ISCR Case 07-15298.h1

Case Headnote

ISCR Case No. 07-15298.h1

deniedMar 30, 2009· Hon. Darlene Lokey Anderson· hearing

Summary

A 33-year-old defense contractor was denied a security clearance due to concerns under Guideline E (Personal Conduct), Guideline F (Financial Considerations), and Guideline J (Criminal Conduct). The denial stemmed from significant delinquent debts, intentional falsification of information on his security clearance application, and a history of criminal conduct.

Specifically, the applicant was found to have over $16,500 in delinquent debt across sixteen creditors, including personal and household expenses, loans, credit cards, medical services, utilities, and back child support. He attributed these issues to poor budgeting after separating from the Air Force in 2000 and claimed his former wife opened some accounts without his knowledge. While he stated his new job increased his salary and he developed a budget, the record showed no evidence of mitigation or prompt, good faith efforts to repay his debts.

Furthermore, the applicant intentionally provided false answers on his Electronic Questionnaire for Investigations Processing dated January 27, 2006. He failed to disclose two arrests in 2002 for Contempt of Court related to child support, marijuana use in February 2000, a car repossession in early 2002, and being over 180 days delinquent on fourteen of seventeen debts. These deliberate omissions, which he admitted were "wrong," constituted a violation of federal law (Title 18, United States Code, Section 1001). The judge concluded that the applicant's conduct demonstrated poor judgment, unreliability, and untrustworthiness, making it inconsistent with national interests to grant a security clearance.

Why the Applicant Was Denied

The applicant has over $16,500 in delinquent debt and has not demonstrated financial responsibility.
The applicant intentionally falsified material information on his security clearance application, violating federal law.
The applicant's history of criminal conduct raises significant concerns about his judgment and trustworthiness.

Conditions Referenced

Disqualifying

19(a)appliedInability or Unwillingness to Satisfy Debts
19(c)appliedA History of Not Meeting Financial Obligations
16(a)appliedThe Deliberate Omission, Concealment, or Falsification of Relevant and Material Facts
31(a)appliedA Single Serious Crime or Multiple Lesser Offenses
31(c)appliedAllegation or Admission of Criminal Conduct

Key Rule Quoted

“The adjudicative process is an examination of a sufficient period of a person’s life to make an affirmative determination that the person is an acceptable security risk.”

Procedural Posture

SOR issuedApr 9, 2008
Answer filedSep 30, 2008Applicant elected to have the case determined on a written record.
Hearing held—No hearing; case determined on written record.
Decision dateMar 30, 2009

Cite For

Financial Irresponsibility as a Disqualifying Factor Under Guideline F
Intentional Falsification of Information Under Guideline E
Criminal Conduct as a Disqualifying Factor Under Guideline J

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

¶	Allegation	Finding	Conduct	Concealed Issue	Response	Disqualifying (¶16)	Mitigating applied (¶17)	Mitigation
2.a	The Government alleges that the Applicant is ineligible for a security clearance because he intentionally falsified material aspects of his personal background during the employment process.	Against Applicant	Falsification Security FormFOUND DELIBERATE	Criminal Conduct	Admitted	(a) deliberate omission, concealment, or falsification on a security form	—	—
2.b	The Applicant completed an Electronic Questionnaire for Investigations Processing dated January 27, 2006. Question 23(f) of the application asked the Applicant if in the last seven years he has been arrested for, charged with, or convicted of any offense(s) not listed listed in response to a, b, c, d, or e. The Applicant answered, “NO”. This was a false answer. Applicant failed to list that he was arrested twice in 2002 for Contempt of Court, Failure to Pay Child Support/comply with Court Order.	Against Applicant	Falsification Security FormFOUND DELIBERATE	Criminal Conduct	Admitted	(a) deliberate omission, concealment, or falsification on a security form	—	—
2.c	Question 24(a) of the same questionnaire asked the Applicant if since the age of sixteen or in the last seven years, whichever is shorter, has he illegally used any controlled substance, for example marijuana, cocaine, crack cocaine, hashish, narcotics, etc. The Applicant answered “NO”. This was a false answer. Applicant failed to disclose that he used marijuana at least twice in February 2000, after he received his General Discharge from the United States Air Force.	Against Applicant	Falsification Security FormFOUND DELIBERATE	Drug Involvement	Admitted	(a) deliberate omission, concealment, or falsification on a security form	—	—
2.d	Question 27(b) of the same questionnaire asked the Applicant if in the last seven years has he had his wages garnished or had any property repossessed for any reason. The applicant answered, “NO”. This was a false answer. He failed to list the fact that his car was repossessed in early 2002.	Against Applicant	Falsification Security FormFOUND DELIBERATE	Other	Admitted	(a) deliberate omission, concealment, or falsification on a security form	—	—
2.e	Question 28(a) of the same questionnaire asked the Applicant if in the last seven years has he been over 180 days delinquent on any debts. The Applicant answered, “NO”. This was a false answer. He failed to list that in the last seven years he had been over 180 days delinquent on fourteen of the seventeen debts listed in the SOR.	Against Applicant	Falsification Security FormFOUND DELIBERATE	Financial	Admitted	(a) deliberate omission, concealment, or falsification on a security form	—	—

Allegation

Finding

Conduct

Concealed Issue

Response

Disqualifying (¶16)

Mitigating applied (¶17)

Mitigation

2.a

The Government alleges that the Applicant is ineligible for a security clearance because he intentionally falsified material aspects of his personal background during the employment process.

Against Applicant

Falsification Security FormFOUND DELIBERATE

Criminal Conduct

Admitted

(a) deliberate omission, concealment, or falsification on a security form

—

2.b

The Applicant completed an Electronic Questionnaire for Investigations Processing dated January 27, 2006. Question 23(f) of the application asked the Applicant if in the last seven years he has been arrested for, charged with, or convicted of any offense(s) not listed listed in response to a, b, c, d, or e. The Applicant answered, “NO”. This was a false answer. Applicant failed to list that he was arrested twice in 2002 for Contempt of Court, Failure to Pay Child Support/comply with Court Order.

Against Applicant

Falsification Security FormFOUND DELIBERATE

Criminal Conduct

Admitted

(a) deliberate omission, concealment, or falsification on a security form

—

2.c

Question 24(a) of the same questionnaire asked the Applicant if since the age of sixteen or in the last seven years, whichever is shorter, has he illegally used any controlled substance, for example marijuana, cocaine, crack cocaine, hashish, narcotics, etc. The Applicant answered “NO”. This was a false answer. Applicant failed to disclose that he used marijuana at least twice in February 2000, after he received his General Discharge from the United States Air Force.

Against Applicant

Falsification Security FormFOUND DELIBERATE

Drug Involvement

Admitted

(a) deliberate omission, concealment, or falsification on a security form

—

2.d

Question 27(b) of the same questionnaire asked the Applicant if in the last seven years has he had his wages garnished or had any property repossessed for any reason. The applicant answered, “NO”. This was a false answer. He failed to list the fact that his car was repossessed in early 2002.

Against Applicant

Falsification Security FormFOUND DELIBERATE

Other

Admitted

(a) deliberate omission, concealment, or falsification on a security form

—

2.e

Question 28(a) of the same questionnaire asked the Applicant if in the last seven years has he been over 180 days delinquent on any debts. The Applicant answered, “NO”. This was a false answer. He failed to list that in the last seven years he had been over 180 days delinquent on fourteen of the seventeen debts listed in the SOR.

Against Applicant

Falsification Security FormFOUND DELIBERATE

Financial

Admitted

(a) deliberate omission, concealment, or falsification on a security form

—

¶	Allegation	Finding	Type	Response	Disqualifying (¶19)	Mitigating applied (¶20)	Mitigation
1.a	The Applicant is ineligible for a security clearance because he is financially overextended and at risk to engage in illegal acts to generate funds.	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.b	The Applicant remains indebted to sixteen creditors in the amount of approximately $16,585.00. $16,585	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.c	The delinquent accounts comprise debt associated with personal and household expenses, loans, credit cards, medical services, utilities and back child support.	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.d	The Applicant attributes his financial problems to poor budgeting skills after he separated from the Air Force in 2000.	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.e	The Applicant claims that his former wife opened some financial accounts and included him on the accounts without his knowledge.	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.f	The Applicant states that his new job increased his salary sufficient to repay his delinquent debts and that he has developed a budget which shows how he plans to cover his expenses and debt repayments.	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.g	The Applicant and his current wife have made a mutual decision to move into a small apartment on top of her store in order to cut down on their expenses, get current with their bills, and then begin the long process of paying back their old delinquent debts.	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.h–3.a	17 sub-charges — specific text not stated in this decision (against the applicant). (low confidence)	Against Applicant			—	—	—

Allegation

Finding

Type

Response

Disqualifying (¶19)

Mitigating applied (¶20)

Mitigation

1.a

The Applicant is ineligible for a security clearance because he is financially overextended and at risk to engage in illegal acts to generate funds.

Against Applicant

Unspecified Financial

Admitted

(a) inability to satisfy debts

(c) a history of not meeting financial obligations

—

1.b

The Applicant remains indebted to sixteen creditors in the amount of approximately $16,585.00.

$16,585

Against Applicant

Unspecified Financial

Admitted

(a) inability to satisfy debts

(c) a history of not meeting financial obligations

—

1.c

The delinquent accounts comprise debt associated with personal and household expenses, loans, credit cards, medical services, utilities and back child support.

Against Applicant

Unspecified Financial

Admitted

(a) inability to satisfy debts

(c) a history of not meeting financial obligations

—

1.d

The Applicant attributes his financial problems to poor budgeting skills after he separated from the Air Force in 2000.

Against Applicant

Unspecified Financial

Admitted

(a) inability to satisfy debts

(c) a history of not meeting financial obligations

—

1.e

The Applicant claims that his former wife opened some financial accounts and included him on the accounts without his knowledge.

Against Applicant

Unspecified Financial

Admitted

(a) inability to satisfy debts

(c) a history of not meeting financial obligations

—

1.f

The Applicant states that his new job increased his salary sufficient to repay his delinquent debts and that he has developed a budget which shows how he plans to cover his expenses and debt repayments.

Against Applicant

Unspecified Financial

Admitted

(a) inability to satisfy debts

(c) a history of not meeting financial obligations

—

1.g

The Applicant and his current wife have made a mutual decision to move into a small apartment on top of her store in order to cut down on their expenses, get current with their bills, and then begin the long process of paying back their old delinquent debts.

Against Applicant

Unspecified Financial

Admitted

(a) inability to satisfy debts

(c) a history of not meeting financial obligations

—

1.h–3.a

17 sub-charges — specific text not stated in this decision (against the applicant). (low confidence)

Against Applicant

—

¶	Allegation	Finding	Offense	Criminal disposition	Response	Disqualifying (¶31)	Mitigating applied (¶32)	Mitigation
3.a	The Government alleges that the Applicant is ineligible for a security clearance because he has engaged in criminal activity which creates doubt about a person’s judgment, reliability, and trustworthiness.	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—
3.b	The Applicant completed an Electronic Questionnaire for Investigations Processing dated January 27, 2006. Question 23(f) of the application asked the Applicant if in the last seven years he has been arrested for, charged with, or convicted of any offense(s) not listed listed in response to a, b, c, d, or e. The Applicant answered, “NO”. This was a false answer. Applicant failed to list that he was arrested twice in 2002 for Contempt of Court, Failure to Pay Child Support/comply with Court Order.	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—
3.c	Question 24(a) of the same questionnaire asked the Applicant if since the age of sixteen or in the last seven years, whichever is shorter, has he illegally used any controlled substance, for example marijuana, cocaine, crack cocaine, hashish, narcotics, etc. The Applicant answered “NO”. This was a false answer. Applicant failed to disclose that he used marijuana at least twice in February 2000, after he received his General Discharge from the United States Air Force.	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—
3.d	Question 27(b) of the same questionnaire asked the Applicant if in the last seven years has he had his wages garnished or had any property repossessed for any reason. The applicant answered, “NO”. This was a false answer. He failed to list the fact that his car was repossessed in early 2002.	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—
3.e	Question 28(a) of the same questionnaire asked the Applicant if in the last seven years has he been over 180 days delinquent on any debts. The Applicant answered, “NO”. This was a false answer. He failed to list that in the last seven years he had been over 180 days delinquent on fourteen of the seventeen debts listed in the SOR.	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—
3.f	Question 28(b) of the same questionnaire asked the Applicant if he was currently over 90 days delinquent on any debts. The Applicant answered, “NO”. This was a false answer. He failed to list that at the time he filled out the questionnaire he was over 90 days delinquent on fifteen of the seventeen debts listed in the SOR.	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—
3.g	The Applicant admits that he was “wrong to put NO for all of those questions”. He states that he was “rushing though the paperwork” so that he could get a better paying job overseas to earn a better salary that would allow him to pay his delinquent debt.	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—
3.h	By deliberately providing false information to the Government on this questionnaire, the Applicant violated federal law, Title 18, United States Code, Section 1001.	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—
3.i	The evidence shows that the Applicant cannot be trusted with the national secrets. Disqualifying Condition 31(a) a single serious crime or multiple lesser offenses and 31(c) allegation or admission of criminal conduct, regardless of whether the person was formally charged, formally prosecuted or convicted apply.	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—
3.j	The Applicant has in excess of $16,500.00 in delinquent debt. The record is void as to any evidence of mitigation. He has not paid any of his delinquent debts although he indicates that he recently set up a payment plan.	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—
3.k	The Applicant had not initiated a prompt, good faith effort to repay his overdue creditors or otherwise resolve his debts. Accordingly, I find against the Applicant under Guideline F (Financial Considerations).	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—
3.l	The totality of the conduct set forth under all of the guidelines viewed as a whole, support a whole person assessment of questionable judgement, untrustworthiness, unreliability, lack of candor, unwillingness to comply with rules and regulations, or other characteristics indicating that the person may not properly safeguard classified information.	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—
3.m	The Government has met its initial burden of proving that the Applicant has been financially irresponsible (Guideline F), that he has been untruthful on his Questionnaire for Investigations Processing (Guideline E) and that he violated federal law, Title 18, United States Code, Section 1001, when he did so (Guideline J).	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—
3.n	The evidence supports a finding against the Applicant as to the factual and conclusionary allegations expressed in Paragraphs 1, 2 and 3 of the Government's Statement of Reasons.	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—
3.o	The Applicant has failed to overcome the Government's case opposing his request for a security clearance.	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—
3.p	In light of the circumstances presented by the record in this case, it is not clearly consistent with the national interests to grant or continue a security clearance for the Applicant.	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—
3.q	The Applicant's conduct demonstrates poor judgment, unreliability and untrustworthiness.	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—
3.r	The Applicant's financial irresponsibility, dishonesty and criminal conduct demonstrate a lack of judgment or unreliability.	Against Applicant	Unspecified Criminal Conduct	Conduct No Charge	Denied	(a) pattern of minor offenses casting doubt on judgment/reliability (c) currently on parole or probation	—	—

Allegation

Finding

Offense

Criminal disposition

Response

Disqualifying (¶31)

Mitigating applied (¶32)

Mitigation

3.a

The Government alleges that the Applicant is ineligible for a security clearance because he has engaged in criminal activity which creates doubt about a person’s judgment, reliability, and trustworthiness.

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

3.b

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

3.c

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

3.d

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

3.e

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

3.f

Question 28(b) of the same questionnaire asked the Applicant if he was currently over 90 days delinquent on any debts. The Applicant answered, “NO”. This was a false answer. He failed to list that at the time he filled out the questionnaire he was over 90 days delinquent on fifteen of the seventeen debts listed in the SOR.

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

3.g

The Applicant admits that he was “wrong to put NO for all of those questions”. He states that he was “rushing though the paperwork” so that he could get a better paying job overseas to earn a better salary that would allow him to pay his delinquent debt.

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

3.h

By deliberately providing false information to the Government on this questionnaire, the Applicant violated federal law, Title 18, United States Code, Section 1001.

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

3.i

The evidence shows that the Applicant cannot be trusted with the national secrets. Disqualifying Condition 31(a) a single serious crime or multiple lesser offenses and 31(c) allegation or admission of criminal conduct, regardless of whether the person was formally charged, formally prosecuted or convicted apply.

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

3.j

The Applicant has in excess of $16,500.00 in delinquent debt. The record is void as to any evidence of mitigation. He has not paid any of his delinquent debts although he indicates that he recently set up a payment plan.

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

3.k

The Applicant had not initiated a prompt, good faith effort to repay his overdue creditors or otherwise resolve his debts. Accordingly, I find against the Applicant under Guideline F (Financial Considerations).

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

3.l

The totality of the conduct set forth under all of the guidelines viewed as a whole, support a whole person assessment of questionable judgement, untrustworthiness, unreliability, lack of candor, unwillingness to comply with rules and regulations, or other characteristics indicating that the person may not properly safeguard classified information.

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

3.m

The Government has met its initial burden of proving that the Applicant has been financially irresponsible (Guideline F), that he has been untruthful on his Questionnaire for Investigations Processing (Guideline E) and that he violated federal law, Title 18, United States Code, Section 1001, when he did so (Guideline J).

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

3.n

The evidence supports a finding against the Applicant as to the factual and conclusionary allegations expressed in Paragraphs 1, 2 and 3 of the Government's Statement of Reasons.

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

3.o

The Applicant has failed to overcome the Government's case opposing his request for a security clearance.

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

3.p

In light of the circumstances presented by the record in this case, it is not clearly consistent with the national interests to grant or continue a security clearance for the Applicant.

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

3.q

The Applicant's conduct demonstrates poor judgment, unreliability and untrustworthiness.

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

3.r

The Applicant's financial irresponsibility, dishonesty and criminal conduct demonstrate a lack of judgment or unreliability.

Against Applicant

Unspecified Criminal Conduct

Conduct No Charge

Denied

(a) pattern of minor offenses casting doubt on judgment/reliability

(c) currently on parole or probation

—

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Case Profile

Summary

Why the Applicant Was Denied

Conditions Referenced

Key Rule Quoted

Procedural Posture

Cite For

Full decision

DEFENSE OFFICE OF HEARINGS AND APPEALS

HEARING

APPEARANCES

STATEMENT OF CASE

FINDINGS OF FACT

POLICIES

CONCLUSION

FORMAL FINDINGS

DECISION