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ISCR Case ISCR Case No. 25-00156 · CASE

Case record

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

Decision Date6/4/2026
Statusdenied
LevelHEARING
TypeWRITTEN RECORD FORM
Participants
Applicant Representation: Pro Se
Government Counsel: Carroll J. Connelley, Esq.
Judge: DRISKILL, A. M.
Guidelines Evaluated
- EPersonal Conduct · Against Applicant
- FFinancial Considerations · Against Applicant
Questions about ISCR ISCR Case No. 25-00156, 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 ISCR Case No. 25-00156denied

Case Headnote

ISCR Case No. ISCR Case No. 25-00156

deniedJun 4, 2026· Hon. DRISKILL, A. M.· hearing

Synopsis

The applicant, a 39-year-old individual with a history of financial difficulties, faced security concerns under Guideline E (Personal Conduct) and Guideline F (Financial Considerations) due to falsifying information on her security clearance application and having multiple delinquent debts totaling $78,177. Despite filing for Chapter 7 bankruptcy, the judge found that the applicant did not mitigate the concerns, leading to a denial of her security clearance.

Why the Applicant Was Denied

The applicant deliberately omitted her delinquent debts on her security clearance application, which undermined the integrity of the adjudication process.
The applicant's explanation for her omissions was inconsistent and did not demonstrate good faith efforts to correct the falsifications before being confronted with the facts.
The applicant's financial issues were not resolved satisfactorily, and there was no evidence of a track record of financial reform after her bankruptcy discharge.

Conditions Referenced

Disqualifying

AG ¶ 16(a)appliedDeliberate Omission, Concealment, or Falsification of Relevant Facts
AG ¶ 19(a)appliedInability to Satisfy Debts
AG ¶ 19(c)appliedA History of Not Meeting Financial Obligations

Mitigating

AG ¶ 17(a)rejectedPrompt, Good-faith Efforts to Correct the OmissionThe applicant did not attempt to correct the omission before being confronted.
AG ¶ 20(b)rejectedConditions Largely Beyond the Person's ControlLeaving her job after childbirth was not considered beyond her control.
AG ¶ 20(c)rejectedReceiving Financial CounselingThere was no evidence of ongoing financial counseling or steps taken to resolve debts post-bankruptcy.
AG ¶ 20(d)rejectedGood-faith Effort to Repay CreditorsThe applicant did not demonstrate a good-faith effort to repay or resolve her debts.

Key Rule Quoted

“[N]o one has a ‘right’ to a security clearance.”
Department of the Navy v. Egan, 484 U.S. 518, 528 (1988)

Procedural Posture

SOR issuedMar 27, 2025
Answer filedApr 23, 2025Requested decision on the written record.
Hearing held—No hearing; decision made on the written record.
Decision dateJun 4, 2026

Cite For

Deliberate Omission of Debts on Security Clearance Applications Under Guideline E
Failure to Demonstrate Financial Rehabilitation Under Guideline F
The Importance of Full Disclosure in Security Clearance Applications.

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 E (Personal Conduct) · descriptive summary of a decided case

Posture: Decision on RecordDecided: denied

The judge found against the applicant on the personal conduct allegations under Guideline E, specifically regarding the falsification of material facts on her security clearance application. The applicant admitted to omitting her delinquent debts due to embarrassment, which the judge deemed a deliberate act, leading to a denial of her security clearance.

1.a The SOR alleges Applicant falsified material facts on her May 2024 security clearance application (SCA) by not reporting her delinquent debts (SOR ¶ 1.a); that she has five delinquent debts totaling $78,177 (SOR ¶¶ 2.a-2.e); and that she filed Chapter 7 bankruptcy in January 2025 (SOR ¶ 2.f).
Finding: Against Applicant
Conduct: Falsification Security FormFOUND DELIBERATE
Concealed issue: Financial
Response: Admitted
Disqualifying (¶16):
(a) deliberate omission, concealment, or falsification on a security form
(b) deliberately providing false information to an investigator or official
Mitigating applied (¶17): —
Mitigation: —

¶	Allegation	Finding	Conduct	Concealed Issue	Response	Disqualifying (¶16)	Mitigating applied (¶17)	Mitigation
1.a	The SOR alleges Applicant falsified material facts on her May 2024 security clearance application (SCA) by not reporting her delinquent debts (SOR ¶ 1.a); that she has five delinquent debts totaling $78,177 (SOR ¶¶ 2.a-2.e); and that she filed Chapter 7 bankruptcy in January 2025 (SOR ¶ 2.f).	Against Applicant	Falsification Security FormFOUND DELIBERATE	Financial	Admitted	(a) deliberate omission, concealment, or falsification on a security form (b) deliberately providing false information to an investigator or official	—	—

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

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 five delinquent debts totaling $78,177 and filed for Chapter 7 bankruptcy, which was discharged. However, the applicant's financial issues were not mitigated due to a lack of evidence showing a track record of financial reform and rehabilitation, leading to a denial of the security clearance.

2.a five delinquent debts totaling $78,177
$78,177
Finding: Against Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
2.b five delinquent debts totaling $78,177
$78,177
Finding: Against Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
2.c five delinquent debts totaling $78,177
$78,177
Finding: Against Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
2.d five delinquent debts totaling $78,177
$78,177
Finding: Against Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
2.e five delinquent debts totaling $78,177
$78,177
Finding: Against Applicant
Type: Unspecified Financial
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —
2.f filed Chapter 7 bankruptcy in January 2025
Finding: Against Applicant
Type: Bankruptcy Filing
Response: Admitted
Disqualifying (¶19):
(a) inability to satisfy debts
(c) a history of not meeting financial obligations
Mitigating applied (¶20): —
Mitigation: —

¶	Allegation	Finding	Type	Response	Disqualifying (¶19)	Mitigating applied (¶20)	Mitigation
2.a	five delinquent debts totaling $78,177 $78,177	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
2.b	five delinquent debts totaling $78,177 $78,177	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
2.c	five delinquent debts totaling $78,177 $78,177	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
2.d	five delinquent debts totaling $78,177 $78,177	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
2.e	five delinquent debts totaling $78,177 $78,177	Against Applicant	Unspecified Financial	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—
2.f	filed Chapter 7 bankruptcy in January 2025	Against Applicant	Bankruptcy Filing	Admitted	(a) inability to satisfy debts (c) a history of not meeting financial obligations	—	—

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

CSA) issued a Statement of Reasons (SOR) to Applicant detailing security concerns under Gu

DECISION

delines E and F. Applicant responded to the SOR on April 23, 2025 (Answer) and requested a decision on the written re

STATEMENT OF CASE

ord in lieu of a hearing. The Government’s written case was submitted on May 13, 2025. A complete copy of the file of relevant material (FORM) was provided to Applicant, who was afforded an opportunity to file objections and submit material to refute, extenuate, or mitigate the security concerns. Applicant received the FORM on May 20, 2025, and she did not respond. The case was assigned to me on April 9, 2026. The Government exhibits included in the FORM (Items 2-8) are admitted in evidence without objection.

Findings of Fact The SOR alleges Applicant falsified material facts on her May 2024 security clea

FINDINGS OF FACT

ance application (SCA) by not reporting her delinquent debts (SOR ¶ 1.a); that she has five delinquent debts totaling $78,177 (SOR ¶¶ 2.a-2.e); and that she filed Chapter 7 bankruptcy in January 2025 (SOR ¶ 2.f). She admitted all the allegations with explanations and provided documentation showing her bankruptcy was discharged. Based on my review of the pleadings and evidence submitted, I make the following additional findings of fact. Applicant is 39 years old. She graduated high school in 2005. She has never married but has a cohabitant and one minor child. She was on maternity leave from June to September 2023, when she decided not to return to her employer. Although she reported being unemployed from March to April 2024, it appears her period of unemployment likely started after she chose not to return to work in September 2023. She has worked for her current employer since April 2024. (Items 2-4) On her May 2024 SCA, she answered “No” to a set of questions under Section 26 – Financial Record, which asked questions regarding delinquencies involving routine accounts. This section included questions such as whether, in the last seven years, she had any bills or debts turned over to a collection agency or any accounts or credit cards suspended, charged off, or cancelled for failing to pay as agreed. Her May 2024 credit bureau report reflects all the delinquent debts alleged in SOR ¶¶ 2.a-2.d. (Items 2, 6) Applicant had a background subject interview (SI) with a government investigator in August 2024. She told the investigator that, within the last seven years, she had not had any accounts sent to collection, been 120 days delinquent on any debt, nor was she currently delinquent on any debt. She had to be confronted with the accounts listed on SOR ¶¶ 2.a-2.d, all of which she recognized. She stated SOR ¶¶ 2.a-2.bwere personal loans used for home improvements. She explained that she fell behind on them due to high interest rates. She stated SOR ¶¶ 2.c-2.dwere credit cards used for daily expenses. They accumulated high balances which she could not afford due to a lack of income and high interest rates. (Items 3, 4) In her SI, Applicant explained that she did not list the accounts on her SCA because she was embarrassed and did not want her employer to find out. She also did not admit them to the investigator when questioned

POLICIES

because she did not think the investigator was aware of the debts. She admitted that she “omitted and tried to conceal these accounts” but after being confronted, she “accepts her faults” and said she would attempt to settle her debts as soon as possible. She told the investigator that she had spoken with a debt consolidation service and was considering filing for bankruptcy. (Items 3, 4) In her January 2025 response to Government interrogatories, Applicant reported that she had not paid any of her delinquent debts. She explained that they became 2

delinquent when she enrolled them in a debt consolidation program and was told to stop paying them so the program could negotiate with the creditors. While unemployed after giving birth to her daughter, she fell behind on the payments to the program. She did not provide documentation of the program or the advice. She attached an unsigned agreement for legal services from a bankruptcy attorney who she said was helping her file a Chapter 7 bankruptcy petition. (Item 5) Applicant filed for Chapter 7 bankruptcy on January 9, 2025, with approximately $78,248 in unsecured claims. SOR ¶¶ 2.a-2.e are all listed on the petition, along with one smaller debt, as creditors who have unsecured claims. Her monthly net income is calculated to be $3.34. She received credit counseling on January 9, 2025, from her bankruptcy attorney. (Items 7-8) In her Answer, Applicant admitted the falsification allegation but stated it was “not intentional” and that she was “embarrassed to disclose that.” Regarding her debts,

ANALYSIS

she reported that her bankruptcy was discharged on April 23, 2025, and she provided the discharge order. Policies This case is adjudicated under Executive Order 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) implemented by the DOD on June 8, 2017. “[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 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 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 3

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, 484 U.S. at 531. “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. See 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, 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 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, 484 U.S. at 531. Analysis Guideline E, Personal Conduct The security concern under this guideline is set out in AG ¶ 15: Conduct involving questionable judgment, lack of candor, dishonesty, or unwillingness to comply with rules and regulations can raise questions about an individual's reliability, trustworthiness, and ability to protect classified or sensitive information. Of special interest is any failure to cooperate or provide truthful and candid answers during national security investigative or adjudicative processes. . . . 4

The following disqualifying conditions are relevant to this case: AG ¶16(a): deliberate omission, concealment, or falsification of relevant facts from any personnel security questionnaire, personal history statement, or similar form used to conduct investigations, determine employment qualifications, award benefits or status, determine national security eligibility or trustworthiness, or award fiduciary responsibilities; and (b) deliberately providing false or misleading information; or concealing or omitting information, concerning relevant facts to an employer, investigator, security official, competent medical or mental health professional involved in making a recommendation r elevant to a national security eligibility determination, or other official government representative; Applicant deliberately failed to disclose her delinquent debts on her SCA and in her SI. Her explanation that it was “not intentional” is inconsistent with her admission in her SI, and repeated in her Answer, that she intentionally omitted the accounts because she was embarrassed. She stated in the SI that she did not want her employer to find out and she tried to conceal them because she did not think the investigator was aware of them. AG ¶¶16(a) and (b) are established. The following mitigating conditions are relevant: AG ¶ 17(a): the individual made prompt, good-faith efforts to correct the omission, concealment, or falsification before being confronted with the facts; and AG ¶ 17(c): the offense is so minor, or so much time has passed, or the behavior is so infrequent, or it happened under such unique circumstances that it is unlikely to recur and does not cast doubt on the individual’s reliability, trustworthiness, or good judgment. AG ¶ 17(a) is not established. Applicant did not attempt to correct this omission and had to be confronted with information that the interviewer had during the SI. AG ¶ 17(c) is not established. Applicant’s deliberate falsification of material facts on her SCA was re

ANALYSIS

ged on April 23, 2025, and she provided the discharge order. Policies This case is adjudicated under Executive Order 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) implemented by the DOD on June 8, 2017. “[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 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 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 3

possible risk that the applicant may deliberately or inadvertently fail to safeguard classified information. Such decisions entail a certain degree of legally permissibl

ANALYSIS

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, 484 U.S. at 531. “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. See 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, 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 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, 484 U.S. at 531. Analysis Guideline E, Personal Conduct The security concern under this guideline is set out in AG ¶ 15: Conduct involving questionable judgment, lack of candor, dishonesty, or unwillingness to comply with rules and regulations can raise questions about an individual's reliability, trustworthiness, and ability to protect classified or sensitive information. Of special interest is any failure to cooperate or provide truthful and candid answers during national security investigative or adjudicative processes. . . . 4

The following disqualifying conditions are relevant to this case: AG ¶16

WHOLE PERSON CONCEPT

a): deliberate omission, concealment, or falsification of relevant facts from any personnel security questionnaire, personal history statement, or similar form used to conduct investigations, determine employment qualifications, award benefits or status, determine national security eligibility or trustworthiness, or award fiduciary responsibilities; and (b) deliberately providing false or misleading information; or concealing or omitting information, concerning relevant facts to an employer, investigator, security official, competent medical or mental health professional involved in making a recommendation r elevant to a national security eligibility determination, or other official government representative; Applicant deliberately failed to disclose her delinquent debts on her SCA and in her SI. Her explanation that it was “not intentional” is inconsistent with her admission in her SI, and repeated in her Answer, that she intentionally omitted the accounts because she was embarrassed. She stated in the SI that she did not want her employer to find out and she tried to conceal them because she did not think the investigator was aware of them. AG ¶¶16(a) and (b) are established. The following mitigating conditions are relevant: AG ¶ 17(a): the individual made prompt, good-faith efforts to correct the omission, concealment, or falsification before being confronted with the facts; and AG ¶ 17(c): the offense is so minor, or so much t

FORMAL FINDINGS

ent, it was repeated in the SI, and it did not occur under unique circumstances. It is not minor, because it undermined the integrity of the adjudication of her SCA. Falsification of an SCA “strikes at the heart of the security clearance process.” ISCR Case No. 09-01652 (App. Bd. Aug. 8, 2011). Guideline F, Financial Considerations The concern under this guideline is set out in AG ¶ 18: 5

Failure to live within one’s means, satisfy debts, and meet financial obligatio

CONCLUSION

smay indicate poor self-control, lack of judgment, or unwillingness to abide by rules and regulations, all of which can raise questions about an individual’s r