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ISCR Case ISCR Case No. 24-02473 — CASE

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ISCR Case ISCR Case No. 24-02473

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

Case Profile
Decision Date1/12/2026
Statusdenied
LevelAPPEAL
TypeSTANDARD ISCR
Related decisionSee the hearing decision (Case 24-02473) →
Participants
Applicant Representation: Pro Se
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 but was denied by the Department of Defense (DoD) due to concerns under Guideline F (Financial Considerations). The Statement of Reasons (SOR) indicated that the applicant had filed for Chapter 7 bankruptcy in 2020, discharging her debts, and had 13 delinquent debts, some of which were duplicates. The applicant admitted to the debts but provided explanations and documentation regarding her financial situation.
The administrative judge found that the applicant had not sufficiently mitigated the financial concerns, particularly regarding four unique debts totaling over $10,000 that remained delinquent. Although the applicant claimed to have made payments and submitted documentation, the judge determined that the evidence did not corroborate her assertions. The judge noted that the applicant's disagreement with the evidence's interpretation did not demonstrate any error in the judge's findings. Ultimately, the judge concluded that the applicant failed to establish a responsible financial record, leading to the affirmation of the denial of her security clearance.
Guidelines Evaluated
- Guideline FFinancial Considerations · Against Applicant
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Case Headnote

ISCR Case No. ISCR Case No. 24-02473

Jan 12, 2026· Hon. Moira D. Modzelewski· appeal

Summary

A security clearance applicant, representing herself, was denied under Guideline F (Financial Considerations) due to significant financial issues. These included a Chapter 7 bankruptcy and multiple delinquent debts exceeding $10,000. The applicant admitted to these debts, which were identified as disqualifying conditions under Adjudicative Guideline (AG) ¶ 20.

While the applicant presented some documentation, the judge determined it was insufficient to mitigate the financial concerns. Specifically, the applicant failed to provide adequate evidence of payments or resolution for the outstanding debts. Consequently, the judge found that the applicant did not establish a sufficient record of responsible financial conduct.

Despite the application of mitigating conditions under AG ¶ 21(a), (b), (c), and (d), the lack of sufficient evidence regarding debt resolution led to the denial of the security clearance. This denial was subsequently affirmed on appeal.

Conditions Referenced

Disqualifying

AG ¶ 20raisedFinancial Considerations

Mitigating

AG ¶ 21(a)rejectedThe Behavior Was Not RecentThe applicant's financial issues were ongoing and not resolved.
AG ¶ 21(b)rejectedThe Conditions That Resulted in the Financial Problems Were Largely Beyond the Person's ControlThe applicant did not demonstrate that her financial issues were beyond her control.
AG ¶ 21(c)rejectedThe Person Has Received or Is Receiving Counseling for the ProblemThe applicant did not provide evidence of financial counseling.
AG ¶ 21(d)rejectedThe Person Has Initiated a Good-faith Effort to Repay Overdue Creditors or Otherwise Resolve DebtsThe applicant's efforts to resolve debts were deemed insufficient.

Key Rule Quoted

“The general standard is that a clearance may be granted only when 'clearly consistent with the interests of the national security.'”
— Department of the Navy v. Egan, 484 U.S. 518, 528 (1988)

Procedural Posture

SOR issuedFeb 13, 2025
Answer filed—
Hearing held—
Decision dateJan 12, 2026Appeal affirmed the denial.

Cite For

Affirmation of Denial Based on Financial Considerations Under Guideline F
Insufficient Evidence of Debt Resolution
Importance of Demonstrating Responsible Financial Conduct for Security Clearance Eligibility

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 the denial of a security clearance based on financial considerations, specifically a Chapter 7 bankruptcy and multiple delinquent debts. The Applicant argued that evidence of payments was not properly submitted. The Board affirmed the Administrative Judge's decision, finding no harmful error in the Judge's conclusions regarding the Applicant's financial responsibility.

Appealed bythe applicant

Applicant representationPro se (self-represented)

Judge belowRichard A. Cefola — denied the clearance

Decided ona hearing

Guidelines belowGuideline F

What the Board reviewed

Judge mis-weighed or ignored evidence — raised by the applicantRejected
Applicant contended that proof of payments was not properly submitted due to a scanning or transmission error.
Decision arbitrary, capricious, or contrary to law — raised by the applicantRejected
Applicant argued that the Judge's conclusions were arbitrary and capricious.

Error found, but harmless. The Board agreed the judge made a mistake but affirmed anyway, because it did not change the outcome.

Why the Board ruled this way

The Board found no error in the Judge's findings regarding the Applicant's financial conduct and concluded that the Judge's decision was sustainable based on the evidence presented.

Standard of review applied

Harmful-error gatekeeperSubstantial-evidence reviewArbitrary-and-capricious reviewProcedural complianceNo de-novo re-decisionNo new evidence on appealDeference to the judge’s credibility calls

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.