis-
charge was both proper and equitable.” 

 
On July 27, 2006, the Commandant disapproved the proceedings and recommendation of 

 
 
On December 18, 2007, the Judge Advocate General (JAG) of the Coast Guard submitted 
an advisory opinion in which he recommended that the Board deny the applicant’s requests.  In 
so doing, the JAG adopted the findings and analysis of the case provided in a memorandum pre-
pared by CGPC. 
 

With  respect  to  the  first  disputed  OER,  CGPC  stated  that  it  granted  the  applicant’s 
request for a substitute rating chain after the applicant’s NJP was overturned due to procedural 
defects.  CGPC stated that although the substitute rating chain members did not directly observe 
the  applicant’s  performance,  they  were  able  to  evaluate  aspects  of  his  performance  based  on 
“credible  information  from  an  administrative  investigation  …  that  showed  [he]  engaged  in  an 
inappropriate relationship with a fellow officer.”  CGPC stated that the substitute rating chain 
was entitled to rely on the enclosures to the IO’s report as long as they did not rely on the flawed 
NJP proceedings.  CGPC noted that the Area Commander’s letter overturning the NJP showed 
that he expected the applicant’s misconduct to be documented on an OER.  CGPC stated that the 
rating chain properly avoided any mention of the NJP in preparing the two disputed OERs “and 
relied on the facts as supported by the enclosures.”  CGPC concluded that the disputed OERs 
were prepared in accordance with Coast Guard regulation and policy.   

 
CGPC alleged that it acted reasonably, justifiably, and fairly in initiating action to con-
vene a Revocation Board based on the adverse information in enclosures 1, 2, and 5 through 34 
to the IO’s report.  CGPC stated that regulations do not restrict either CGPC or a Revocation 

the DRB and ordered that his DD 214 and other records remain as they are. 
 

VIEWS OF THE COAST GUARD 

Board to only those documents filed in an officer’s PDR.  CGPC stated that a Revocation Board 
may review “available and factual matters of record, such as sworn statements in an administra-
tive investigation,” in addition to the records kept in a PDR.  CGPC noted that in BCMR Docket 
No.  1999-171,  the  BCMR  upheld  the  use  of  material  from  an  investigation  by  Coast  Guard 
Investigative  Service  by  a  special  board  “as  long  as  the  applicant  was  afforded  the  essential 
requirements of due process.”  CGPC stated that the applicant was afforded due process in that 
he was allowed to view and comment on the evidence that would be considered by the Revoca-
tion Board.   

 
CGPC concluded that the applicant was properly discharged based on his approved vol-
untary request and that the separation code BHK and narrative reason for separation are appro-
priate  under  the  Separation  Program  Designator  Handbook.    In  support of its findings, CGPC 
submitted copies of some of the enclosures to the IO’s report, which are summarized above, and 
affidavits from the substitute rating chain, as summarized below. 
 
Declaration of the Supervisor for the Disputed OERs, Dated October 31, 2007 
 
 
The  Supervisor  stated  that  as  the  Assistant  Chief  for  Major  Cutter  Forces  he  routinely 
spoke  with  the  XO  of  the  applicant’s  cutter  during  the  evaluation  periods  for  both  disputed 
OERs.  He stated that he assigned the applicant a mark of 2 for Workplace Climate in the Super-
visor’s section of the first disputed OER based on information in the IO’s report, which his office 
received  before  the  Area  Commander  overturned  the  NJP.    He  alleged  that  he  completed  the 
OER “fairly, properly and without bias” based on the information in the IO’s report about the 
applicant’s unacceptable relationship with a fellow officer aboard his cutter, which is a violation 
of Coast Guard policy on interpersonal relationships.  He noted that Article 8.H.2.d. of the Per-
sonnel  Manual states that unacceptable relationships are “inappropriate and not allowed under 
service policy.”  The Supervisor further alleged that nothing prohibits the report of an investiga-
tion convened under the Military Justice Manual from being used for administrative purposes, 
such as documenting an officer’s performance in an OER. 
 
Declaration of the Reporting Officers for the Disputed OERs, Dated October 24, 2007 
 
 
The Reporting Officer stated that as Chief of the Xxxxxx Area’s Major Cutter forces in 
2002 and 2003, he was responsible for programmatic oversight and fleet management of the cut-
ters, including the applicant’s cutter.  He was also the first-line supervisor of the CO of that cut-
ter and therefore had routine contact with him about shipboard matters, including personnel.  The 
Reporting Officer stated that his office became aware of the NJP proceedings during the legal 
review after the mast.  He stated that because of the number of NJP proceedings on the cutters, 
his office only reviewed NJP cases that were appealed.  During his office’s review of the appli-
cant’s NJP, he spoke with the CO of the cutter several times and the Supervisor spoke with the 
XO several times to collect facts. 
 
 
When  CGPC  informed  him  that  he  would  have  to  serve  as  the  applicant’s  Reporting 
Office  because  the  applicant  had  requested  a  substitute  rating  chain,  he  queried  the  decision 
because of his lack of observation of the applicant’s performance.  Both CGPC and the Area’s 
legal  office  told  him  that  the  administrative  investigation  and  the  evidence  therein  “would  be 
appropriate information for my consideration” in evaluating the applicant’s performance, but that 

he could not mention the NJP or the appeal of the NJP.  In addition, he was told that he could 
mark “‘not observed’ in most categories while still commenting in those areas where I had suffi-
cient information to make an informed opinion.”  Therefore, he based his marks in the disputed 
OER on the statements in the IO’s report, the applicant’s OER input (the OSF), and his own per-
ception of the applicant’s behavior.  The Reporting Officer stated that he “did not discuss the 
OER with either the CO or XO of the [cutter].” 
 
The Reporting Officer denied the applicant’s allegations that he was biased because of his 
 
prior interaction with the applicant’s father.  He stated that his office had no role in conducting 
the investigation or the mast and only served as a conduit of information between the cutter’s 
command  and  the  Area  Commander  during  the  review  upon  appeal.    The  Reporting  Officer 
denied having ever been negatively counseled about the NJP or the appeal.  He alleged that he 
was actually “praised for [his] programmatic handling of this sensitive and complex matter.”  He 
stated that he had never met the applicant and had no reason to be biased against him.  Moreover, 
he can recall meeting the applicant’s father  
 

only briefly at a meeting of several of his fellow contractors, representatives of xxxxxxxxxxx, and 
members of the Operational Forces staff. … I do not recall any awkwardness at the meeting, which 
I recall as cordially professional.  [The applicant’s father] and his co-workers were contracted to 
look at cutter casualty data and how to present it in terms of overall operational readiness.  Their 
work was neither controversial nor critical.  If they ever filed a final report, I am not aware of it.  
There was not resulting negative pressure or even follow-on discussions related to their particular 
efforts.  A single 1-2 hour meeting certainly did not form the basis for any personal bias. 

 
 
The Reporting Officer stated that in preparing the first disputed OER, he “felt duty-bound 
to comment on [the applicant’s] inappropriate behavior on two separate occasions, particularly 
how those lapses, fueled by alcohol, reflected on his judgment, responsibility and general adher-
ence to CG core values.  I stand by those original marks and comments.” 
 
Declaration of the Reporting Officers for the Disputed OERs, Dated October 16, 2007 
 
 
The Reviewer of the disputed OERs, who was the Chief of the Operational Forces Branch 
for the Area, is now retired.  He stated that as the CO’s reporting officer, he was the first person 
to review the applicant’s mast appeal and he discovered “the fatal flaws in the NJP administra-
tive proceedings by the [cutter’s command].  I personally recommended to [the Area Command-
er] that the 5-day period for submission of the appeal be waived and that the mast be overturned.  
This was done in consultation with [the Area legal advisor].”  The Area Commander agreed with 
his  assessment  and  overturned  the  NJP  based  upon  the  procedural  errors  but  directed  that the 
applicant’s underlying conduct be documented on his OER.  The Reviewer alleged that but for 
the  procedural  errors, which he listed as “no mast rep[resentative], circumstances leading [the 
applicant] to [make] an incriminating statement, and pre-mast restrictions,” the NJP would not 
have been overturned.  The Reviewer stated that he personally reprimanded the CO of the cutter 
for his performance with respect to the applicant’s mast. 

 
The Reviewer stated that because the applicant decided to have his regular rating chain 
disqualified,  officers  who  did  not  personally  observe  his  performance  during  the  evaluation 
period were required to prepare the OER.  However, the Reviewer argued, “OERs are routinely 
written by supervisors and reporting officers on personnel with whom they do not have routine 

personal observation” when the facts are otherwise “well known and documented.”  He alleged 
that  ignoring  the  applicant’s  misconduct  during  the  evaluation  period  “was  not  an  option,” 
especially given the Area Commander’s direction in the March 24, 2003, letter.  He also alleged 
that “[a]ll personnel in the rating chain for this OER had personal knowledge of the [applicant’s] 
negative performance.” 

 
Regarding  the  allegation  that  he  was  biased  because  of  his  prior  interaction  with  the 

applicant’s father, the Reviewer stated that he  

 
always had the utmost respect [for the applicant’s father] while we served together as Officers in 
the  Coast  Guard.    Although  he  was  always  senior  to  me  with  respect  to  linear  numbers,  I  have 
never worked for, [or] worked with [him], nor did he work for me.  We were simply members of 
the  same  community,  the  Surface  Operations  community  …  a  tight-knit  group  that  always  had 
shown respect and admiration for each other.  Although I am somewhat offended by these [allega-
tions of grudge and bias], I still have the utmost respect for [the applicant’s father], and will dis-
miss them as comments made by a concerned father wanting the best for their child. 
 
2.  [The applicant’s father] references a project that we worked together after his retirement that 
may have led to this bias.  To my recollection, he was working as a civilian contractor on a CG 
funded project and he conducted one interview with myself and the Operational Forces Branch.  
This survey was conducted in my office and as far as I remember ended amicably.  I honestly can-
not even remember the subject of the study. 
 
3.  [The applicant’s father] also states that I purposely withheld information about his son, includ-
ing his whereabouts after the [cutter] issue.  The only conversation I can recall was one in which I 
told [him] that I was not at liberty to discuss his son’s case with respect to the incident, the NJP 
case,  and  the  subsequent  performance  evaluations.    [The  applicant]  is  an  adult  and  information 
concerning him, other then Health and Well being, is protected even from a parent under the Pri-
vacy Act.  I informed [the applicant’s father] that any information concerning his son’s perform-
ance needed to be obtained directly from his son.  I even referred him to xxxxxx legal if he had 
additional questions. 
 
4.  … I believe the [disputed OER] was correct and administratively appropriate.  The [Supervisor 
and Reporting Officer] had personal knowledge/observation of the negative performance dimen-
sions  outside  of  the  NJP  case.    To  my  knowledge  no  mention  of  the  NJP  was  included  in  [the 
applicant’s] record by Xxxxxx Area, and there is no personal bias by me held against [him] or his 
father and, in fact, I was first and his strongest advocate for granting his mast appeal. 
 

APPLICANT’S RESPONSE TO THE VIEWS OF THE COAST GUARD 

 

On December 21, 2007, the Chair sent the applicant’s counsel a copy of the views of the 
Coast Guard and invited him to respond within thirty days.  The applicant was granted an exten-
sion and responded on February 29, 2008.  

 
The applicant alleged that the JAG’s recommendation constitutes a reversal of its prior 
recommendation that the Commandant approve the recommendation of the DRB to grant relief.  
He argued that his resignation cannot be considered voluntary because CGPC refused to remove 
all  the  enclosures  to  the  IO’s  report  from  consideration  by  the  proposed  Revocation  Board.  
Therefore, his resignation was coerced, not voluntary. 

 
The applicant alleged that the investigation into his relationship with LTJG X was not an 
informal administrative investigation but a pre-disciplinary investigation governed by the Mili-

tary Justice Manual.  Therefore, the entire IO’s report with all of its enclosures is “an integral part 
of the NJP proceedings,” which were ordered removed from his record by the Area Commander.  
However,  instead  of  fully  removing  them,  CGPC  threatened  to  use  them  for  the  Revocation 
Board and is now submitting them for consideration by the BCMR.  He argued that when the 
Area Commander ordered the removal of the NJP proceedings, including the IO’s report, from 
his record, CGPC should have destroyed them or, at least, made it impossible for them to be used 
against him in any subsequent forum. 

 
The applicant stated that the substitute rating chain must have relied on information from 
the applicant’s XO and CO in preparing the OER and on information in the IO’s report, which 
the  Area  Commander  had  ordered  removed  from  his  record,  because  they  never  personally 
observed his performance and had no direct knowledge of it.  The applicant further alleged that it 
was unfair for the substitute rating chain to assign him so many marks of “not observed” and then 
to assign him very low marks in certain categories based up “a single set of circumstances” rather 
than his overall performance in those categories as documented in his OSF. 

 
The applicant argued that Article 8.H. of the Personnel Manual does not prohibit the con-
duct of which he was accused.  He also alleged that under Articles 8.H.6.c. and e., “allegations of 
violations cannot be used against personnel in their formal evaluations (such as OERs), until they 
are counseled and an administrative entry made in their personnel record,” which his command 
failed to do. 

 
The applicant again disputed CGPC’s decision to allow the Revocation Board to see any 
record pertaining to the applicant except those filed in his PDR.  He argued that the Coast Guard 
is bound by its own regulations and that it should have written Article 12.A.11.b.3. differently if 
documents  outside  the  PDR  were  to  be  considered.    The  applicant  argued  that  the  “clear  and 
obvious meaning” of the phrase “officer’s record” in Article 12.A.11.b.3. is an officer’s PDR and 
does not include any other documents, such as the report of an IO.  

 
The applicant argued that the IO’s report should have been removed from consideration 
by  the  Revocation  Board  because  he  was  not  provided  due  process.    He  alleged  that  he  was 
denied due process because his statements were coerced by threat, he was denied legal counsel, 
and he was illegally detained.  The applicant further argued that in the case cited by the Coast 
Guard, BCMR Docket No. 1999-171, the investigation had not been ordered removed from that 
applicant’s record. 

 

APPLICABLE LAW 

Regulations about Personal Relationships  
 
 
Article  8.H.  of  the  Personnel  Manual  in effect in 2002 concerns personal relationships 
among  Coast  Guard  personnel.    Article  8.H.1.c.  states  that  “interpersonal  relationships  which 
raise even a perception of unfairness undermine good leadership and military discipline.”  Article 
8.H.2.d.3. provides the following descriptions of types of relationships: 
 

a. Personal relationship: Non-intimate, non-romantic association between two or more people (of 
the  same  gender  or  not),  such  as  occasional  attendance  at  recreational  or  entertainment  events 

(movies,  ball  games,  concerts,  etc.)  or  meals.  (Does  not  involve  conduct  which  violates  the 
UCMJ.) 
b. Romantic relationship: Cross-gender sexual or amorous relationship.  (Does not involve conduct 
which violates the UCMJ.) 
c.  Unacceptable  relationship:  Inappropriate  and  not  allowed  under  Service  policy.  Resolution 
normally administrative.  Relationship must be terminated or otherwise resolved once recognized. 
d. Prohibited relationship: Violates the UCMJ. Resolution may be either administrative, punitive, 
or both as circumstances warrant. 

 

Article 8.H.2.e. states that a relationship does not violate Service policy unless “the rela-
tionship or the members' conduct fails to meet the standards set by this section, standards of con-
duct set by the Uniform Code of Military Justice (UCMJ), or other regulations.”  
 

Article 8.H.2.f. states that a romantic relationship between any two members assigned to 
the same cutter constitutes an “unacceptable romantic relationship” that violates Service policy.  
The  article  explains  that  “[t]he  nature  of  operations  and  personnel  interactions  on  cutters  and 
small  shore  units  makes  romantic  relationships  between  members  assigned  to  such  units  the 
equivalent  of  relationships  in  the  chain  of  command  and,  therefore,  unacceptable.  This  policy 
applies regardless of rank, grade, or position.” 
 

Article 8.H.6.c. states that when a command has “potential concerns about the character-
istics  of  a  relationship,”  the  members  may  be  informally  or  formally  counseled  and  may  be 
ordered  to  terminate  a  relationship.    Article  8.H.6.d.  states  that  “[m]embers  may  request  or  a 
command may recommend reassignment of a member involved in a questionable relationship.  
However, reassignment is not a preferred option.  The Coast Guard is not obligated to reassign 
personnel due to members’ desires or based solely on a relationship.  When reassignment is not 
an option, members may be directed to end a relationship.”  Article 8.H.6.e. states that “[w]hen 
members do not respond favorably to counseling, comments and marks in officer and enlisted 
evaluations may be appropriate.”  Under Articles 8.H.6.f. and 8.H.6.g., commands may award 
NJP, prefer charges for court-martial, or recommend separation. 

 

Regulations about Investigations 
 
Article 1.C.2.a. of the Administrative Investigations Manual (AIM) in effect in January 
 
2003 states that “[i]f there is no basis for investigation other than prospective disciplinary action, 
a preliminary inquiry under RCM 303, MCM, or a pretrial investigation under article 32, UCMJ 
and RCM 405, MCM should be conducted without recourse to the proceedings of an administra-
tive investigation under this manual.” 
 

Rule  303  of  the  Rules  for  Courts-Martial  (RCM)  in  the  Manual  for  Courts-Martial 
(MCM) states that “[u]pon receipt of information that a member of the command is accused or 
suspected of committing an offense or offenses triable by court-martial, the immediate comman-
der shall make or cause to be made a preliminary inquiry into the charges or suspected offenses.”  
The discussion for this rule in the MCM states the following: 

 
The  preliminary  inquiry  is  usually  informal.    It  may  be  an  examination  of  the  charges  and  an 
investigative  report  or  other  summary  of  expected  evidence.    In  other  cases  a  more  extensive 
investigation may be necessary.  Although the commander may conduct the investigation person-
ally or with members of the command, in serious or complex cases the commander should consider 

 

Article 1.B.1.a. and c. of the Coast Guard’s Military Justice Manual (MJM) provide that 
any member who becomes aware of an offense under the UCMJ may complete and submit an 
offense  report,  form  CG-4910,  to  his  or  her  command,  and  “[a]ny  report  of  misconduct  may 
serve as the basis for initiating a preliminary inquiry.” 

 
Article 1.B.3.a. of the MJM provides that when a member has been charged with viola-
tions  of  the  UCMJ,  a  CG-4910  is  normally  completed,  forwarded  to,  and  “reviewed  by  the 
executive  officer.  …    If  the  executive  officer  determines  that  nonjudicial  punishment  may  be 
appropriate, he or she should advise the member of the general nature of the offense that he or 
she is suspected of committing and that the command is considering imposition of nonjudicial 
punishment. The executive officer should designate a preliminary inquiry officer [PIO] to con-
duct a preliminary inquiry.  If appropriate, the executive officer may dismiss the matter, if dele-
gated this authority by the commanding officer.” 
 

Article  1.B.3.c.  of  the  MJM  states  that  “[t]he  executive  officer  normally  designates  a 
member of the command to conduct a preliminary inquiry. The designation may be made orally 
or in writing.”  Article 1.B.4. states that the duties of a PIO include  

whether to seek the assistance of law enforcement personnel in conducting any inquiry or further 
investigation.    The  inquiry  should  gather  all  reasonably  available  evidence  bearing  on  guilt  or 
innocence … 

 

reviewing  the  description  of  each  suspected  offense  in  the  Manual  for  Courts-Martial  and 

• 
addressing each element of each offense during his inquiry; 
•  conducting a preliminary investigation either remotely or on-site; 
•  questioning witnesses who have information about an alleged offense and gathering written 
statements from them; 
•  preparing summaries of interviews of witnesses who refuse to provide statements; 
•  collecting documents such as log entries and other evidence of suspected offenses; 
•  correcting the CG-4910 based on his findings if necessary; and 
•  completing a preliminary inquiry report, with a summary of events and supporting materials, 
as well as the PIO’s own findings, opinions, and recommendations about whether should con-
vene a mast to dispose of the offenses, refer the charges for court-martial, and/or take adminis-
trative actions, such as preparing OERs or initiating separation. 

   
Article 1.B.4.a.(4) of the MJM specifically states that it “is usually recommended that the 
PIO not question the suspect until after collecting available evidence and questioning other wit-
nesses.  By doing so, the PIO is better prepared to interview the suspect, formulate questions, 
confront issues in contention and ascertain the suspect's credibility.” 
  
 
Under Article 1.B.5. of the MJM, an XO shall review a PIO’s report as well as the CG-
4910, which the XO may amend as necessary.  The XO has authority to dismiss the charges, if 
such authority is delegated to the XO by the CO, or the XO may refer the matter to the CO with a 
recommendation that the charges be disposed of at mast or referred for trial by court-martial.  If 
the XO decides that the charges should be disposed of at mast, the XO notifies the member. 

Laws and Regulations about Restraints and Confinement 

 
Chapter  1.B.2.  of  the  MJM  states  that  “[p]re-mast  confinement  or  restriction  is  not 
authorized.  A  member  may  be  placed  in  pretrial  restraint  only  if  the  command  is  considering 
referring the charges against the member for trial by special or general court-martial. A command 
may not automatically place a member in restraint solely because he or she has been placed on 
report.  Pretrial  restraint,  including pretrial restriction or confinement, may be imposed only in 
very limited circumstances [see, RCM 304 and 305]. Generally, pretrial restraint may be imposed 
only  if  necessary  to  ensure  an  accused's  presence  at  trial  or  to  prevent  the  commission  of 
additional  serious  offenses.  The  member  must  be  immediately  released  from  restraint  if  the 
command decides to dispose of the offense(s) other than at court-martial.” 
 

Under Rule 304 of the Rules for Courts-Martial, a CO may impose pre-trial restraints, 
such as orders prohibiting communications with potential witnesses if there is probable cause to 
do so, which requires a reasonable belief that (a) an offense triable by court-martial (against the 
UCMJ) has been committed; (b) the person restrained committed it; and (c) the restraint ordered 
is required by the circumstances.  The discussion to the rule requires restraints to permit pretrial 
preparations. 

 
Under Rule 305 of the Rules for Courts-Martial, a CO may physically confine a member 
if there is probable cause to do so, which requires a reasonable belief that (a) an offense triable by 
court-martial (against the UCMJ) has been committed; (b) the person restrained committed it; 
and (c) the confinement is required by the circumstances.  However, a member so confined is 
entitled  to  be  informed  of  his  rights  and  of  the  procedures  by  which  his  confinement  will  be 
reviewed.  Within 72 hours of the confinement order, the CO must release the member from con-
finement unless the CO also finds, in addition to the above criteria for probable cause, (d) that 
the confinement is necessary either to ensure the member’s presence for a trial, pre-trial hearing, 
or investigation or to prevent “serious criminal misconduct,” such as intimidation of witnesses 
and obstruction of justice, and (e) that less severe forms of restraint are inadequate. 

Laws and Regulations about the Applicant’s NJP 

 
Article 92 of the UCMJ concerns a member’s failure to obey a lawful order or regulation.  
Article 125 concerns sodomy, the definition of which includes oral sex.  Article 133 concerns 
conduct unbecoming an officer and gentleman.  Article 134 concerns adultery, the definition of 
which requires “sexual intercourse” between two people while at least one of them is married to 
a third person. 
 
 
Under Article 15 of the UCMJ, commanding officers, at their discretion, may impose NJP 
for minor violations of the UCMJ to maintain good order and discipline when administrative cor-
rective measures seem inadequate and court-martial seems excessive.  Manual for Courts-Martial 
(MCM), Part V, Para. 1.d.(1).  Only members who are not “attached to or embarked in a vessel” 
may refuse NJP by demanding trial by court-martial. 10 U.S.C. § 815(a);  MCM, Part V, Para. 3.  
Under  MCM,  Part  V,  Para.  4.a.,  “[i]f,  after  a  preliminary  inquiry  (see  R.C.M.  303,  the  [NJP] 
authority determines that disposition by [NJP] is appropriate …, the [NJP] authority” must pro-
vide the member with notification of the pending mast proceeding and the alleged offenses, a 

brief summary of the information upon which the allegations are based, and a statement of his 
rights at mast.”  The member is entitled, inter alia, to appear before the officer imposing NJP; to 
examine documents to be considered by the NJP authority; to be accompanied by a spokesperson 
to speak on his behalf (but not to question witnesses) unless the punishment is significantly lim-
ited and unless the mast would have to be delayed to permit the presence of a selected spokesper-
son; to present matters in defense, extenuation, and mitigation orally, or in writing, or both; and 
to present witnesses.  MCM, Part V, Para. 4.c. 
 

“Failure to comply with any of the procedural provisions of Part V of this Manual shall 
not invalidate a punishment imposed under Article 15, unless the error materially prejudiced a 
substantial right of the servicemember on whom the punishment was imposed.”  MCM, Part V, 
Para. 1.h. 

 
Article 15 and Part V of the Manual for Courts-Martial “do not apply to include, or limit 
use of administrative corrective measures that promote efficiency and good order and discipline. 
…  Administrative  corrective  measures  are  not  punishment,  and  they  may  be  used  for  acts  or 
omissions  which  are  not  offenses  under  the  code  or  for  acts  or  omissions  which  are  offenses 
under the code.”  MCM, Part V, Para.1.g. 
 

Chapter 1.C.2.b. of the MJM states that a “member attached to or embarked in a vessel 
has no right to demand trial by court-martial in lieu of NJP or, consequently, to consult with a 
military or civilian attorney prior to NJP regarding the option to demand trial by court-martial.” 

 
Under Chapters 1.C.3.a. and 1.B.3.b. of the MJM, the XO should appoint an officer of the 
unit to serve as the “mast representative” for the accused.  Chapter 1.C.1. states that because a 
mast is not an adversarial proceeding, a member “has no right to be represented by an attorney at 
mast.”  However, “the member may obtain the services of an attorney or any other person, at no 
expense to the government, to appear as his or her spokesperson.”  Chapter 1.C.4.c. states that 
the CO “may not exclude the spokesperson from the mast solely because he or she is an attor-
ney.”   

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

 
Chapter  1.C.4.b.  states  that  the  role  of  a  spokesperson  is  to  speak  for  the  member  “at 
those times during the mast when the member’s responses are invited by the commanding offi-
cer.  A spokesperson may be anyone, including an attorney retained by the member.”  Chapter 
1.C.4.e. provides that a “spokesperson is not permitted to examine or cross-examine witnesses,” 
except  at  the  discretion  of  the  CO,  but  “is  always  permitted to speak for a member when the 
member is otherwise entitled to speak.” 

 
Chapter 1.E. provides that the maximum punishment a captain (O-6) may impose on a 
subordinate officer at mast is an admonition or reprimand and 30 days of restriction.  Chapter 

1.F.1.  provides  that  a  member  may  appeal  an  NJP  “if  he  or  she  considers  the  punishment 
imposed ‘unjust’ or ‘disproportionate’ to the acts of misconduct for which punished … in writing 
within 5 calendar days of the imposition of the punishment.”  Chapter 1.F.1.a. defines “unjust” to 
include various kinds of illegality and denial of rights. 
 
Regulations about OERs 
 
Under Article 10.A.2. of the Personnel Manual, an officer’s rating chain usually consists 
 
of his direct supervisor who observes and directs his work on a daily basis; his reporting officer, 
who is usually the supervisor’s supervisor; and the reviewer, who is usually the reporting offi-
cer’s supervisor.  Under Article 10.A.2.g., an officer may ask that one or more members of his 
rating chain be “disqualified,” which includes “any situation in which a personal interest or con-
flict on the part of the Supervisor, Reporting Officer, or Reviewer raises a substantial question as 
to whether the Reported-on Officer will receive a fair, accurate evaluation.”  Rating chain offi-
cials may base their evaluations on direction observation of an officer’s performance, the offi-
cer’s own OER input, and other reliable records and reports about his performance. 
 

Article 10.A.4.f.1. prohibits a rating chain from mentioning that an “officer’s conduct is 
the subject of a judicial, administrative, or investigative proceeding, including criminal and non-
judicial punishment proceedings under the Uniform Code of Military Justice, … except as pro-
vided in Article 10.A.3.c. … These restrictions do not preclude comments on the conduct that is 
the subject of the proceeding.  They only prohibit reference to the proceeding itself.” 

 
Article 10.A.3.c.2., which concerns “Concurrent OERs,” states that a “concurrent OER is 
an OER submitted in addition to a regular or special OER. The permanent unit’s OER is never 
considered a concurrent report and should not be so identified.  A concurrent report is always in 
addition to a regular or special OER, and thus does not count for continuity. The unit to which 
the Reported-on Officer is permanently attached is always responsible for ensuring that continu-
ity is maintained with either regular or special OERs. Concurrent reports may be submitted only 
when the officer is: … e. Performing temporary assigned duty (TAD) away from a permanent 
station for a period of at least 60 consecutive days while being observed by a senior other than 
the regular Reporting Officer.”   
 

Under Article 10.A.4.g., an officer may submit a Reply to any OER for entry in his record 
with the OER.  Article 10.A.4.g.1. states that “[r]eplies provide an opportunity for the Reported-
on Officer to express a view of performance which may differ from that of a rating official.  Arti-
cle  10.A.4.g.2. states that “[c]omments should be performance-oriented, either addressing per-
formance not contained in the OER or amplifying the reported performance. Restrictions outlined 
in Article 10.A.4.f. apply. Comments pertaining strictly to interpersonal relations or a personal 
opinion of the abilities or qualities of a rating chain member are not permitted.” 
 
Regulations about the Documentation of Alcohol Abuse 

 
Article  20.B.2.d.  of  the  Personnel  Manual  states  the  following  about  “Alcohol-Related 

Situations”: 

 

An alcohol-related situation is defined as any situation in which alcohol was involved or present 
but was not considered a causative factor for a member's undesirable behavior or performance. A 
member  does  not  have  to  consume  alcohol  to  meet  this  criterion,  e.g.,  purchasing  alcohol  for 
minors. Commands shall not use the term “alcohol related situations” when a member's behavior 
clearly meets the criteria of an “alcohol incident.” Members involved in alcohol related situations 
shall be counseled on their use of alcohol and informed of the conduct expected of Coast Guard 
members.    Commanding  officers  are  strongly  encouraged  to  consider  whether  screening  and/or 
alcohol awareness training such as IMPACT is appropriate. Commanding officers shall document 
such  occurrences  with  an appropriate Administrative Remarks (CG-3307) entry in the member's 
Personnel  Data  Record  (PDR).  Documentation  of  alcohol  related  situations  provides  commands 
with  significant  background  information  for  determining  whether  any  administrative  or  medical 
action is necessary. 

 

Article 20.A.2.d.1. defines an “alcohol incident” as “[a]ny behavior, in which alcohol is 
determined, by the commanding officer, to be a significant or causative factor, that results in the 
member's  loss  of  ability  to  perform  assigned duties, brings discredit upon the Uniformed Ser-
vices, or is a violation of the Uniform Code of Military Justice, Federal, State, or local laws. The 
member need not be found guilty at court-martial, in a civilian court, or be awarded non-judicial 
punishment for the behavior to be considered an alcohol incident.”  Article 20.B.2.h.1. states that 
“[o]fficers will be processed for separation following a second alcohol incident.”  There is no 
corresponding regulation requiring the separation of officers involved in more than one “alcohol-
related situation.” 
 
Regulations about Revoking a Commission 
 

Article 12.A.11. of the Personnel Manual concerns “Revoking Officers’ Commissions in 

Their First Three Years of Service.”  Article 12.A.11.a.1. states the following: 

 
The  Service  considers  the  first  three  years  of  an  officer’s  career  a  probationary  period  during 
which he or she demonstrates ability to adapt to the requirements of Coast Guard life and shows 
capability for future development. Some officers either are unable to adapt to service life or their 
performance indicates it is doubtful whether the time and effort required will form them into effec-
tive officers. 
 
Article 12.A.11.b. provides the following procedures for revocation: 
 
1.  A  commanding  officer  or  a  superior  in  the  chain  of  command  may  recommend  revoking  the 
commission of an officer who has fewer than three years of continuous service as a Coast Guard 
commissioned officer. Commander (CGPC-opm) also may initiate board action to revoke an offi-
cer’s regular commission based on knowledge of adverse information about the officer. A com-
manding officer or superior in the chain of command shall recommend revocation in the form of a 
letter to Commander (CGPC-opm) containing the following information.  
 

a. Officer’s name; 
b. Length of service; 
c. Period of time officer was observed; 
d. Reason for recommendation; 
e. Specific facts or circumstances relating to performance; 
f. Medical reports or opinions, if applicable; 
g. Nature of counseling and other steps taken to correct deficiencies; 
h. Officer’s response to counseling; 
i. Special Officer Evaluation Report, if applicable. 

 

2. The recommending officer shall grant the officer concerned an opportunity to review the rec-
ommendation and permit him or her to comment as desired by letter endorsement. 
 
3. A panel of senior officers, normally consisting of the Coast Guard Personnel Command’s Chief, 
Administration Division; Chief, Officer Personnel Management Division; and a senior officer rep-
resentative  from  the  Headquarters  division  …  with  cognizance  of  the  officer’s  specialty  shall 
review  the  recommendation.  After  thoroughly  reviewing  the  officer’s  record,  the  panel  recom-
mends to the Commandant either executing the revocation proceedings under this Article or clos-
ing the case. … 
 
4. Commander (CGPC-opm) sends the panel’s recommendations to the Commandant for approval, 
modification, or disapproval (14 U.S.C. 281). 

 

FINDINGS AND CONCLUSIONS 

1. 

2. 

3. 

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

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

 
 
military record and submissions, the Coast Guard's submission, and applicable law: 
 
 
The application was timely. 
 
 
The  applicant  requested  an  oral  hearing  before  the  Board.    The  Chair,  acting 
pursuant to 33 C.F.R. § 52.51, denied the request and recommended disposition of the case with-
out a hearing.  The Board concurs in that recommendation. 
 
 
The applicant asked the Board to remove from his record (a) two OERs; (b) all 
documents relating to an informal investigation, to an alleged inappropriate relationship, and to 
his NJP on January 7, 2003; (c) a Page 7 dated April 11, 2003, concerning his referral for alcohol 
screening; (d) any administrative action taken in whole or in part on the basis of the OERs and 
NJP;  and  (e)  the  potential  revocation  of  his  commission,  his  resignation,  and  his  discharge 
papers.  He also asked the Board to offer him the opportunity to return to active duty with back 
pay and allowances.  In the alternative, he asked the Board to correct his DD 214 to show that he 
was discharged for “Miscellaneous/General Reasons” with separation code FND. 
 
 
 Regarding the first disputed OER, which covers his performance from October 1, 
2002,  to  January  31,  2003,  the  applicant  alleged  that it  is erroneous and unjust and asked the 
Board to replace it with one prepared “for continuity purposes only” with all performance catego-
ries marked “not observed.”  To establish that an OER is erroneous or unjust, an applicant must 
prove that it was adversely affected by (a) a “misstatement of significant hard fact,” (b) a “clear 
and prejudicial violation of a statute or regulation,” or (c) factors that “had no business being in 
the rating process.”3  The Board begins its analysis in every case by presuming that the disputed 
OER is correct as it appears in the record, and the applicant bears the burden of proving by a pre-
ponderance of the evidence that it is erroneous or unjust.4  Absent evidence to the contrary, the 

4. 

                                                 
3  Germano  v.  United  States,  26  Cl.  Ct.  1446,  1460  (1992); Hary  v.  United  States,  618  F.2d  704  (Ct.  Cl.  1980); 
CGBCMR Dkt. No. 86-96. 
4 33 C.F.R. § 52.24(b). 

5. 

Board presumes that the applicant’s rating chain prepared the disputed OER “correctly, lawfully, 
and in good faith.”5 
 
 
The first disputed OER contains primarily marks of “not observed,” no positive 
marks or comments, and several low marks supported by comments about his behavior during 
two port calls in December 2002 “creat[ing] the perception of an inappropriate relationship” and 
his misuse of alcohol causing him “to participat[e] in an inappropriate relationship.”  The appli-
cant alleged that the OER should be removed (a) because he did not have an inappropriate rela-
tionship, misuse alcohol, or lack courage during the reporting period, (b) because the substitute 
rating chain failed to include positive comments and marks based upon his OSF, and his OER 
Reply  was  rejected  twice,  (c)  because  the  substitute  rating  chain  relied  on  information  from 
members of his original rating chain who were biased, (d) because the substitute rating chain was 
biased against the applicant’s father and took revenge on him through his son’s OER, (e) because 
the  substitute  rating  chain  relied  on  the  IO’s  report,  which  the  Area  Commander  had  ordered 
removed from his record, and (f) because he did not receive due process during the investigation 
and so his self-incriminating statements to the IO should not have been considered.  The Board 
will address these allegations in order: 
 

The record before the Board shows that during one port call, the applicant 
and a female crewmate—LTJG X—kissed after drinking one or more shots of tequila at the Xxx 
Bar in the presence of several other crewmembers.  The applicant drank alcohol to excess that 
night and vomited in the bar twice.  The record further shows that a day or two later the applicant 
was counseled by his supervisor, the Operations Officer, about the kiss and the fact that he was 
creating a perception of an “unacceptable relationship”6 with LTJG X as there was a rumor about 
them among the crew.  Despite this counseling, during another port call about ten days later, the 
applicant was observed acting like a couple with LTJG X at a crew party and then slept alone in a 
bedroom with her the rest of the night and much of the next morning when he could have slept 
elsewhere  in  the  “villa”  they  had  rented,  sought  another  key  to  his  own  room  from  a  hotel 
employee or caretaker, or gone back to the cutter like his roommate LTJG C did.  Given these 
facts, the Board finds that the applicant has not proved that the comments in the first disputed 
OER about his misuse of alcohol and participation in an “inappropriate relationship”7 are errone-
ous or unjust.  In addition, whether the applicant’s failure to address his conduct during the port 
calls in his OSF shows a lack of courage is a matter of opinion that under these circumstances 
cannot be considered a misstatement of hard  fact.  Nor has he proved that his decision not to 
address these matters in his OSF was made after the reporting period ended. 
 
(b)  When the applicant decided to request disqualification of his entire rating 
 
chain because he thought they would prepare a biased OER after his NJP was overturned, CGPC 
granted his request and disqualified the Operations Officer, the XO, and CO the of the cutter, 
                                                 
5 Arens v. United States, 969 F.2d 1034, 1037 (Fed. Cir. 1992); Sanders v. United States, 594 F.2d 804, 813 (Ct. Cl. 
1979). 
6 Article 8.H.2.f. of the Personnel Manual states that a “romantic relationship” between any two members assigned to 
the same cutter constitutes an “unacceptable romantic relationship” that violates Service policy.  Article 8.H.2.d.3.b. 
defines a “romantic relationship” as a “cross-gender sexual or amorous relationship.” 
7 This phrase is not defined in the Personnel Manual, but Article 4.F.3.d. notes that “inappropriate relationships” that 
“adversely affect a unit’s morale, good order and discipline, and its mission performance” may result in a CO’s relief 
for cause. 

 

(a) 

 

(c) 

who had observed his performance throughout the evaluation period.  The applicant alleged that 
his substitute rating chain should have assigned him positive performance marks and comments 
in the OER based on his own input for the OER on an OSF.  However, while an OSF should be 
reviewed by the rating chain, an officer’s own claims about his performance should not be the 
sole basis for evaluation marks as an officer is not entitled to write his own OER.  The substitute 
rating chain in this case could not seek opinions from the disqualified rating chain members, who 
might have confirmed the applicant’s claims on his OSF.  In the alternative, the applicant argued, 
the  substitute  rating  chain  should  have  marked  all  performance  categories  as  “not  observed” 
because they did not personally observe the conduct that was the basis for the negative marks and 
comments in the OER.  However, under Article 10.A.2. of the Personnel Manual, rating chain 
members are allowed to rely on “reliable reports” in preparing OERs, and the substitute rating 
chain has stated that they relied on information in the IO’s report.  Therefore, the fact that no 
member  of  the  substitute  rating  chain  had  personally  observed  his  performance  during  the 
evaluation period does not render their marks and comments unjust or improper under the Per-
sonnel Manual.  Moreover, the Board notes that when the Area Commander overturned the NJP, 
he specifically stated that the applicant’s underlying conduct should be documented in his OER.  
Regarding the applicant’s OER Reply, he has not shown that CGPC erred in requiring him to 
remove  comments  that  presumably  failed  to meet the requirements of Article 10.A.4.g. of the 
Personnel Manual. 
 
 
In light of the declarations of the substitute rating chain affirming that they 
relied upon the evidence in the IO’s report to prepare the first disputed OER and given the lack of 
any contrary evidence, the Board finds that the applicant has not proved that the substitute rating 
chain based their marks and comments in the OER upon the opinions of the disqualified rating 
chain. 
 
 
The allegations of the applicant and his father about bias on the part of the 
substitute rating chain because of their prior interactions with his father are strongly contradicted 
in the declarations of the substitute rating chain.  The applicant has failed to overcome the pre-
sumption that they prepared the OER in good faith8 or to prove by a preponderance of the evi-
dence that any of the members of the substitute rating chain were biased against him or his father.  
 
 
The applicant alleged that the substitute rating chain’s reliance on informa-
tion in the IO’s report was improper because the Area Commander had ordered all references to 
his NJP to be removed from his record.  However, in the same letter that the Area Commander 
ordered all “references to the nonjudicial punishment” to be removed from the applicant’s record, 
he also stated that the applicant’s misconduct, which was revealed in the IO’s report, should be 
documented in applicant’s OER.  In addition, the Area Commander did not order the expunge-
ment of the investigation.  Therefore, it is clear that the intention and action of the Area Com-
mander was not to remove all evidence of the applicant’s misconduct from his records, and the 
only documentary evidence of his misconduct other than the NJP itself was the information in the 
IO’s report.   
 

(d) 

(e) 

 

 

 

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

 

Moreover, while the Coast Guard may have responded to the Area Commander’s 
order by removing all references to NJP from the applicant’s record—even the IO’s recommen-
dation about NJP—rather than just the documentation of the NJP (the Court Memorandum and 
the  letter  of  reprimand),  the  Board  disagrees  with  the  applicant’s  claim  that  the  Area  Com-
mander’s language required the IO’s report to be thrown out in its entirety as if it were only a part 
of the NJP.  The applicant argued that the purpose of the investigation was purely disciplinary 
and so the IO’s report should not exist apart from the NJP and must be thrown out with the NJP.  
However, there is insufficient evidence in the record to show exactly what kind of investigation 
was ordered and what sort of report the IO submitted.  Coast Guard regulations permit COs to 
convene informal investigations, which may ultimately result in no action at all; any number of 
purely administrative actions, such as transfers, bad OERs, “alcohol incident” documentation, or 
psychiatric screening; mast/NJP; court-martial;  or various combinations thereof.  The fact that 
one result of the investigation convened by the CO of the cutter was a mast proceeding for the 
applicant  does  not  mean  that  the  investigation  ceased  to  exist  apart  from  the  mast,  had  to  be 
thrown out in its entirety as part of the NJP, and could not be used as a basis for administrative 
actions.  The Area Commander’s letter required the Coast Guard to remove “all references to the 
nonjudicial punishment from your [the applicant’s] record,” and the applicant has not proved that 
the substitute rating chain relied on the NJP in preparing the OER. 

(f) 

Article 10.A.4.f.1. prohibits a rating chain from mentioning that an “officer’s con-
duct is the subject of a judicial, administrative, or investigative proceeding, including criminal 
and non-judicial punishment proceedings under the Uniform Code of Military Justice, … except 
as provided in Article 10.A.3.c. … These restrictions do not preclude comments on the conduct 
that is the subject of the proceeding.  They only prohibit reference to the proceeding itself.”  The 
applicant has not proved that the comments in the first disputed OER concerning his conduct that 
was the subject of the IO’s investigation are erroneous or unfair or contrary to any law, regula-
tion, or order of the Area Commander.  The substitute rating chain was entitled to base marks 
and comments in the OER on the information discovered in the investigation whether or not the 
NJP occurred or was overturned.9   
 

The applicant alleged that the substitute rating chain’s reliance on informa-
tion  in  the  IO’s  report  was  improper  because  his  self-incriminating  statement  to  the  IO  was 
coerced through threats and illegal confinement.  The applicant was very vague about the timing 
and duration of the confinement and the nature of the alleged threats.  Was he confined from the 
onset of the investigation, was he confined for more than 72 hours without a review while his CO 
considered court-martial,  or was he confined the day before the mast when the command dis-
covered that he and LTJG Y had communicated about the case in violation of the CO’s order, as 
indicated in his third statement to the IO?  Was he threatened with ridiculous charges and pun-
ishment, or did someone simply remind him that signing a sworn, false statement for an investi-
gation and violating an order not to communicate with LTJG Y about the case were also punish-
able offenses?  The Area Commander wrote in his letter overturning the NJP that he was “con-
cerned about the restrictions that were place on you [the applicant] before the mast, … and the 
circumstances that led to you providing an incriminating statement to the investigating officer.”  
On the other hand, the applicant, a well educated officer, was advised of his rights on January 3, 
2003, including his right to remain silent, and indicated by his signature that he did not desire to 
                                                 
9 Coast Guard Personnel Manual (COMDTINST M1000.6A), Arts. 10.A.4.c.4.d., 10.A.4.c.7.d., 10.A.4.f.1. 

 
 

 

consult an attorney and wanted to answer questions and make a statement.  He began each of his 
formal statements for the IO with the following sentence:  “With full understanding of my rights, 
I make the following statement freely, voluntarily, and without any promises or threats made to 
me.”  Moreover, three hours after signing a summary of his answers to some of the IO’s ques-
tions, the applicant went to the IO’s stateroom and said he thought he could save LTJG X’s mar-
riage but that, after learning what LTJG Y had related, he “needed to come clean morally and 
professionally.”  This addendum, which the applicant also signed, shows that his confession of 
January 6, 2003, was motivated not by illegal threats but by his realization that LTJG Y had told 
the IO a much more complete story of his behavior with LTJG X than he had confessed to; by his 
desire to save LTJG X’s marriage; and by his desire “to come clean.”  It also indicates that the 
applicant was not confined for much of the duration of the investigation because he was able to 
talk to LTJG Y about the case, contrary to orders, and to visit the IO’s room to make his third 
statement.  In light of these facts, the Board finds that the applicant has failed to prove by a pre-
ponderance of the evidence that his confession to the IO was coerced or that it should be consid-
ered unreliable or improper as a source of information for the substitute rating chain.  However, 
even if one assumes that his self-incriminating statements to the IO were coerced and so ignores 
them, the other witnesses’ statements to the IO provided a sufficient basis for the substitute rating 
chain to conclude that the applicant had misused alcohol and had an inappropriate relationship 
with LTJG X. 
 

6. 

The Board finds that the applicant has failed to prove by a preponderance of the evidence 
that the first disputed OER was adversely affected by a “misstatement of significant hard fact,” a 
“clear and prejudicial violation of a statute or regulation,” or factors that “had no business being 
in the rating process.”10   
 
Regarding the second disputed OER, which covers the period February 1 to July 
 
13, 2003, the applicant argued that it should be removed because he was assigned on temporary 
orders to another unit throughout the evaluation period, and the command at his temporary unit 
provided a substantive concurrent OER for his record.  The regular OER is signed by the substi-
tute rating chain and appears much the same as a continuity OER, with all performance catego-
ries marked “not observed,” except that block 3 contains the following explanation for the sub-
stitute rating chain and the marks of “not observed”:  “Not observed marks reflect Reported On 
Officer’s approved request to disqualify the regular shipboard rating chain.  Mbr TAD to Coast 
Guard  Xxxxxxx  for duration of period.”  The regular and concurrent OERs in the applicant’s 
record for this period conform to the applicable requirements of the Personnel Manual.  Article 
10.A.3.c.2. provides that a concurrent OER may be prepared by a different command when an 
officer is temporarily assigned away from his permanent duty station for at least sixty days, but a 
regular (or special) OER must still be prepared by the rating chain at the permanent duty station.  
Since the applicant’s rating chain at his permanent duty station (the cutter) had been disqualified, 
the substitute rating chain prepared the regular OER.  While the applicant’s record might appear 
better  if  he  had  been  issued  permanent transfer orders upon his release from restriction at the 
Xxxxx so that he would have one regular substantive OER for the evaluation period instead of a 
non-substantive regular OER and a substantive concurrent OER, the fact is that, February being 
off-season for assignments, he was issued temporary rather than permanent transfer orders and so 
                                                 
10 Germano v. United States, 26 Cl. Ct. 1446, 1460 (1992); Hary v. United States, 618 F .2d 704 (Ct. Cl. 1980); 
CGBCMR Dkt. No. 86-96. 

7. 

the  combination  of  regular  and  concurrent  OERs  in  his  record  is  correct  under  the  Personnel 
Manual.  Nor is the Board persuaded that the combination is unjust simply because it explains 
the signatures of the form by stating that the regular rating chain was disqualified.11  Therefore, 
the applicant has failed to prove by a preponderance of the evidence that either disputed OER 
was adversely affected by a “misstatement of significant hard fact,” a “clear and prejudicial vio-
lation of a statute or regulation,” or factors that “had no business being in the rating process.”12   
 
The applicant asked the Board to remove all documentation of his NJP from his 
 
record.  The Area Commander ordered that all references to the NJP be removed from his record.  
The Coast Guard appears to have followed this instruction by removing not only the usual docu-
mentation of the NJP itself—the Court Memorandum and letter of reprimand—but also the parts 
of the IO’s report that mentioned NJP.  Although the applicant argues that the NJP proceedings 
include  the  IO’s  investigation  in  its  entirety  so  that  the  entire  investigation  should  be  thrown 
away, the Board disagrees.  While the IO’s report certainly resulted in the NJP and was presuma-
bly used as evidence at the mast, as stated in Finding 5(e) above, the investigation was a pro-
ceeding unto itself with due process rights and procedures very different from those at mast.  As 
the  applicant  himself  pointed  out,  investigative  reports  are  not  even  filed  in  an  officer’s  PDR 
with the Court Memorandum of an NJP.   
 
 
Although the electronic copy of the applicant’s PDR received by the Board contains no 
references to his mast or NJP, the paper copy contains his memorandum requesting disqualifi-
cation of his rating chain as well as the Area Commander’s memorandum in response disquali-
fying  his  rating  chain.    Both  of these documents contain references to the applicant’s mast of 
January  7,  2003.    Since  on  March  24, 2003, the Area Commander ordered the removal of all 
references to the mast/NJP from the applicant’s records, the Board finds that these two memoran-
dum  should  be  removed  from  his  record  even  though  they  post-date  the  Area  Commander’s 
order. 
 

The Board notes that the record before the Board also contains the Area Commander’s 
letter overturning the NJP.  This letter does not appear in either the imaged electronic or hard 
copies of the PDR received by the Board.  However, since CGPC was able to submit an unre-
dacted version of the letter in response to the applicant’s submission of a redacted version, the 
Coast Guard or perhaps the Area Commander himself clearly retains a copy of the letter.  The 
applicant has not proved that the letter is filed in any part of his own records, but CGPC did not 
state where the letter is now filed.  The Board, therefore, will remind the Coast Guard that the 
Area  Commander’s  order  requiring  the  removal  of  references  to  the  NJP from the applicant’s 
records clearly pertains to his letter containing the order, which therefore may not be retained in 
any part of the applicant’s military records—records filed under or accessible by his name.  In 
addition, the Board will order the Coast Guard not to enter a copy of this decision in the appli-
cant’s military record.   
 

                                                 
11 See Sawyer v. United States, 18 Cl. Ct. 860, 868 (1989), rev’d on other grounds, 930 F.2d 1577 (citing Reale v. 
United  States,  208  Ct.  Cl.  1010,  1011  (1976)  (finding  that  for  purposes  of  the  BCMRs  under  10 U.S.C. § 1552, 
“injustice” is treatment by military authorities that “shocks the sense of justice”). 
12 Germano v. United States, 26 Cl. Ct. 1446, 1460 (1992); Hary v. United States, 618 F .2d 704 (Ct. Cl. 1980); 
CGBCMR Dkt. No. 86-96. 

8. 

9. 

 
The applicant asked the Board either to remove from his record the Page 7 dated 
April 11, 2003, concerning his referral to a Naval hospital for alcohol screening or to add the 
hospital’s written response to his record because he alleged that it states that he does not have a 
problem and indicates that the screening was a waste of time.  The applicant did not submit a 
copy of this letter, however, and there is none in the record so its suitability for inclusion in his 
record cannot be determined.  He alleged that the Page 7, standing by itself, falsely indicates that 
he  has  an  “alcohol  problem.”    However,  the  record  shows  that  the  applicant  got  sufficiently 
intoxicated on tequila during one port call to vomit twice in a public bar and risk his career by 
kissing a married female LTJG in front of several other crewmembers and then ten days later, 
despite counseling, risked his career again after drinking alcohol by unnecessarily sharing a bed-
room alone with the same married LTJG.  Therefore, the Board is not persuaded that the com-
mand erred or acted out of bias when it referred him for alcohol screening on April 11, 2003.  
Either  incident  could  have  been  documented  as  an  “alcohol  incident”  by  his  command  under 
Article 20.A.2.d.1. of the Personnel Manual, and any two such incidents in an officer’s record 
result in administrative separation from the Coast Guard under Article 20.B.2.h.1.  Instead, the 
command  documented  his  misconduct  as  merely  an  “alcohol-related  situation”  under  Article 
20.B.2.d. of the Personnel Manual, wisely referred him for alcohol abuse screening (the Board 
doubts that the hospital staff knew the full story of his alcohol abuse if, as he alleged, they con-
cluded that his screening was a waste of time), and prepared the required Page 7.  The only error 
the Board finds with respect to the Page 7 in the applicant’s record is that it incorrectly indicates 
that a subsequent alcohol incident might result in his separation, which would only be the case if 
he already had one alcohol incident in his record.  Since he did not, the Board finds that the text 
of  the  Page  7  should  be  corrected  by  removing  the  phrase “any further alcohol incidents may 
result in your separation from the U.S. Coast Guard.” 
 
The  applicant  asked  the  Board  to  expunge  any  administrative  actions  taken  in 
 
whole  or  in  part  because  of  the  NJP  and  the  disputed  OERs,  such  as  the  planned  Revocation 
Board; to rescind his resignation; and to offer him reinstatement on active duty.  He alleged that 
he  is  entitled  to  the  rescission of his resignation and reinstatement on active duty because his 
resignation was coerced and involuntary since CGPC illegally intended to show several enclo-
sures to the IO’s report to the Revocation Board.  He argued that CGPC’s intention in this regard 
violated  the  Area  Commander’s  order  to  expunge  the  NJP  from  his  records  and  Article 
12.A.11.b. of the Personnel Manual, which (he alleged) limits the documents to be considered by 
a Revocation Board to the officer’s PDR.  The applicant has not proved that the Coast Guard 
intended to provide the Revocation Board with any documents noting that he had been taken to 
mast and awarded NJP by his CO.  For the reasons stated in Findings 5 and 7, above, the Board 
finds  that  CGPC’s  stated  intention  to  reveal  to  the  Revocation  Board  the  disputed  OERs  and 
parts of the IO’s report that did not mention that the applicant was taken to mast or awarded NJP 
did not violate the Area Commander’s order overturning the NJP and expunging all references to 
the NJP from his records.   
 
 
In addition, the Board strongly disagrees with the applicant’s argument that Arti-
cle  12.A.11.b.  of  the  Personnel  Manual  limits  the  documents  that  a  Revocation  Board  may 
review to the officer’s PDR.  That Article does not specify the “PDR,” as many other provisions 
in the Personnel Manual do.  A search of the Personnel Manual reveals many specific references 
to an officer’s PDR and many other references referring more generally to an “officer’s record.”  
In particular, the Board notes that under regulations for “show cause” proceedings for officers 

10. 

more  senior  than  the  applicant,  Article  12.A.15.f.  states  that  “[a]t  any  time  and  place  Com-
mander, (CGPC) may convene a board of officers to review any Regular Coast Guard officer’s 
record  to  decide  whether  the  officer  should be required to show cause for retention on active 
duty.    Article  12.A.15.f.2.  states  that  “[a]  board  of  officers  convened  to  review  an  officer’s 
records  (a  “determination  board”)  shall  consist  of  at  least  three  officers  …  .”    Then  Article 
12.A.15.f.3. more explicitly states that such a board will review “the officer’s PDR, the initiating 
officer’s recommendation, and all other available information relevant to the reasons for separa-
tion to determine whether it should require the officer to show cause for retention.”  When the 
Determination Board decides that the officer must “show cause” for retention, the case is for-
warded to a Board of Inquiry, which is required, under Article 12.A.15.h.6.b.(4), to “consider an 
officer’s  record  as  a  whole  and  make  its  recommendation  based  on  a  preponderance  of  evi-
dence.”  Therefore, the Board is not persuaded that whenever the Personnel Manual refers to an 
“officer’s record,” it means only the officer’s PDR, or that such a limiting interpretation of Arti-
cle 12.A.11.b.3. is reasonable. 
 

Moreover, the Board notes that Article 12.A.11.b.1. requires the authority recommending 
the revocation to prepare and submit to CGPC a recommendation containing a variety of infor-
mation, including the reason for the recommendation and specific facts or circumstances relating 
to  the  officer’s  performance.    Nothing  prohibits  the  recommending  authority  from  including 
investigations  or  witnesses’  statements  as  part  of  his  recommendation  package,  which  is  also 
reviewed by the Revocation Board.   

 
Finally, the Coast Guard files a wide variety of significant documents about its members 
in a variety of files and databases for a variety of purposes.  To suggest that Revocation Boards 
cannot  consider  evidence  from  reports  of  investigations  into  officers’  misconduct  because  the 
Coast Guard has decided that it is not appropriate to retain such evidence (e.g., witnesses’ state-
ments) in officers’ PDRs and instead retains these reports in other filing systems is absurd.  The 
Board concludes that CGPC did not err or commit injustice when it advised the applicant that the 
Revocation  Board  would  be  entitled  to  see  certain  enclosures  to  the  IO’s  report.    He  has  not 
shown that he was subject to any illegal coercion by CGPC when he submitted his request to 
resign.13 
 
Even assuming arguendo that CGPC’s intention to submit the applicant’s and/or 
 
other witnesses’ statements to the Revocation Board was erroneous, the applicant’s resignation 
would not be rendered involuntary even though he resigned to avoid the Revocation Board and 
its possible consequences.  In Wright v. United States, 2008 U.S. Claims LEXIS 96 *1 (April 7, 
2008),  the  plaintiff  had  appealed  his  NJP  for  sending  pornography  in  emails  from  his  Coast 
Guard computer on the basis that his punishment was too harsh.  While awaiting a delayed reso-
lution of his appeal, Wright submitted a request to retire because his enlistment was ending and if 
his appeal were resolved unfavorably he might not have been allowed to reenlist or extend his 
enlistment for the four more months of service he needed to attain a twenty-year retirement.14  
The applicant’s request to retire was approved, and he was retired about one month after his NJP 

11. 

                                                 
13 See Christie v. United States,  207 Ct. Cl. 333, 337-8 (1975) (holding that a request to resign is not involuntary 
unless it is shown “(1) that one side involuntarily accepted the terms of another; (2) that circumstances permitted no 
other alternative; and (3) that said circumstances were the results of coercive acts of the opposite party”). 
14 See Final Decision in BCMR Docket No. 2007-050. 

●  ●  ● 

This court has enunciated a principle, now firmly established, for determining whether a resigna-
tion is voluntarily tendered.  The element of voluntariness is vitiated only when the resignation is 
submitted under duress brought on by Government action. …  The tripart test for such duress is: 
“(1) that one side involuntarily accepted the terms of another; (2) that circumstances permitted no 
other alternative; and (3) that said circumstances were the results of coercive acts of the opposite 
party.”  [Citations and indentation omitted.] 

… Duress is not measured by the employee’s subjective evaluation of a situation.  Rather, the test 
is an objective one. …  While it is possible plaintiff, herself, perceived no viable alternative but to 
tender  her  resignation,  the record evidence supports CSC’s finding that plaintiff chose to resign 
and accept discontinued service retirement rather than challenge the validity of her proposed dis-
charge for cause.  The fact remains, plaintiff had a choice.  She could stand pat and fight.  She 
chose not to.  Merely because plaintiff was faced with an inherently unpleasant situation in that her 
choice was arguably limited to two unpleasant alternatives does not obviate the voluntariness of 
her resignation.  [Citations omitted.] 
 
This court has repeatedly upheld the voluntariness of resignations where they were submitted to 
avoid threatened termination for cause. …  Of course, the threatened termination must be for good 
cause in order to precipitate a binding, voluntary resignation. … But this “good cause” requirement 
is met as long as plaintiff fails to show that the agency knew or believed that the proposed termi-
nation could not be substantiated.  [Citations omitted.] 
 

was overturned.  The BCMR had denied Wright’s request for constructive service credit because 
his “choice to request retirement rather than to wait for the outcome of his NJP appeal does not 
render his retirement involuntary.”15  In upholding the BCMR’s decision, the U.S. Court of Fed-
eral Claims stated, “a decision to retire is not rendered involuntary merely because the service-
member is faced with an undesirable choice.”16  In Christie v. United States,  207 Ct. Cl. 333, 
337-8 (1975), the court held the following: 
 

The “tripart test” in Christie for an involuntary resignation is still used,17 and the applicant has 
not shown that he had no alternative but to resign or that CGPC’s intention to convene a Revo-
cation  Board  was  a  coercive  act  without  “good  cause.”    In  Tippett  v.  United  States, 185 F.3d 
1250, 1255 (Fed. Cir. 1999), the court held that “[a]n otherwise voluntary resignation or request 
for discharge is rendered involuntary if it is submitted under duress or coercion, or results from 
misrepresentation  or  deception  on  the  part  of  government  officers.”  The Board finds that the 
applicant has not shown that his resignation was submitted under duress or coercion or that it 
resulted from misrepresentation or deception on the part of the Coast Guard.  Therefore, he has 
not proved by a preponderance of the evidence that his resignation was involuntary and so he is 
not entitled to have his discharge voided or to be offered reinstatement on active duty. 
 

As alternative relief, the applicant asked the Board to correct his DD 214 to show 
that  he  was  separated  for  “Miscellaneous/General  Reasons”  with  separation  code  FND  rather 
than for “Substandard Performance” with separation code BHK.  He argued that he is entitled to 
this relief because the Commandant overturned the recommendation of the DRB on this issue 
                                                 
15 Id. 
16 Wright v. United States, 2008 U.S. Claims LEXIS 96 *19 (April 7, 2008), citing Cruz v. Dep't of Navy, 934 F.2d 
1240, 1245 (Fed. Cir. 1991) (“This court has repeatedly held that the imminence of a less desirable alternative does 
not render involuntary the choice made.”).  See also Scarseth v. United States, 52 Fed. Cl. 458, 468 (2002) (citing 
Christie v. United States, 207 Ct. Cl. 333, 338 (1975), for its determination that “the exercise of an option to retire is 
not rendered involuntary by the impending prospect of a less desirable alternative”).  
17 See Scarseth v. United States, 52 Fed. Cl. 458, 468 (2002). 

12. 

without explanation.  However, the DRB panel apparently did not see any of the evidence gath-
ered by the IO.  Moreover, the BCMR is not an appellate board above the DRB and does not 
overturn DRB decisions based upon whether the DRB provided or denied due process.  Instead, 
the  BCMR  conducts  de  novo  reviews  of  the  record  and  issues its own independent decisions.  
The  applicant  argued  that  his  narrative  reason  for  separation  is  erroneous  and  unjust  because 
most of the OERs in his record contain excellent performance marks and comments.  The Board 
notes  that  CGPC  could  have  chosen  other notations, such as “Unacceptable Conduct” (BNC), 
when he resigned in lieu of further administrative separation proceedings.  The BHK denotes a 
resignation  in  lieu  of  further  proceedings  “when  a  member’s  performance  is  below  accepted 
standards.”  To find that the entries on the applicant’s DD 214 are erroneous or unjust, the Board 
would have to determine that the applicant’s performance as an officer met the Coast Guard’s 
accepted standards of performance for an officer.  Given the applicant’s behavior as revealed by 
the investigation, the Board will not do so. 

The Board has considered all of the applicant’s requests for relief and found that 
he is entitled only to the limited relief described in Findings 7 and 8 above.  The applicant made 
numerous allegations with respect to the actions of various Coast Guard officers.  Those allega-
tions not specifically addressed above are considered to be not dispositive of the case.  While the 
CO apparently conducted the mast improperly by not providing the applicant with a mast repre-
sentative and by not conducting the mitigation and extenuation phase of the mast, these errors 
were cured when the Area Commander overturned the NJP. 

Accordingly, most of the applicant’s requests should be denied but partial relief 
should be granted by removing the phrase “any further alcohol incidents may result in your sepa-
ration from the U.S. Coast Guard” from the Page 7 in his record dated April 11, 2003.   The 
Coast Guard should also remove from his record his memorandum requesting disqualification of 
his  rating  chain  and  the  xxxxxxxxxx  Commander’s  memorandum  dated  April  29,  2003,  dis-
qualifying his rating chain because both contain references to his mast.  In addition, the Board 
should remind the Coast Guard that the Area Commander’s letter with the order to remove all 
references to the NJP from the applicant’s record clearly pertains to the letter itself, which there-
fore may not be retained in any part of the applicant’s military records—i.e., records filed under 
or accessible by his name, employee identification number, or social security number. 

 
13. 

 
14. 

 

[ORDER AND SIGNATURES APPEAR ON NEXT PAGE]

 
 

The  application  of  former  xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx,  USCG,  for 

 
 
correction of his military record is granted in part as follows: 
 

ORDER 

The Coast Guard shall correct the Page 7 (CG-3307) dated April 11, 2003, in his record 
by removing the phrase “any further alcohol incidents may result in your separation from the U.S. 
Coast Guard.” 
 
 
The  Coast  Guard  shall  remove  from  his  record  his  memorandum  requesting 
disqualification of his rating chain and the xxxxxxx Commander’s memorandum dated April 29, 
2003, disqualifying his rating chain because both contain references to his mast. 
 

No copy of this decision shall be placed in his record. 

The Board also reminds the Coast Guard that the Area Commander’s letter dated March 
24, 2003, overturning the applicant’s NJP also orders the removal of “all references to the NJP 
from  [the  applicant’s]  record”  and  so  clearly  requires  the  removal  of  the  letter  itself  from  his 
military  records—i.e.,  records  filed  under  or  accessible  by  his  name,  employee  identification 
number, or social security number.  The Board orders the Coast Guard to remove the Area Com-
mander’s March 24, 2003, letter from the applicant’s military records if it has not already done 
so. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  

 
 James E. McLeod 

 
 Randall J. Kaplan 

 

 
 Bruce D. Burkley 

 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
 

 
 

 
 

 
 



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