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ISCR Case 24-00198 — CASE

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ISCR Case 24-00198

A decided public DOHA case, shown for research — not advice or a prediction.

Case Profile
Decision Date6/24/2025
Statusdenied
LevelAPPEAL
TypeSTANDARD ISCR
Related decisionSee the hearing decision (Case 24-00198) →
Participants
Judge: Moira D. Modzelewski, Allison Marie, Jennifer I. Goldstein
Government Counsel: Andrea M. Corrales
Case Summary
The applicant in this case sought a security clearance from the Department of Defense (DoD), which was denied based on concerns under Guideline F (Financial Considerations) of the National Security Adjudicative Guidelines. The Statement of Reasons (SOR) outlined 12 delinquent debts totaling approximately $36,000. The applicant's financial difficulties were attributed to various personal hardships, including job loss, family financial dependency, the death of her mother due to COVID-19, and significant restitution payments from a prior legal matter.
The administrative judge found in favor of the applicant on seven of the alleged debts but ruled adversely on five. The applicant admitted to the existence of the debts but argued that her circumstances warranted mitigation. However, the judge determined that the applicant's financial decisions, including a timeshare purchase made after the SOR was issued, were imprudent and contributed to her financial issues. The judge concluded that the applicant had not sufficiently demonstrated that her financial situation was manageable or that it would not pose a risk to national security. Consequently, the appeal board affirmed the judge's decision, stating that the applicant had not established any harmful error in the judge's analysis or weighing of the evidence.
Guidelines Evaluated
- Guideline FFinancial Considerations · Against Applicant
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Case Headnote

ISCR Case No. 24-00198

Jun 24, 2025· Hon. Moira D. Modzelewski· appeal

Summary

An applicant, represented by counsel, was denied a security clearance under Guideline F (Financial Considerations) due to unmitigated financial concerns. The case involved 12 delinquent debts totaling approximately $36,000.

The Administrative Judge found favorably on seven of these debts, applying mitigating conditions AG ¶ 20(a), AG ¶ 20(b), and AG ¶ 20(c). However, the judge found adversely on five remaining delinquent debts, which also totaled approximately $36,000, determining that the applicant's claimed financial hardships did not sufficiently mitigate the security concerns raised by disqualifying condition AG ¶ 19.

Ultimately, the security clearance was denied. The appeal board affirmed this decision, concluding that the Administrative Judge had adequately considered all presented evidence and provided a satisfactory explanation for the denial.

Conditions Referenced

Disqualifying

AG ¶ 19raisedFinancial Considerations

Mitigating

AG ¶ 20(a)rejectedThe Behavior Was Not RecentThe judge found that the applicant's financial issues were ongoing.
AG ¶ 20(b)rejectedThe Individual Has Received CounselingThe applicant did not demonstrate effective financial management.
AG ¶ 20(c)rejectedThe Individual Has a Good Faith Effort to Repay DebtsThe applicant's actions did not show a good faith effort to resolve the debts.

Key Rule Quoted

“"Any doubt concerning personnel being considered for national security eligibility will be resolved in favor of the national security."”
— AG ¶ 2(b)

Procedural Posture

SOR issuedMar 7, 2024
Answer filed—
Hearing held—
Decision dateJun 24, 2025Appeal decision affirmed.

Cite For

Denial of Security Clearance Due to Unresolved Financial Obligations Under Guideline F
Consideration of Mitigating Factors in Financial Cases
Affirmation of a Judge's Decision When Evidence Is Adequately Considered and Explained.

Editorial summary generated for research. Not legal advice; not a prediction. Verify against the full decision before relying on any quoted language.

Appeal at a glance· Full written decision

Affirmed

The appeal involved a denial of security clearance based on financial considerations. The applicant argued that the Judge erred in the mitigation analysis by not adequately considering her hardships. The Board affirmed the decision, finding no harmful error in the Judge's analysis and weighing of the evidence.

Appealed bythe applicant

Applicant representationAttorney

Judge belowEdward W. Loughran — denied the clearance (split findings)

Decided ona hearing

Guidelines belowGuideline F

What the Board reviewed

Mitigation wrongly applied / not applied — raised by the applicantRejected
The Judge erred in his mitigation analysis by not giving appropriate weight to the applicant's hardships.
Decision arbitrary, capricious, or contrary to law — raised by the applicantRejected
The Judge's weighing of the evidence was arbitrary and capricious.

Why the Board ruled this way

The Board found that the Judge considered all relevant evidence and articulated a satisfactory explanation for the decision. The applicant's arguments did not establish harmful error or that the Judge's decision was arbitrary or capricious.

Standard of review applied

Harmful-error gatekeeperSubstantial-evidence reviewArbitrary-and-capricious reviewProcedural complianceNo de-novo re-decision

Appeal Board panel

Moira Modzelewski — Chair
Allison Marie
Jennifer I. Goldstein

Descriptive structured reading of this decided, public Appeal Board decision — what the case says, not a prediction or advice.

Full decision

The complete, official text — footnotes and signatures included — is in the original PDF.