DEPARTMENT OF TRANSPORTATION 

BOARD FOR CORRECTION OF MILITARY RECORDS 

 
Application for the Correction of 
the Coast Guard Record of: 
 
                                                                                BCMR Docket No. 2000-030 
 
 
   

 

 
 

FINAL DECISION 

 
ANDREWS, Attorney-Advisor: 
 
 
This  proceeding  was  conducted  according  to  the  provisions  of  section 
1552 of title 10 and section 425 of title 14 of the United States Code.  The BCMR 
docketed  this  case  on  December  7,  1999,  upon  receipt  of  the  applicant’s  com-
pleted application. 
 
 
appointed members who were designated to serve as the Board in this case. 
 

This  final  decision,  dated  August  17,  2000,  is  signed  by  the  three  duly 

RELIEF REQUESTED 

 
 
The applicant, a xxxxxxxxxxx on active duty in the Coast Guard Reserve,1 
asked the Board to correct his record to show that on xxxxxxxx, he was accessed 
by  the  Coast  Guard  Reserve  through  an  inter-service  transfer  from  the  Naval 
Reserve, in which he was serving as a lieutenant junior grade already selected for 
promotion to lieutenant (O-3) at the time of his accession.  He asked the Board to 
correct his grade, date of rank, and signal number in the Coast Guard Reserve 
accordingly and to award him all back pay and allowances that would be due as 
a result of the correction. 
 

APPLICANT’S ALLEGATIONS 

 
 
The applicant alleged that on November 13, 1997, while serving as a lieu-
tenant junior grade in the Naval Reserve in pay grade O-2, he requested an inter-
                                                 
1  When the applicant filed his application for correction, he was still an xxxxxxxx.  However, on 
xxxxxxxxx, he was promoted to xxxxxxxxxxxx in the Coast Guard. 

service  transfer  to  the  Coast  Guard  Reserve.    He  alleged  that  his  request  was 
approved by the Secretary of the Navy and forwarded to the Commandant of the 
Coast Guard for consideration.   
 

He  further  alleged  that,  on  January  7,  1998,  upon  the  advice  of  Coast 
Guard  recruiters,  he  also  submitted  an  application  for  a  direct  commission 
through the Maritime Academy Graduate (MARGRAD) program.  On April 14, 
1998, the Coast Guard recruiters offered him a commission as an ensign (O-1).  
The applicant stated that he accepted the offer only because he did not know that 
he could retain his date of rank and pay grade by waiting for the Coast Guard to 
approve his inter-service transfer request. 

  
The  Coast  Guard  Recruiting  Command,  he  alleged,  sent  a  letter  to  the 
Chief  of  Naval  Personnel  consenting  to  the  inter-service  transfer  on  April  20, 
1998, after he had accepted his commission through MARGRAD. 

 
The applicant further alleged that, on July 20, 1998, prior to the comple-
tion of his transfer to the Coast Guard, he was selected for promotion to lieuten-
ant, pay grade O-3, by the Navy.  He alleged that 10 U.S.C. § 716 and the Navy 
Military  Personnel  Manual  require  the  service  receiving  an  officer  through  an 
inter-service  transfer  to  place  the  officer  in  the  same  grade  he  held  in  the  first 
service and to honor any selection for promotion made by the first service prior 
to the completion of the transfer.  
 

The applicant alleged that the Coast Guard refused to honor his rank in 
the Naval Reserve (O-2) or his selection for promotion to O-3.  He argued that 
because he was an O-2 in the Naval Reserve and was selected for promotion to 
O-3 prior to the completion of the inter-service transfer, he should now be in pay 
grade O-3 in the Coast Guard, with a date of rank based on his O-2 date of rank, 
which was July 3, 1997. 
 
 
As evidence that his entry into the Coast Guard Reserve should be consid-
ered  an  inter-service  transfer,  rather  than  a  direct  commission  as  an  O-1,  the 
applicant cited the fact that there was never a break in service, he received a dis-
location allowance for a permanent change of station (PCS), and his outstanding 
leave balance was transferred from the Navy to the Coast Guard. 
 

SUMMARY OF THE RECORD 

 
 
In July 1995, the applicant graduated from xxxx Maritime Academy, was 
licensed by the Coast Guard as a third mate in the U.S. Merchant Marine, and 
was appointed an ensign in the Naval Reserve.  On July 3, 1997, the applicant 
was promoted from ensign to lieutenant junior grade in the Naval Reserve. 

 
 
On November 13, 1997, the applicant sent a letter to the Secretary of the 
Navy  requesting  an  inter-service  transfer  from  the  Naval  Reserve  to  the  Coast 
Guard  Reserve.    He  stated  that  he  believed  his  background  and  training  as  a 
merchant marine officer made him better qualified to serve in the Coast Guard, 
one of whose missions is to regulate the merchant marine.  He also tendered his 
resignation and requested “that it be accepted contingent upon final approval of 
my application for transfer to the U.S. Coast Guard Reserve and effective as of 
the  day  preceding  my  acceptance  of  an  appointment  in  the  U.S.  Coast  Guard 
Reserve.” 
 

On November 15, 1997, the applicant’s commanding officer forwarded the 

On January 7, 1998, the applicant signed an application for a direct com-

request to the Secretary of the Navy “strongly recommending approval.” 
 
 
mission in the Coast Guard Reserve through MARGRAD. 
 
 
On February 26, 1998, the Assistant Secretary of the Navy for Manpower 
and Reserve Affairs approved and forwarded the applicant’s request for an inter-
service transfer to the Commandant of the Coast Guard for consideration. 
 
 
On April 14, 1998, the Chief of the Coast Guard Operations Branch noti-
fied the applicant that the Secretary of Transportation had approved his appoint-
ment as an ensign on active duty in the Coast Guard Reserve under the MAR-
GRAD program. 
 
 
On April 16, 1998, the Coast Guard published in ALCGPERSCOM 031/98 
the results of the MARGRAD selection board that convened on March 16, 1998.  
The applicant’s name appears on the list of “primary selectees.” 
 
 
On April 20, 1998, the Director of the Coast Guard Recruiting Center sent 
the Chief of Naval Personnel a letter stating that the applicant had been selected 
for commissioning through the MARGRAD program and that his appointment 
had been approved by the Secretary.  The Director noted that his “application to 
the  Coast  Guard  contained  an  approved  inter-service  transfer  request.”    The 
Director asked that the applicant be released from all obligations to the Navy by 
xxxxxxx, so that he could enter a class for direct commission officers beginning 
on xxxxxxxxx.  A copy of the applicant’s notification dated April 14, 1998, was 
enclosed with this letter. 
 
 
separation orders, which stated the following in pertinent part: 
 

On April 21, 1998, the Chief of Naval Personnel sent the applicant official 

Your  request  to  be  transferred  to  the  USCG  submitted  in  your  letter  of  13 
Nov[ember] 1997, has been approved pursuant to the provisions of 10 U.S.C. Sec. 
716 and [the Military Personnel Manual] 3830140.  When directed by reporting 
senior, detach in Jul[y] 98. …  By direction of the President, the Secretary of the 
Navy  has  accepted  your  resignation  from  the  U.S.  Naval  Service  submitted  in 
your letter of 13 Nov[ember] 1997 … .  Records and accounts will be handled in 
accordance with [the Military Personnel Manual] 3830140.  In final endorsement 
to these orders, officer’s CO is directed to include therein information concerning 
leave as required by [the Military Personnel Manual] 3830140. 

 
The  separation  orders  also  contained  instructions  for  the  applicant’s  PCS  and 
travel to a new duty station. 
 
 
On May 4, 1998, the Commander of the Coast Guard Personnel Command 
sent the applicant orders for active duty to be effective upon his execution of an 
oath of office and acceptance of an appointment as an ensign in the Coast Guard 
Reserve.    The  orders  state  that  he  should  attend  Direct  Commission  Officer 
Indoctrination training in xxxxxxx and that the orders “constitute a permanent 
change of station from the place from which ordered to active duty to xxxxxxx.” 
 
 
On July 22, 1998, the applicant’s commanding officer wrote a letter to the 
Coast  Guard’s  Human  Resources  Services,  asking  that  his  unused  leave  in  the 
Naval  Reserve  be  credited  to  him  by  the  Coast  Guard  because  he  had  been 
assigned to sea duty and could not take the leave prior to his transfer. 
 
 
On xxxxxx, 1998, the Navy discharged the applicant.  His discharge form, 
DD 214, shows that he had performed 1 year, 1 month, and 12 days of sea service 
and that his 22.5 days of accrued leave “is requested to be carried over to USCG.”  
It also shows that he was being transferred to the Coast Guard with a narrative 
reason for separation of “interdepartmental transfer.”  
 
 
On  xxxxxxx,  1998,  the  applicant  signed  an  “Acceptance  and  Oath  of 
Office” accepting an appointment in the Coast Guard Reserve “in the grade of 
ENS/O-1 with rank as such from (date of rank) xxxxxx.”  The following day, he 
signed an active duty agreement that showed his rank as ensign. 
 
 
On  November  25,  1998,  the  Secretary  of  the  Navy  issued  a  bulletin 
(ALNAV 094/98) with the results of the lieutenant (O-3) selection board that met 
in July 1998.  The list shows that the applicant was selected for promotion in the 
Naval Reserve prior to his accession by the Coast Guard Reserve. 
 
 
The  applicant  filed  his  application  for  correction  with  the  BCMR  on 
December 7, 1999.  In it, he included a supporting letter from his commanding 
officer (CO) dated November 24, 1999.  The CO outlined the facts and stated that 

although  the  Coast  Guard  accessed  the  applicant  through  MARGRAD,  “all 
requirements  for  an  interservice  transfer  appear  to  have  been  met.”    The  CO 
stated that the Board should determine which of the accession applications took 
precedence  and  whether  an  inter-service  transfer  actually  took  place.    The  CO 
stated that the lack of a break in active duty service, the applicant’s receipt of a 
dislocation  allowance  for  a  PCS,  and  the  transfer  of  his  leave  balance  indicate 
that an inter-service transfer did, in fact, occur. 
 

On December 3, 1999, and again on February 15, 2000, the Commander of 
the Coast Guard Personnel Command responded to inquiries by a United States 
Senator  on the  applicant’s  behalf.    In  both letters,  he  denied that  the  applicant 
had ever applied for an inter-service transfer. 
 
On February 3, 2000, the Commander of the Navy Personnel Command 
 
wrote a letter to the Chairman of the BCMR stating that, based on the April 20, 
1998, letter from the Director of the Coast Guard Recruiting Center, which refer-
enced the applicant’s November 13, 1997, inter-service transfer request, the Navy 
had  issued  him  “inter-service  transfer  orders.”    He  alleged  that  the  applicant 
“was released to service in the U.S. Coast Guard based on the consent of both 
services  to  an  interservice  transfer.”    He  also  stated  that  the  applicant  did  not 
submit “an unqualified resignation through this office.” 
 

VIEWS OF THE COAST GUARD 

On  June  19,  2000,  the  Chief  Counsel  of  the  Coast  Guard  submitted  an 

 
 
advisory opinion recommending that the Board deny the applicant’s request.  
 
 
The Chief Counsel alleged that after the applicant submitted a request to 
the Navy for an inter-service transfer to the Coast Guard, he was properly coun-
seled by a Coast Guard recruiter about the low acceptance rate of requests for 
inter-service transfers.  Because of the low rate, the Chief Counsel alleged, he was 
counseled that his chance of receiving a commission in the Coast Guard “would 
be greatly increased if he applied for accession under the MARGRAD program.”  
The  Chief  Counsel  further  alleged that  accession  through  the MARGRAD  pro-
gram  gave  the  applicant  his  best  chance  at  having  a  long  career  in  the  Coast 
Guard.    He  alleged  that  if  the  applicant  had  been  accessed  as  an  O-2  or  O-3 
through  an  inter-service  transfer  or  the  MARGRAD  program,  he  might  have 
been  “at  considerable risk  for  non-selection for  promotion  before his  first  ‘best 
qualified’ selection board” because his officer evaluations from the Navy would 
not  have  been  considered  by  the  selection  board.    Moreover,  he  alleged,  the 
applicant did not meet the criteria for accession as an O-2 through MARGRAD, 
which  include  at  least  one  year  of  creditable  sea  service.    The  Chief  Counsel 

stated that the applicant had served only nine months aboard the USS xxx at the 
time his application was reviewed by the MARGRAD selection board. 
 
The  Chief  Counsel  argued  that,  after  the  applicant  offered  to  accept  a 
 
commission  in  the  Coast  Guard  through  either  an  inter-service  transfer  or  the 
Direct  Commission  MARGRAD  program,  the  Coast  Guard  was  free  to  accept 
either of the applicant’s two offers, even though the record reflects that he was 
qualified for an inter-service transfer.  He alleged that the Coast Guard “chose to 
access Applicant through the MARGRAD program” and “chose not to accept the 
Applicant  for  an  inter-service  transfer,  and  never  forwarded  the application  to 
the  Secretary  of  Transportation.”    The  Chief  Counsel  further  alleged  that  the 
Coast  Guard’s  failure  to  inform  the  applicant  of  his  non-selection  for  an  inter-
service  transfer  was  not  an  error  because  the  Coast  Guard  “is  not  required  to 
notify an applicant who is not selected for an inter-service transfer.” 
 
 
The Chief Counsel alleged that there was never any contractual agreement 
for an inter-service transfer.  Instead, he alleged, the Coast Guard and the appli-
cant entered a valid contract for his direct commission as an ensign through the 
MARGRAD program.  The terms of the contract, he argued, should be “deter-
mined by the objective manifestations of the parties, rather than their subjective 
intent.”  He argued that the significant objective manifestations of the terms of 
the  applicant’s  contract  are  the  oath  of  office  and  active  duty  agreement  he 
signed, both of which show that his rank in the Coast Guard Reserve was to be 
ensign. 
 
 
The Chief Counsel also argued that the applicant has not presented evi-
dence that “overcome[s] the presumption that Coast Guard officials carried out 
their  duties  correctly,  lawfully,  and  in  good  faith,”  nor  shown  that  the  Coast 
Guard  committed  any  “error or  injustice  entitling  him  to  the requested  relief.”  
He  stated  that  any  determination  by  the  Board  that  the  Coast  Guard  was 
required  to  accept  one  of  the  applicant’s  offers  (inter-service  transfer)  over  the 
other  (direct  commission  through  the  MARGRAD  program)  would  have  “the 
potential to effect significant issues of Coast Guard policy.” 
 
 
The Chief Counsel argued that “the Navy’s action in characterizing Appli-
cant’s case as an inter-service transfer has no effect on the Coast Guard’s valid 
and enforceable contract to access Applicant through the MARGRAD program.” 
The Navy “was never a party to any contract between Applicant and the Coast 
Guard”  and  that  the  Navy’s  release  of  the  applicant  “was  merely  a  condition 
precedent  to  the  separate  and  independent  contractual  arrangement  between 
Applicant  and  the  Coast  Guard.”    Thus,  he  argued,  even  if  the  Navy  released 
him  under  the  perception  that  the  applicant  was  joining  the  Coast  Guard 
through an inter-service transfer, that misperception is “of no legal moment to 

this case.”  In a memorandum attached to the Chief Counsel’s advisory opinion, 
the Commander of the Coast Guard Personnel Command stated that the Navy 
may  have  referred  to  an  inter-service  transfer  in  the  applicant’s  “detachment 
orders” because it had approved his request for an inter-service transfer but was 
unaware of his application for a direct commission through the MARGRAD pro-
gram. 
 
 
Finally,  the  Chief  Counsel  argued  that  although  the  Coast  Guard  “con-
ferred certain [benefits] normally associated with inter-service transfer arrange-
ments, such benefits did not dictate or otherwise govern the terms of Applicant’s 
MARGRAD program contract with the Coast Guard.”  He argued that the dislo-
cation allowance for a PCS and the transfer of the applicant’s leave balance were 
collateral to the contract and did not change the nature and terms of the contract.  
 
 
The Chief Counsel attached to his advisory opinion an affidavit signed on 
April 12, 2000, by a lieutenant commander who served in the Officer Personnel 
Management (OPM) Division of the Coast Guard Personnel Command from July 
1996 to May 1999.   He stated that his duties included management of the Inter-
Service Transfer (IST) program and that he processed each request for an inter-
service transfer.  He stated that he believes he spoke with the applicant on the 
telephone at least once, although he cannot remember the date.  He alleged that 
he remembers the following about that conversation:   
 

APPLICANT’S RESPONSE TO THE VIEWS OF THE COAST GUARD 

 
 
On June 20, 2000, the BCMR sent the applicant a copy of the Chief Coun-
sel’s  advisory  opinion  and  invited  him  to  respond  within  15  days.    On  July  3, 
2000, the applicant responded. 
 
 
The applicant alleged that the Coast Guard erred and committed an injus-
tice  when  it  refused  to  abide  by  the  policies  for  inter-service  transfers  even 

We discussed the IST process, as well as the likelihood of approval.  Generally, 
IST  to  the  Coast  Guard  was  not  encouraged.    The  primary  reason  for  this  was 
that  most  of  the  other  services’  experience  fields  (MOS)  did  not  correlate  with 
Coast  Guard  specialties.    Therefore,  it  was  difficult  to  place  them  at  a  Coast 
Guard  unit.    When  [the  applicant]  indicated  he  was  also  applying  for  a  direct 
commission, I recall specifying that the “Direct Commission” program would be 
his best chance to obtain a Coast Guard commission.  

 
The  lieutenant  commander  also  stated  that  “during  my  assignment  [at 
 
OPM from July 1996 to May 1999], only one request for IST was approved.  That 
person was a  Naval Officer (female aviator) who had previously served in the 
Coast Guard as a Coast Guard aviator.” 
 

though it was aware that this was the purpose for which the Navy was releasing 
him.  Moreover, the applicant alleged, under COMDTINST 1131.23, he was not 
qualified for the MARGRAD program because when he applied in January 1998 
he did not have an approved release date from the Navy, which is a requirement 
for  application  to  the  program.    He  alleged  that  the  Navy’s  statement  that  he 
would  be  released  upon  appointment  in  the  Coast  Guard  did  not  fulfill  the 
requirement for applying to the MARGRAD program although it was sufficient 
for an inter-service transfer.   
 
 
The applicant also alleged that COMDTINST 1131.21 requires selectees for 
a direct commission who are on active duty in another service to be discharged 
from  that  service  at  least  two  days  before  being  commissioned  in  the  Coast 
Guard. He alleged that the two-day break is required “to ensure that all dates of 
rank,  service  entitlements  and  precedence  begin  anew  upon  commissioning  in 
the Coast Guard.”  Because he had no such break in service, he argued, his acces-
sion must be considered an inter-service transfer.  
 
 
The applicant argued that he never submitted an unqualified resignation 
to the Navy.  His resignation dated November 13, 1997, was premised upon the 
consent of both services that he receive an inter-service transfer.  Therefore, he 
argued, the only legal way he could have been accessed to the Coast Guard was 
by  inter-service  transfer.    He  argued  that  the  inter-service  transfer  orders  he 
received from the Navy were not based on an erroneous assumption but “on the 
Coast Guard’s communications with the Chief of Naval Personnel.”  The Coast 
Guard’s letter to the Chief of Naval Personnel, he argued, clearly indicates the 
existence of an approved inter-service transfer request, although the Chief Coun-
sel  denied  that  his  request  had  ever  been  approved.    Moreover,  he  stated,  the 
Coast Guard received copies of both his inter-service transfer orders and his DD 
214 at the time of his transfer but never questioned or contested them. 
 
 
The applicant also alleged that the absence of a written contractual agree-
ment for an inter-service transfer between him and the Coast Guard is irrelevant 
because  “interservice  transfer  regulations  do  not  require  written  contracts 
between the two services as [the Coast Guard] would like to lead the Board to 
believe.”  
 
 
The applicant alleged that the benefits he received upon his commission-
ing in the Coast Guard are not collateral to a contract but evidence that he was 
accessed  by  inter-service  transfer.    He  alleged  that  he  received  a  dislocation 
allowance  for  his  moving  expenses2  and  that,  under  Chapter  5,  U5630,  of  the 
                                                 
2    The  applicant  submitted  a  copy  of  his  travel  voucher,  which  indicates  that  the  Coast  Guard 
paid him a dislocation allowance of $1,260.59. 

Joint  Forces  Travel  Regulations  (JFTR),  only  officers  executing  an  inter-service 
transfer are entitled to a dislocation allowance.  He alleged that the transfer of his 
leave balance from the Navy to the Coast Guard is also evidence that he executed 
an inter-service transfer under Article 12.A.3. of the Personnel Manual.  
 
 
The applicant alleged that the Coast Guard itself treated his application to 
MARGRAD and his request for inter-service transfer as one “offer,” rather than 
two separate offers, because the Coast Guard put a copy of his “approved inter-
service  transfer  request”  in  his  application  to  MARGRAD  and  referred  to  it  in 
communications  with  the  Navy  concerning  his  transfer.    He  alleged  that  the 
Coast Guard’s confusion of the circumstances surrounding his transfer is shown 
by the two letters from the Commander of the Personnel Command to the Sena-
tor denying that he had ever applied for an inter-service transfer. 
 
 
The applicant denied ever having spoken with the lieutenant commander 
at OPM.  He alleged that he never spoke with anyone at OPM but “dealt exclu-
sively  with  the  Coast  Guard  Recruiting  Command  (CGRC)  in  Washington  DC 
and  their  local  office  in  xxxxxx.”    In  addition,  he  stated  he  was  never  told  by 
anyone  that  the  Coast  Guard  “would  not  entertain  my  interservice  transfer 
request.” 
 
 
The applicant strongly disputed the Chief Counsel’s argument that acces-
sion through the MARGRAD program was in his best interest.  He did not lack 
relevant  experience  because  prior  to  joining  the  Navy,  he  had  “worked  in  the 
marine industry for such entities as xxxxxx Corporation and the US Army Corps 
of Engineers in both an afloat and shoreside capacity.”  He alleged that at his last 
Coast Guard duty station, a marine safety office, he was the only junior officer 
with  experience  in  the  merchant  marine  and  was  put  in  the  “precarious  and 
sometimes  uncomfortable  position  of  being  responsible  for  training  officers  to 
whom  I  was  junior  in  rank.”    Moreover,  he  stated,  if  he  had  been  properly 
accessed  as  an  O-2  already  selected  for  promotion  to  O-3,  he  would  have 
received  seven  years’  worth  of  officer  evaluations  before  he  would  have  been 
considered for selection to lieutenant commander.  Seven years, he alleged, “is 
more than sufficient time to establish a career track and competitive performance 
record.” 
 
 
The applicant also stated that, contrary to the Chief Counsel’s allegation, 
he did meet the qualifications for accession as an O-2 through the MARGRAD 
program.  At the time he was commissioned, he had more than one year of sea 
duty, as required by regulation.  Therefore, he stated that even if the Board con-
siders his accession through direct commission to have been legal, it should still 
correct his record to show that he was commissioned as an O-2. 
 

 
Finally, the applicant  stated that he only accepted his commission as an 
ensign  because  he  was  unaware  that  he  could  retain  his  rank  and  pay  grade 
through an inter-service transfer.  He alleged that the Coast Guard either inten-
tionally  or  unintentionally  misled  him  into  believing  that  he  had  to  accept  the 
demotion  in  order  to  transfer  to  the  Coast  Guard.    The  regulations  the  Coast 
Guard violated in accessing him through the MARGRAD program, rather than 
through inter-service transfer, “are in effect to protect not only the service, but 
the member as well.”  He argued that the Coast Guard, in effect, used the inter-
service transfer process to procure his release from the Navy, switched to treat-
ing  his  accession  as  a  direct  commission  to  save  money  by  demoting  him  to 
ensign,  but  then  “returned  to  recognizing  me  as  an  interservice  transfer”  by 
awarding him the benefits of an officer accessed through inter-service transfer. 
 

APPLICABLE LAWS 

 
Laws Concerning Inter-Service Transfer 
 
 
 

Title 10 U.S.C. § 716 states the following: 

(a) 
Notwithstanding  any  other  provision  of  law,  the  President,  within 
authorized strengths and with the consent of the officer involved, may transfer 
any commissioned officer of a uniformed service from his uniformed service to, 
and  appoint  him  in,  another  uniformed  service.    The  Secretary  of  Defense,  the 
Secretary  of  Transportation,  the  Secretary  of  Commerce,  and  the  Secretary  of 
Health and  Human Services shall jointly establish, by regulations approved  by 
the President, policies and procedures for such transfers and appointments. 
 
(b) 
or relative rank higher than that which he held on the day before the transfer. 

An officer transferred under this section may not be assigned precedence 

 
 
Department of Defense Directive 1300.4, entitled “Inter-Service Transfer of 
Commissioned Officers,” was issued on November 15, 1996, and applies to the 
Coast  Guard  “by  agreement  with  the  Department  of  Transportation.”    In  the 
directive, the terms “military service” and “military department” do not apply to 
the  Coast  Guard  unless  it  is  operating  under  the  Navy.    The  Coast  Guard  is 
included  in  the  term  “uniformed  services.”    Paragraph  3.3.1.  of  the  directive 
states the following: 
 

Except for commissioned officers in the [Public Health Service], a commissioned 
officer transferred under this Directive shall continue to hold the same grade and 
date of rank held in the losing Uniformed Service.  The officer shall be placed on 
the active duty list of the gaining Uniformed Service in accordance with regula-
tions prescribed by the gaining Uniformed Service. … 

 
 
 

Paragraph 3.3.5. states the following: 

If a commissioned officer transferred between two Military Services is on a pro-
motion list to the next higher grade under [10 U.S.C. § 624], the Secretary of the 
Military Department concerned may integrate the officer into the promotion list 
of the gaining Military Service based on the  officer’s  date of rank in his or  her 
current grade in the losing Military Service. 

Paragraph 3.6. states the following: 

If  the  request  for  transfer  has  received  final  approval,  termination  of  current 
commission  and  reappointment  in  the  gaining  Uniformed  Service  shall  be 
accomplished by the Military Departments concerned without interruption of the 
continuity  of  the  officer’s  total  service.    Commissioned  officers  so  transferred 
shall be credited with the total amount of unused leave and service as of the date 
before such transfer. 

 
 
 

   
Part 1 of Chapter 25 of the Navy Military Personnel Manual (MILPERS-
 
MAN  1300-080)  governs  inter-service  transfers  of  officers  out  of  the  Navy.    It 
provides  that  officers  transferred  out  of  the  Navy  under  10  U.S.C.  § 716  “will 
continue to hold the same grade and date of rank held in the losing Uniformed 
Service.”  It specified that a “Reserve Naval officer on active duty … transferred 
out of the Navy under this map is awarded a permanent Reserve grade and the 
date  of  rank  as  determined  by  applying  the  amount  of  service  accrued  in  the 
Navy to the appointment laws then in effect for the gaining Uniformed Service.  
The officer is placed on the active duty list following regulations of the gaining 
service.”    Preservation  of  a  transferring  officer’s  status  on  a  promotion  list  is 
required  only  when  the  gaining  service  is  a  “Military  Service.”    Officers  being 
transferred  to  a  “Uniformed  Service”  are  credited  with  all  unused  leave.    The 
manual also requires an application for an inter-service transfer to contain a res-
ignation that is “contingent upon final approval of [the officer’s] application for 
transfer  to  the  (specify  service)  and  effective  as  of  the  day  preceding  [the  offi-
cer’s] acceptance of an appointment in the (specify service).”   
 
 
The Coast Guard has no regulations or written procedures for processing 
inter-service  transfer  requests  from  officers  in  other  services  seeking  commis-
sions in the Coast Guard.3  Article 12.A.3. of the Personnel Manual, which was 
cited by the applicant, governs the release of Coast Guard officers to other serv-
ices by inter-service transfer.  It does not govern the accession of other services’ 
officers by the Coast Guard.  It states that an officer transferring out of the Coast 
Guard will receive a  grade, date of rank, and position on the gaining service’s 

                                                 
3  The lack of written provisions was verified by the BCMR in a telephone call to the officer in 
charge  of  processing  inter-service  transfer  requests  in  the  Officer  Personnel  Management  Divi-
sion  of  the  Coast  Guard  Personnel  Command.    The  officer  also  stated  that  the  Coast  Guard 
receives and approves very few inter-service transfer requests from officers of other services. 
 

(1) 
A member of the … Coast Guard … who has accrued leave to his credit 
at the time  of his discharge, is entitled to be paid in  cash or by a check on the 
Treasurer  of  the  United  States  for  such  leave  on  the  basis  of  the  basic  pay  to 
which he was entitled on the date of discharge. 
 
(2)  Payment  may  not  be  made  under  this  subsection  to  a  member  who  is  dis-
charged  for  the  purpose  of  accepting  an  appointment  or  a  warrant  in  any  uni-
formed service. 
 
(3) Payment may not be made to a member for any leave he elects to have carried 
over to a new enlistment in any uniformed service on the day after the date of his 
discharge; but payment may be made to a member for any leave he elects not to 
carry over to a new enlistment. … 
 
(4)  A  member  to  whom  a  payment  may  not  be  made  under  this  subsection  … 
carries the accrued leave standing to his credit from the one status to the other 
within any uniformed service. 

 
Laws Concerning Payment of Dislocation Allowances 
 
 
to military members, provides the following: 
 

Title 37 U.S.C. § 407, which governs the payment of dislocation allowances 

active  duty  promotion  list  in  accordance  with  the  officer’s grade, date  of rank, 
and position on the Coast Guard’s promotion list. 
 
Laws Concerning the Transfer of Accrued Leave 
 

Title 37 U.S.C. § 501(b) provides the following: 

 

(2) 

 

Eligibility for primary dislocation allowance.   
(1) 

(a) 
  
Under  regulations  prescribed  by  the  Secretary  concerned,  a 
member  of  a  uniformed  service  described  in  paragraph  (2)  is  entitled  to  a  pri-
mary  dislocation  allowance  at  the  rate  determined  under  subsection  (c)  for  the 
member's pay grade and dependency status. 
    
is any of the following: 
       
A  member  who  makes  a  change  of  permanent  station 
and the member's dependents actually make an authorized move in connection 
with the change, … 
(D) 

A member of the uniformed services referred to in paragraph (1) 

(A) 

A member who is without dependents and-- 
(i) 

actually  moves  to  a  new  permanent  station 
where  the  member  is  not  assigned  to  quarters  of  the  United 
States; or 

(ii) actually  moves from a  place of residence under cir-

cumstances described in section 406a of this title. 

•  •  • 

 (e) 
First or last duty.  A member is not entitled to payment of a dislocation 
allowance  under  this  section  when  the  member  is  ordered  from  the  member's 

home to the member's first duty station or from the member's last duty station to 
the member's home. 
  
(f) 
Rule  of  construction.    For  purposes  of  this  section,  a  member  whose 
dependents may not make an authorized move in connection with a change of 
permanent station is considered a member without dependents. 

 
 
Chapter  5  of  the  Joint  Federal  Travel  Regulations  (JFTR)  governs  travel 
allowances for permanent duty travel, which is defined as travel from one duty 
station to another or travel from home or the place from which ordered to active 
duty  to  the  member’s  first  duty  station.    JFTR,  U5000(B).    Part  G  of  Chapter  5 
governs payment of a dislocation allowance “to partially reimburse a member for 
the  expenses  incurred  in  relocating  the  member’s  household.”    Members  with 
dependents (such as the applicant) are normally entitled to a dislocation allow-
ance  when  relocating  in  connection  with  a  PCS.    JFTR,  U5610(A).    However, 
members with PCS orders from home or the “place from which ordered to active 
duty” to the member’s “first duty station” are not entitled to a dislocation allow-
ance.  JFTR, U5630(C).  In addition, a member who moves from the last duty sta-
tion of one period of service to the first duty station of another period of service 
is  not  entitled  to  a  dislocation  allowance  if  the  member  did  not  receive  PCS 
orders for the move.  JFTR, U5630(C).  A member “transferred with no break in 
service from one Service to another under the authority of 10 U.S.C. § 716 or any 
similar  statutory  provision  …  is  entitled  to  [a  dislocation  allowance]  when  the 
household  is  relocated  incident  to  an  ordered  PCS  resulting  from  a  change  of 
service.” JFTR, U5630(B). 
 
Laws Concerning the Direct Commission of Maritime Academy Graduates 
 
 
Commandant  Instruction  1131.23  contains  the  regulations  for  the  Coast 
Guard’s  direct  commission  program  for  maritime  academy  graduates  (MAR-
GRAD).4  Paragraph 4.e. of the instruction contains the following provisions: 
 

(1) 
All selectees who currently hold regular or reserve commissions and are 
serving  on active duty must be discharged from the  losing  service at least two 
calendar days before being administered the oath for commissioning in the Coast 
Guard Reserve.  …  This is necessary to ensure that active duty entitlements and 
service precedence begin anew upon commissioning in the Coast Guard Reserve. 
 

                                                 
4    The  Coast  Guard  also  has  a  direct  commission  program  for  officers  of  the  U.S.  Merchant 
Marine.  Licensed second mates, first class pilots, and second assistant engineers with at least two 
years of sea service may be appointed to the rank of lieutenant junior grade.  Personnel Manual, 
Article 1.A.5.c.  With just one year of sea service and a license as a third mate, the applicant did 
not qualify for this program.  Moreover, officers on active duty in other military services may not 
apply under this program. 

Applicants on active duty in another service may not apply unless such 
(2) 
application  includes  a  statement  from  the  losing  service  to  the  extent  that  the 
applicant has an approved release date, or has no service obligation remaining 
and  is  eligible  to  resign,  or  that  any  remaining  service  obligation  would  be 
waived to allow resignation in time for an appointment to the Coast Guard.  A 
statement  that  the  member  will  be  released  upon  appointment  is  not  adequate 
for meeting this prerequisite.  Clearance from the losing service, and provision of 
proof of such clearance, is the sole responsibility of the selectee.  Selectee will not 
be appointed until such proof is provided. 

 
 
Paragraph 6 of the instruction concerns the direct commissioning of state 
and federal maritime academy graduates.  Paragraph 6.a. states that the officer’s 
“date  of  rank  shall  be  the  date  of  appointment  to  commissioned  status  in  the 
Coast  Guard  Reserve.”    Paragraph  6.c.(3)(b)  states  that  to  be  appointed  at  the 
rank  of  lieutenant  junior  grade,  rather  than  ensign,  an  applicant  “must  have 
served 1 or more years, as of commissioning date, on board vessels of the United 
States in the capacity of a licensed officer.  Credit for up to 1 year may be given 
for service on board vessels considered equivalent to merchant vessels … .” 
 
Laws Concerning Service Precedence and Date of Rank 
 
Article  2.A.4.a.  of  the  Personnel  Manual  states  that  “[u]pon  original 
 
appointment in the Coast Guard, the date of rank of a commissioned officer or 
chief  warrant  officer  shall  be  the  date  specified  in  the  appointment  letter,  or  if 
there be no specified date, then the date the oath of office is taken.”   
 

Article  5-A-2.d.  of  the  Coast  Guard  Personnel  Manual  provides  “[a] 
Reserve officer … shall, when entering on extended active duty, be placed on the 
active duty promotion list in accordance with grade and seniority.” 
 
 
Title 14 U.S.C. § 727 provides that “[u]nder regulations prescribed by the 
Secretary,  a  person,  appointed  as  a  Reserve  officer,  may  be  assigned  a  date  of 
rank and precedence which reflects that person’s experience, education, or other 
qualifications.”  
 
 
Title 14 U.S.C. § 744 provides that a “former officer of the Regular Navy or 
Coast Guard who applies for a Reserve commission within one year of resigning 
the officer’s Regular commission, and who is appointed in the same grade previ-
ously held in the Regular Navy or Coast Guard, shall be given the same date of 
rank in that grade as that previously assigned to the officer while a member of 
the Regular Navy or Coast Guard.” 
 

 

FINDINGS AND CONCLUSIONS 

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

The Board has jurisdiction concerning this matter pursuant to sec-

tion 1552 of title 10 of the United States Code.  The application was timely. 
 

1. 

2. 

3. 

The  applicant  requested  an  oral  hearing  before  the  Board.    The 
Chairman,  acting  pursuant  to  33  C.F.R.  § 52.31,  denied  the  request  and  recom-
mended  disposition  of  the  case  without  a  hearing.    The  Board  concurs  in  that 
recommendation. 
 
 
Upon the advice of Coast Guard recruiters, the applicant sought a 
commission  with  the  Coast  Guard  Reserve  through  the  Direct  Commission 
MARGRAD program as well as by inter-service transfer.  Although the applicant 
may have been qualified for an inter-service transfer, he has not proved that his 
recruiters  committed  any  error  or  injustice  or  acted  in  bad  faith  when  they 
advised  him  that  he  had  a  better  chance  of  being  accepted  through  the  MAR-
GRAD  program.    The  sworn  statement  of  the  officer  in  charge  of  inter-service 
transfers at the time indicates that the Coast Guard accepts very few inter-service 
transfers.  In addition, the applicant has not proved by a preponderance of the 
evidence that his recruiters improperly advised him with respect to the advan-
tages and disadvantages of the two avenues to a commission in the Coast Guard 
Reserve. 
 
 
The applicant submitted his MARGRAD application on January 7, 
1998.    His  request  for  an  inter-service  transfer  did  not  reach  the  Coast  Guard 
until after February 26, 1998, when it was approved by the Navy.  A copy of that 
request was apparently included in his MARGRAD application when it was con-
sidered by the direct commission selection board on March 16, 1998.  The appli-
cant has not proved by a preponderance of  the evidence that the  Coast Guard 
committed  any  error  or  injustice  with  respect  to  his  acceptance  through  the 
MARGRAD program.  There is no evidence in the record that the Coast Guard 
erred or acted in bad faith in the processing of his inter-service transfer request. 
 
 
The applicant alleged  that the Coast Guard actually accessed him 
by  inter-service  transfer.    However,  all  of  the  Coast  Guard’s  communications 
with the applicant submitted for the record—including his notification letter, his 
PCS orders, his oath of office, and his active duty agreement—indicate that he 
was offered and he accepted a direct commission in the Coast Guard Reserve as 
an ensign through the MARGRAD program.  There is no evidence that the Coast 
Guard ever promised him that he would be accessed by inter-service transfer or 
that he would retain his prior rank and service precedence. 

4. 

5. 

6. 

(a) 

 
 
The applicant alleged that, despite his acceptance of a direct com-
mission as an ensign, his accession by the Coast Guard Reserve must be consid-
ered  an  inter-service  transfer  because  (a)  there  was  no  break  in  service;  (b)  his 
unused leave balance was transferred from the Navy to the Coast Guard; (c) the 
Coast Guard issued him orders on May 4, 1998, characterizing his transfer as a 
PCS and paid him a  dislocation allowance; (d) his MARGRAD application did 
not  contain  a  statement  from  the  Navy  indicating  a  definite  release  date  as 
required  by  Paragraph  4.e.(2)  of  COMDTINST  1131.23;  (e) his  resignation  from 
the  Navy  was  contingent  upon  the  final  approval  of  his  inter-service  transfer 
request; (f) the Coast Guard’s letter to the Chief of Naval Personnel dated April 
20, 1998, mentioned that there was an “approved inter-service transfer request” 
in his MARGRAD application; and (g) the separation orders and DD 214 issued 
by  the  Navy  indicate  that  the  Navy  thought  the  Coast  Guard  Reserve  was 
accessing him by inter-service transfer.  For the reasons stated below, the appli-
cant’s  argument  that  these  facts—considered  either  singly  or  cumulatively  —
prove that he was accessed by inter-service transfer is rejected by the Board: 
 
 
Paragraph  4.e.(1)  of  COMDTINST  1131.23  clearly  requires 
selectees for a direct commission serving on active duty in another service to be 
discharged  from  the  losing  service  at  least  two  days  before  taking  the  oath  of 
office in the Coast Guard Reserve.  The applicant was discharged from the Naval 
Reserve the day before he took the oath of office for the Coast Guard Reserve.  
The regulation indicates that the lack of a break in service may entitle an officer 
entering under the MARGRAD program to the continuation of active duty enti-
tlements, such as annual leave, and service precedence.  It does not state that the 
lack of a break in service causes the officer’s accession to become an inter-service 
transfer under 10 U.S.C. § 716.  The Board finds that the lack of a break in service 
between the applicant’s discharge by the Naval Reserve and appointment by the 
Coast  Guard  Reserve  proves  only  that  the  Coast  Guard  failed  to  comply  with 
Paragraph 4.e.(1) of COMDTINST 1131.23.  The error did not harm the applicant 
and is not evidence that the Coast Guard ever approved the applicant’s request 
for an inter-service transfer. 
 
 
(b)  Under 37 U.S.C. § 501(b), the applicant was entitled to carry 
over  his  accrued  leave  from  the  Naval  Reserve  to  the  Coast  Guard  Reserve 
whether  his  accession  was  through  inter-service  transfer  or  through  the  MAR-
GRAD program.  Therefore, the transfer of  his unused leave balance from one 
service to the other is not evidence of the nature of his accession.  
 
All members ordered to travel to a new permanent duty sta-
 
tion receive PCS orders, whether they are required to travel from a previous duty 
station,  from  home,  or  from  “the  place  from  which  ordered  to  active  duty.”  

(c) 

 

 

 

Therefore,  the  characterization  of  the  applicant’s  orders  as  PCS  orders  is  not 
determinative of the nature of his accession.   
 

On May 4, 1998, the Coast Guard issued the applicant PCS 
orders “from the place from which ordered to active duty to xxxxxxx.”  Members 
with  PCS  orders  requiring  travel  “from  the  place  from  which  called  to  active 
duty” to a “first duty station” are not entitled to a dislocation allowance.  JFTR, 
U5630(C).    The  term  “first  duty  station”  is  not  defined  in  the  JFTR,  and  it  is 
unclear  whether  the  applicant’s  first  duty  station  in  the  Coast  Guard  Reserve 
constituted a “first duty station” for the purposes of this regulation.  In addition, 
the same regulation provides that a member who moves from the last duty sta-
tion of one period of service to the first duty station of another period of service 
is  not  entitled  to  a  dislocation  allowance  if  the  member  did  not  receive  PCS 
orders  for  the  move.    This  statement  strongly  implies  that  a  member  in  this 
situation  who  does  receive  PCS  orders  may  be  entitled  to  a  dislocation  allow-
ance.  Thus, it is not clear to the Board that the applicant could only have been 
entitled  to  a  dislocation  allowance  if  he  were  being  accessed  by  inter-service 
transfer under 10 U.S.C. § 716 and JFTR, U5630(B).  The Board is  therefore not 
convinced  that  the  payment  of  the  dislocation  allowance  constitutes  evidence 
that  the  applicant  was  accessed  by  the  Coast  Guard  Reserve  by  inter-service 
transfer rather than through the MARGRAD program. 

 
 
The Board finds that the February 26, 1998, approval of the 
applicant’s request for an inter-service transfer by the Assistant Secretary of the 
Navy  for  Manpower  and  Reserve  Affairs,  which  the  applicant’s  recruiters 
included in his MARGRAD application, met the requirement of Paragraph 4.e.(2) 
of COMDTINST 1131.23 that each application contain “a statement from the los-
ing  service  to  the  extent  that  …  any  remaining  service  obligation  would  be 
waived to allow resignation in time for an appointment to the Coast Guard.”  
 
 
Although the applicant’s resignation in his request for inter-
service transfer was contingent upon the approval of his request, the applicant 
had  in  fact  been  discharged  from the  Naval  Reserve  when  he took  the  oath  of 
office for the Coast Guard Reserve.  The Coast Guard did not err or commit any 
injustice in administering the oath of office to the applicant after he had been dis-
charged from the Naval Reserve. 
 
 
The  April  20,  1998,  letter  from  the  Director  of  the  Coast 
Guard Recruiting Center to the Chief of U.S. Naval Personnel clearly states that 
the applicant had been selected for commissioning under the Direct Commission 
MARGRAD program.  In the context of the letter, the reference to an “approved 
inter-service  transfer  request”  clearly  means  “approved”  by  the  Navy,  not  the 

(d) 

 

 

 

(e) 

(f) 

 

(g) 

Coast  Guard,  and  does  not  imply  that  the  Coast  Guard  had  approved  the 
request. 
 
The  Board  does  not  agree  with  the  Chief  Counsel  that  the 
 
Navy’s apparent misunderstanding of the nature of the applicant’s accession by 
the Coast Guard is “of no legal moment” because the Navy “was never a party to 
any  contract  between  Applicant  and  the  Coast  Guard.”    Every  service  has  an 
inherent  interest  in  ensuring  that  its  officers  are  treated  fairly  and  accorded 
proper respect by other services.  Part 1 of Chapter 25 of the Navy Military Per-
sonnel  Manual  clearly  indicates  that  the  Navy  expects  officers  transferred  to 
other services to be commissioned in the same rank they held in the Navy.  To 
characterize  the  Navy’s  release  of  the  applicant  as  “merely  a  condition  prece-
dent” to a “contract” is overly dismissive of the Navy’s legitimate interest in the 
continuing service of its officers.   
 

7. 

There is no evidence, however, that the Coast Guard caused 
the  Navy’s  misunderstanding.    The  April  20,  1998,  letter  clearly  indicates  the 
Coast  Guard’s  intention  to  commission  the  applicant  as  an  ensign  through  the 
MARGRAD program.  The Coast Guard did fail to notice or question the Navy’s 
characterization  of  the  accession  as  an  inter-service  transfer  on  the  applicant’s 
DD 214 prior to administering the oath of office.  But this failure is insufficient to 
prove any bad faith on the part of or injustice committed by the Coast Guard that 
would render his oath of office and active duty agreement void.  Moreover, there 
is no evidence that the Navy would have refused to release the applicant if it had 
understood  that  he  was  being  accessed  through  the  MARGRAD  program.  
Therefore, the Board concludes that the Navy’s misunderstanding  of the Coast 
Guard’s intention should not determine the nature of his accession.  
 
 
In light of findings 5 and 6 above, the Board finds that the applicant 
was  accessed  by  the  Coast  Guard  through the  Direct  Commission  MARGRAD 
program rather than through inter-service transfer.  Therefore, the provisions of 
10 U.S.C. § 716, Department of Defense Directive 1300.4, and Part 1 of Chapter 25 
of the Navy Military Personnel Manual regarding the retention of rank, service 
precedence, and position on a promotion list do not apply to his accession by the 
Coast Guard. 
 
 
The  Chief  Counsel  alleged  that  the  applicant  was  not  entitled  to 
direct  commissioning  as  a  lieutenant  junior  grade  under  the  MARGRAD  pro-
gram because he had completed only nine months of sea duty when his appli-
cation was considered by the selection board.  However, Paragraph 6.c.(3)(b) of 
COMDTINST  1131.23  clearly  states  that  applicants  must  have  one  year  of  sea 
duty  as  of  the  date  of  commissioning  to  qualify  for  a  direct  commission  as  a 
lieutenant junior grade.  On the date he was commissioned in the Coast Guard 

8. 

9. 

Reserve, the applicant had over one year of sea duty in the Navy, as shown on 
his  DD  214.    Therefore,  the  Board  finds  that  the  Coast  Guard  committed  error 
and injustice when it appointed the applicant in the rank of ensign, rather than 
lieutenant  junior  grade.    Because  many  officers  are  directly  commissioned  at 
ranks above ensign and enjoy long careers despite their lack of OERs at the low-
est rank, the Board is not persuaded by the Chief Counsel’s argument that com-
missioning the applicant as an ensign was in his best interest. 
 
 
Title  14  U.S.C.  § 744,  which  requires  the  transfer  of  dates  of  rank 
and service precedence from one service to another when an officer is commis-
sioned in the same grade, narrowly misses applying to the applicant because he 
was an officer on active duty in the Naval Reserve rather an officer in the regular 
Navy.  Title 14 U.S.C. § 727 states that the Secretary may assign a Reserve officer 
a “date of rank and precedence which reflects that person’s experience, educa-
tion, or other qualifications.”  However, Paragraph 6.a. of COMDTINST 1131.23, 
which governs direct commissions under the MARGRAD program, states that an 
officer’s “date of rank shall be the date of appointment to commissioned status in 
the Coast Guard Reserve.”  Therefore, the Board finds that the applicant’s date of 
rank as a lieutenant junior grade in the Coast Guard Reserve should be the date 
of his appointment, xxxxxxx. 
 
 
10.  Accordingly,  partial  relief  should  be  granted  by  correcting  the 
applicant’s oath of office to show that he was appointed in the rank of lieutenant 
junior  grade  and  by  correcting  his  date  of  rank  as  a  lieutenant  junior  grade to 
xxxxxxxxx.  
 
 
 
 
 

[ORDER AND SIGNATURES ON FOLLOWING PAGE] 

 
 
 
 

ORDER 

 

The application of XXXXXXXXXX, USCGR, for correction of his military 

record is hereby granted as follows: 

 
His records shall be corrected to show that he took the oath of office and 
was commissioned at the rank of lieutenant junior grade (O-2) on xxxxxxxx.  His 
date of rank shall be xxxxxxx. 

 
The Coast Guard shall pay the applicant any back pay and allowances he 

 

 
Karen L. Petronis 

 

 
 

 

 
Edmund T. Sommer, Jr. 

 

 

 

 

 

 

 

 

 

 

 
 

 
 

 
 

 
 

 
 

may be due as a result of this correction. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 
 

 

 
 
Betsy L. Wolf