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ISCR Case 24-01764 · CASE

Case record

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

Decision Date3/23/2026
Statusdenied
LevelHEARING
TypeSTANDARD ISCR
Participants
Applicant Representation: Pro Se
Government Counsel: Carroll J. Connelley
Judge: LeRoy F. Foreman
Guidelines Evaluated
- FFinancial Considerations · Against Applicant
Questions about ISCR 24-01764, answered from its own record: what was alleged, what the judge found, where it says so. Descriptive only; never advice.

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Other decisions whose allegations read most like this one. Descriptive similarity of the allegations only, not a prediction.
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ISCR Case 24-01764denied

Case Headnote

ISCR Case No. 24-01764

deniedMar 23, 2026· Hon. LeRoy F. Foreman· hearing

Synopsis

The applicant, a 40-year-old mail clerk, faced security concerns under Guideline F (Financial Considerations) due to 16 delinquent debts totaling over $23,000. Despite attributing her financial issues to a layoff and a cohabitant's refusal to share expenses, she admitted all debts without taking action to resolve them. The judge denied the security clearance, citing a lack of responsible conduct and failure to mitigate the financial concerns.

Why the Applicant Was Denied

Applicant admitted all allegations in the SOR, including numerous and recent delinquent debts.
She failed to take any meaningful action to resolve her debts, casting doubt on her reliability and judgment.
No evidence was presented to demonstrate a good-faith effort to repay or resolve her debts.

Conditions Referenced

Disqualifying

AG ¶ 19(a)appliedInability to Satisfy Debts
AG ¶ 19(c)appliedA History of Not Meeting Financial Obligations

Mitigating

AG ¶ 20(a)rejectedBehavior Happened so Long Ago, Was Infrequent, or Unlikely to RecurDelinquent debts are numerous and recent.
AG ¶ 20(b)rejectedConditions Beyond the Person's ControlWhile the breakup of her relationship was beyond her control, her lack of concern about her debts undermined this argument.
AG ¶ 20(d)rejectedGood-faith Effort to Repay DebtsApplicant submitted no evidence of a good-faith effort to repay or resolve her debts.
AG ¶ 20(e)rejectedReasonable Basis to Dispute DebtsApplicant has not disputed any of the debts alleged in the SOR.

Key Rule Quoted

“Eligibility for a security clearance is predicated upon the applicant meeting the criteria contained in the adjudicative guidelines.”

Procedural Posture

SOR issuedSep 17, 2025
Answer filedSep 29, 2025Requested decision on the written record without a hearing.
Hearing held—No hearing held.
Decision dateMar 23, 2026

Cite For

Denial of Clearance Due to Financial Irresponsibility Under Guideline F
Failure to Demonstrate Good-faith Efforts to Resolve Debts
Impact of Recent Financial Issues on 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.

Standardized Decision Profile

SEAD-4 Guideline F · descriptive summary of a decided case

Posture: Decision on RecordDecided: denied

The judge found that the applicant had numerous delinquent debts totaling over $23,000, which she admitted without providing explanations or evidence of efforts to resolve them. The judge ruled against the applicant on all allegations under Guideline F, citing her inability to satisfy debts and a history of not meeting financial obligations as disqualifying conditions.

1.a–1.e 5 sub-charges: specific text not stated in this decision (against the applicant).
Finding: Against Applicant
Type:
Response:
Disqualifying (¶19): —
Mitigating applied (¶20): —
Mitigation: —
1.f Delinquent personal loan account in the amount of $1,324
$1,324
Finding: Against Applicant
Type: Personal Loan Debt
Response: Unknown
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
1.g–1.p 10 sub-charges: specific text not stated in this decision (against the applicant).
Finding: Against Applicant
Type:
Response:
Disqualifying (¶19): —
Mitigating applied (¶20): —
Mitigation: —

¶	Allegation	Finding	Type	Response	Disqualifying (¶19)	Mitigating applied (¶20)	Mitigation
1.a–1.e	5 sub-charges: specific text not stated in this decision (against the applicant).	Against Applicant			—	—	—
1.f	Delinquent personal loan account in the amount of $1,324 $1,324	Against Applicant	Personal Loan Debt	Unknown	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
1.g–1.p	10 sub-charges: specific text not stated in this decision (against the applicant).	Against Applicant			—	—	—

Descriptive standardized rendering of a decided public case (Guideline F). The verbatim source decision is shown in full below.

Full decision

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

Decision text, by section

DEFENSE OFFICE OF HEARINGS AND APPEALS

HEARING

APPEARANCES

icant for Security Clearance ) Appearances For Government: Carroll J. Connelley, Esq

DECISION

, Department Counsel For Applicant: Pro se 03/23/2026 Decision FOREMAN, LeRoy F., Administrative Judge: This case involves security concerns raised under Guideline F (Financial Considerations

STATEMENT OF CASE

. Clearance is denied. Statement of the Case Applicant submitted a security clearance application (SCA) on October 18, 2023. On September 17, 2025, the Defense Counterintelligence and Security Agency (DCSA) sent her a Statement of Reasons (SOR) alleging security concerns under Guideline F. The DCSA acted under Executive Order (Exec. Or.) 10865, Safeguarding Classified Information within Industry (February 20, 1960), as amended; Department of Defense (DOD) Directive 5220.6, Defense Industrial Personnel Security Clearance Review Program (January 2, 1992), as amended (Directive); and the adjudicative guidelines (AG) promulgated in Security Executive Agent Directive 4, National Security Adjudi

FINDINGS OF FACT

ative Guidelines (December 10, 2016), which became effective on June 8, 2017. 1

Applicant answered the SOR on September 29, 2025, and requested a decision on the written record without a hearing. Department Counsel submitted the Government’s written case on December 30, 2025. A complete copy of the file of relevant material (FORM) was sent to Applicant, who was given an opportunity to file objections and submit material to refute, extenuate, or mitigate the Government’s evidence. She received the FORM on January 13, 2026, and she did not respond. The FORM consists of seven exhibits. Government Exhibit (GX) 1 contains the pleadings in the case. GX 2 through 7 are the evidence in support of the allegations in the SOR, and they are admitted in evidence. Findings of Fact In Applicant’s answer to the SOR, she admitted all the allegations in the SOR. Her admissions are incorporated in my findings of fact. Applicant is a 40-year-old mail clerk sponsored for a clearance by a federal contractor. She is a high sch

POLICIES

ol graduate. She has worked for her current employer since June 2023. She has never married but lived with a cohabitant between 2005 and 2024, and they have two children, ages 14 and 11. She and her cohabitant are in the process of separating. The SOR alleges 16 delinquent debts totaling more than $23,000. The debts are reflected in credit reports from September 2025, August 2024, and October 2023. (FORM Items 3, ,4, and 5) Applicant admitted all the debts in her answer to the SOR without explanation. When she was interviewed by a security investigator, she admitted all the debts, but could identify only the delinquent personal loan alleged in SOR ¶¶ 1.f ($1,324) and the delinquent credit-card accounts alleged in SOR ¶¶ 1.c, 1.d, 1.h, and 1.n. She attributed her debts to being laid off in 2022 after being employed since 2005 and the refusal of her cohabitant to share expenses. In response to DCSA interrogatories in August 2024, she submitted a personal financial statement reflecting a net monthly income of approximately $3,398, expenses of $2,398, a debt payment of $538 on a car loan, and a net remainder of about $463. Her monthly income includes child-support payments of $1,000 per month from her cohabitant. She has not disputed any of the debts alleged in the SOR, and she has taken no action to resolve them. Policies “[N]o one has a ‘right’ to a security clearance.” Department of the Navy v. Egan, 484 U.S. 518, 528 (1988). As Commander in Chief, the President has the authority to “control access to information bearing on national security and to determine whether an individual is sufficiently trustworthy to have access to such information.” Id. at 527. The President has authorized the Secretary of Defense or his designee to grant applicants 2

eligibility for access to classified information “only upon a finding that it is clearly consistent with the national interest to do so.” Exec. Or. 10865 § 2.

Eligibility for a security clearance is predicated upon the applicant meeting the criteria contained in the adjudicative

ANALYSIS

guidelines. These guidelines are not inflexible rules of law. Instead, recognizing the complexities of human behavior, an administrative judge applies these guidelines in conjunction with an evaluation of the whole person. An administrative judge’s overarching adjudicative goal is a fair, impartial, and commonsense decision. An administrative judge must consider all available and reliable information about the person, past and present, favorable and unfavorable. The Government reposes a high degree of trust and confidence in persons with access to classified information. This relationship transcends normal duty hours and endures throughout off-duty hours. Decisions include, by necessity, consideration of the possible risk that the applicant may deliberately or inadvertently fail to safeguard classified information. Such decisions entail a certain degree of legally permissible extrapolation about potential, rather than actual, risk of compromise of classified information. Clearance decisions must be made “in terms of the national interest and shall in no sense be a determination as to the loyalty of the applicant concerned.” Exec. Or. 10865 § 7. Thus, a decision to deny a security clearance is merely an indication the applicant has not met the strict guidelines the President and the Secretary of Defense have established for issuing a clearance. Initially, the Government must establish, by substantial evidence, conditions in the personal or professional history of the applicant that may disqualify the applicant from being eligible for access to classified information. The Government has the burden of establishing controverted facts alleged in the SOR. See Egan at 531. Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion in light of all the contrary evidence in the same record.” See ISCR Case No. 17-04166 at 3 (App. Bd. Mar. 21, 2019).

ANALYSIS

tinflexible rules of law. Instead, recognizing the complexities of human behavior, an administrative judge applies these guidelines in conjunction with an evaluation of the whole person. An administrative judge’s overarching adjudicative goal is a fair, impartial, and commonsense decision. An administrative judge must consider all available and reliable information about the person, past and present, favorable and unfavorable. The Government reposes a high degree of trust and confidence in persons with access to classified information. This relationship transcends normal duty hours and endures throughout off-duty hours. Decisions include, by necessity, consideration of the possible risk that the applicant may deliberately or inadvertently fail to safeguard classified information. Such decisions entail a certain degree of legally permissible extrapolation about potential, rather than actual, risk of compromise of classified information. Clearance decisions must be made “in terms of the national interest and shall in no sense be a determination as to the loyalty of the applicant concerned.” Exec. Or. 10865 § 7. Thus, a decision to deny a security clearance is merely an indication the applicant has not met the strict guidelines the President and the Secretary of Defense have established for issuing a clearance. Initially, the Government must establish, by substantial evidence, conditions in the personal or professional history of the applicant that may disqualify the applicant from being eligible for access to classified information. The Government has the burden of establishing controverted facts alleged in the SOR. See Egan at 531. Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion in light of all the contrary evidence in the same record.” See ISCR Case No. 17-04166 at 3 (App. Bd. Mar. 21, 2019).

WHOLE PERSON ANALYSIS

It is “less than the weight of the evidence, and the possibility of drawing two inconsistent conclusions from the evidence does not prevent [a Judge’s] finding from being supported by substantial evidence.” Consolo v. Federal Maritime Comm’n, 383 U.S. 607, 620 (1966). “Substantial evidence” is “more than a scintilla but less than a preponderance.” See v. Washington Metro. Area Transit Auth., 36 F.3d 375, 380 (4th Cir. 1994). The guidelines presume a nexus or rational connection between proven conduct under any of the criteria listed therein and an applicant’s security suitability. ISCR Case No. 15-01253 at 3 (App. Bd. Apr. 20, 2016). Once the Government establishes a disqualifying condition by substantial evidence, the burden shifts to the applicant to rebut, explain, extenuate, or mitigate the facts. Directive ¶ E3.1.15. An applicant has the burden of proving a mitigating condition, 3

and the burden of disproving it never shifts to the Government. See ISCR Case No. 02- 31154 at 5 (App. Bd. Sep. 22, 2005). An applicant “has the ultimate burden

FORMAL FINDINGS

of demonstrating that it is clearly consistent with the national interest to grant or continue his security clearance.” ISCR Case No. 01- 20700 at 3 (App. Bd. Dec. 19, 2002). “[S]ecurity clearance determinations should err, if they must, on the side of denials.” Egan at 531. Analysis

CONCLUSION

Guideline F, Financial Considerations The security concern under this guideline is set out in AG ¶ 18: Failure to live within one’s means, satisfy debts, and meet financial obligations may indicate poor self-control, la