PSH-14-0089

*The original of this document contains information which is subject to
withholding from disclosure under 5 U.S. C. § 552. Such material has been
deleted from this copy and replaced with XXXXXX’s.
United States Department of Energy
Office of Hearings and Appeals
In the Matter of: Personnel Security Hearing )
)
Filing Date: September 19, 2014 ) Case No. PSH-14-0089
)
_________________________________________ )
Issued: February 4, 2015
__________________________
Administrative Judge Decision
__________________________
Diane DeMoura, Administrative Judge:
This Decision concerns the eligibility of XXXXXXXXXX (“the Individual”) to hold an access
authorization under the Department of Energy (DOE) regulations set forth at 10 C.F.R. Part 710,
Subpart A, entitled “General Criteria and Procedures for Determining Eligibility for Access to
Classified Matter or Special Nuclear Material.”1 For the reasons detailed below, after carefully
considering the record before me in light of the applicable regulations and the Adjudicative
Guidelines, I find that the DOE should not restore the Individual’s suspended access
authorization at this time.
I. BACKGROUND
The Individual is a DOE contractor employee who participated in the DOE’s Human Reliability
Program (HRP),2 and currently holds a suspended DOE access authorization. DOE Exhibit
(“Ex.”) 3. In January 2014, a coworker filed an incident report that raised concerns regarding the
Individual’s mental state. DOE Ex. 10; see also DOE Exs. 8, 9. As a result, the agency
suspended the Individual’s HRP certification and the Local Security Office (LSO) requested that
1 Access authorization, also known as a security clearance, is an administrative determination that an individual is
eligible for access to classified matter or special nuclear material. 10 C.F.R. § 710.5.
2 The Human Reliability Program is a security and safety reliability program designed to ensure that individuals who
occupy positions affording access to certain materials, nuclear explosive devices, facilities, and programs, meet the
highest standards of reliability and physical and mental suitability. See 10 C.F.R. § 712.1.
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the Individual participate in a March 2014 Personnel Security Interview (PSI). DOE Ex. 12. In
April 2014, the HRP’s consultant-psychiatrist (“the HRP psychiatrist”) evaluated the Individual
in connection with his HRP certification. DOE Ex. 14. In addition, the LSO referred the
Individual to a DOE consultant-psychologist (“the DOE psychologist”) for an evaluation, which
took place in May 2014. DOE Ex. 7. In July 2014, the LSO informed the Individual that there
existed derogatory information that raised security concerns under 10 C.F.R. §§ 710.8(h), (j)
(Criteria H and J, respectively).3 See DOE Ex. 1 (Notification Letter, July 30, 2014).
The Individual requested a hearing on this matter. DOE Ex. 2. The LSO forwarded his request
to the Office of Hearings and Appeals, and I was appointed the Administrative Judge. At the
hearing, the Individual, represented by counsel, testified on his own behalf. In addition, the
Individual submitted three exhibits into the record (Indiv. Exs. A-C). The DOE counsel
presented the testimony of the DOE psychologist, and tendered fourteen exhibits (DOE Exs. 1-
14). See Transcript of Hearing, Case No. PSH-14-0089 (hereinafter cited as “Tr.”).
II. REGULATORY STANDARD
The regulations governing the Individual’s eligibility for access authorization are set forth at
10 C.F.R. Part 710, “Criteria and Procedures for Determining Eligibility for Access to Classified
Matter or Special Nuclear Material.” The regulations identify certain types of derogatory
information that may raise a question concerning an individual’s access authorization eligibility.
10 C.F.R. § 710.10(a). Once a security concern is raised, the individual has the burden of
bringing forward sufficient evidence to resolve the concern.
In determining whether an individual has resolved a security concern, the Administrative Judge
considers relevant factors, including “the nature, extent, and seriousness of the conduct; the
circumstances surrounding the conduct, to include knowledgeable participation; the frequency
and recency of the conduct; the age and maturity of the individual at the time of the conduct; the
voluntariness of participation; the absence or presence of rehabilitation or reformation and other
pertinent behavioral changes; the motivation for the conduct; the potential for pressure, coercion,
exploitation, or duress; the likelihood of continuation or recurrence; and other relevant and
material factors,” and the impact of the foregoing on the relevant security concerns. 10 C.F.R.
§ 710.7(c). In considering these factors, the Administrative Judge also consults adjudicative
guidelines that set forth a more comprehensive listing of relevant factors and considerations. See
Revised Adjudicative Guidelines for Determining Eligibility for Access to Classified
Information (issued on December 29, 2005 by the Assistant to the President for National
Security Affairs, The White House) (Adjudicative Guidelines).
Ultimately, the decision concerning eligibility is “a comprehensive, common-sense judgment
made after consideration of all relevant information, favorable and unfavorable . . . .” 10 C.F.R.
3 Criterion H concerns information that a person has “an illness or mental condition of a nature which, in the opinion
of a board-certified psychiatrist, other licensed physician or a licensed clinical psychologist causes, or may cause, a
significant defect in judgment or reliability.” 10 C.F.R. § 710.8(h). Criterion J relates to conduct indicating that the
Individual has “been, or is, a user of alcohol habitually to excess, or has been diagnosed by a psychiatrist or a
licensed clinical psychologist as alcohol dependent or as suffering from alcohol abuse.” 10 C.F.R. § 710.8(j).
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§ 710.7(a). In order to reach a decision favorable to the individual, the Administrative Judge
must find that “the grant or restoration of access authorization to the individual will not endanger
the common defense and security and is clearly consistent with the national interest.” 10 C.F.R.
§ 710.27(a). “Any doubt as to an individual’s access authorization eligibility shall be resolved in
favor of the national security.” Id. See generally Dep’t of the Navy v. Egan, 484 U.S. 518, 531
(1988) (the “clearly consistent with the interests of national security” test indicates that “security
clearance determinations should err, if they must, on the side of denials”).
III. DEROGATORY INFORMATION AND ASSOCIATED SECURITY CONCERNS
As stated above, the LSO issued a Notification Letter informing the Individual that the DOE
possessed derogatory information which raised doubts regarding his continued eligibility to hold
a DOE access authorization. According to the Notification Letter, this information raises
security concerns under Criteria H and J of the Part 710 regulations. DOE Ex. 1. As a basis for
its Criterion H concerns, the LSO cited the DOE psychologist’s opinion that the Individual meets
the diagnostic criteria for Other Specified Personality Disorder and Alcohol Use Disorder, which
are illnesses or mental conditions which cause, or may cause, a significant defect in his judgment
or reliability. Id. In support of its Criterion J concerns, the LSO cited the following information
regarding the Individual’s alcohol use: (1) the Individual’s self-reported pattern of excessive
alcohol consumption between 2010 and 2012; (2) the Individual’s admission that he discontinued
his participation in the Alcoholics Anonymous (AA) program in 2013, after participating for
approximately eight to ten months, because he “did not like to be told what to do in regards to his
sobriety;” and (3) the opinion of the DOE psychologist that the Individual is, or has been, a user
of alcohol habitually to excess. Id.
It is well-settled that certain mental conditions “can impair judgment, reliability, or
trustworthiness,” and that the diagnosis of such a condition by a duly qualified mental health
professional may raise security concerns. Adjudicative Guidelines, Guideline I, ¶ 27. Similarly,
there is no question that the excessive use of alcohol raises security concerns because “excessive
alcohol consumption often leads to the exercise of questionable judgment or the failure to control
impulses, and can raise questions about an individual’s reliability and trustworthiness.” Id.,
Guideline G, ¶ 21. In light of the DOE psychologist’s diagnoses of the Individual with Other
Specified Personality Disorder and Alcohol Use Disorder, his opinion that the Individual is, or
has been, a user of alcohol habitually to excess, as well as the Individual’s own statements
regarding his alcohol use, I find that the LSO properly invoked Criteria H and J in this case.
IV. FINDINGS OF FACT AND ANALYSIS
In making a determination regarding the Individual’s eligibility for DOE access authorization, I
have thoroughly considered the record in this proceeding, including the hearing testimony and
the documentary evidence. For the reasons set forth below, I cannot conclude that restoring the
Individual’s suspended DOE access authorization “will not endanger the common defense and
security, and is clearly consistent with national interest.” 10 C.F.R. § 710.7(a).
A. Criterion H –Illness or Mental Condition
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The Individual has a history of depression, marked by recurrent suicidal thoughts, which spans
over 30 years. Tr. at 18-20. However, he was not formally diagnosed with a mental condition
until 2007 when his marriage counselor suggested to the Individual that he may be “clinically
depressed” and should consult with a psychiatrist concerning his psychological condition.4 DOE
Ex. 14 at 9. The Individual met with a psychiatrist, who diagnosed him with depression and
prescribed appropriate medications. Id.; Tr. at 34-35. He also began meeting with a counselor
on a weekly basis for individual therapy sessions. Tr. at 23-24.
In late 2011, following several years of marital problems, the Individual entered into a
relationship with a married coworker. DOE Ex. 14 at 7. The Individual and his wife separated
in early 2012, and they finalized their divorce in March 2013. Tr. at 14; DOE Ex. 14 at 7.
Around the time that the Individual and his wife separated, in April or May of 2012, the
Individual’s coworker also discontinued their relationship.5 DOE Ex. 14 at 7. The Individual
had difficulty coping with the end of his relationship with his coworker; however, he did
ultimately begin a new relationship in September 2013. Id. at 8; Tr. at 32. Nonetheless, in
January 2014, the Individual observed the coworker with another male coworker and became
depressed. DOE Exs. 7 at 4, 12 at 9-12. The incident prompted the Individual to prepare his will
and ask another coworker to be the executor of his estate. DOE Ex. 12 at 7-8, 12. Fearing that
the Individual intended to harm himself, this coworker filed an incident report notifying their
employer of her concerns. DOE Ex. 10.
In her May 2014 evaluation report, the HRP psychiatrist diagnosed the Individual with Persistent
Depressive Disorder. DOE Ex. 14 at 17, 18-19. She based this diagnosis on the Individual’s
“acknowledged symptoms of insomnia, low self-esteem, feelings of hopelessness in the form of
sustained pessimism, decreased interest in social activities, implied sense of being overwhelmed
or out of control . . . .” Id. at 17. In addition, the HRP psychiatrist noted that the Individual’s
demeanor and statements during the evaluation “provided clues to long-term personality
dysfunction . . . .” Id. Ultimately, the HRP psychiatrist concluded that the Individual exhibited
traits which meet the criteria for “borderline personality disorder and other traits that are
significant but do not meet full criteria for the specific disorder.” Id. at 18.
The DOE psychologist’s evaluation of the Individual largely echoed the findings of the HRP
psychiatrist. In his May 2014 report, the DOE psychologist noted that the Individual’s history of
depression “has been long-standing and unremitting,” despite the treatment that the Individual
has undergone over the years. DOE Ex. 7 at 7. In addition, the DOE psychologist indicated that
the Individual displayed “signs of a personality disorder marked by a pervasive pattern of
instability or interpersonal relationships and mood.” Id. at 8. According to the DOE
psychologist, based on the Individual’s “instability, volatility, suicidality, and ample evidence of
4 After experiencing marital difficulty over several years, the Individual and his wife sought marriage counseling in
2007. Id. at 7, 12.
5 There is disagreement in the record regarding the nature of the relationship. The Individual has described the
relationship as an “intense,” albeit not physical affair. DOE Ex. 7 at 4. The coworker disagreed. She stated that she
and the Individual confided in one another regarding difficulties in their respective marriages and became closer
than they should have and things “got out of hand.” See DOE Ex. 9. Although the coworker did not testify at the
hearing, in a written statement dated January 17, 2014, she alleged that the Individual behaved inappropriately
toward her after she discontinued their relationship. Id.
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a clinically significant distress and impairment in social and interpersonal areas,” he meets the
diagnostic criteria for Other Specified Personality Disorder. Id. Finally, the DOE psychologist
concluded that the Individual’s depression and personality disorder were illnesses or mental
conditions which cause, or may cause, a significant defect in his judgment or reliability. Id. at 7-
8.
At the hearing, the Individual acknowledged that depression has been a part of his life for many
years, “more at some times than others,” and that he has had suicidal thoughts intermittently
since he was in college. Tr. at 19-20, 34-35. According to the Individual, when things in his life
became overwhelming, he took solace in the idea of suicide as “a possible way out.” He stated
that he was “able to gain comfort” from the idea that he had “that one bit of control over [his]
life.” Id. The Individual has since learned that his suicidal thoughts were a poor coping
mechanism to which he turned in difficult times. In May 2014, the Individual attended an
intensive outpatient program (IOP) at the suggestion of his site’s Employee Assistance Program
(EAP) counselor. Tr. at 16-17; see also Indiv. Ex. B. While the focus of the IOP was primarily
on alcohol-related issues, the Individual found the program helpful in addressing issues
pertaining to his depression. According to the Individual, he found the IOP beneficial because
the program made him aware that his coping skills “were non-existent or self-destructive.” Tr. at
18. Describing the group sessions in the IOP as “very enlightening,” the Individual stated that he
has learned not to avoid difficult situations and is now better able to communicate. Tr. at 20-21.
The Individual testified that he continues to take his anti-depressant medications, and he sees his
psychiatrist every six months for medication management. Tr. at 42. He also continues meeting
with a counselor for individual therapy and attends the IOP aftercare sessions. Tr. at 43-44;
Indiv. Ex. B. The Individual has noticed improvement in his day-to-day life. He stated that he
can still “get down,” but he does not resort to planning or threatening suicide as a coping
mechanism anymore. Tr. at 35. He further stated that he “no longer cope[s] by disappearing
back into [his] mind and using that to avoid the situation at hand.” Tr. at 33-34. Finally, the
Individual, who has been in a stable relationship since September 2013, noted that his
relationship has benefitted from his willingness to communicate and be honest with his partner,
rather than to avoid difficult situations. Tr. at 30, 33.
After listening to the Individual’s testimony at the hearing, the DOE psychologist did not change
the findings or opinions contained in his May 2014 report. Tr. at 72-73. The DOE psychologist
noted that personality disorders are among “the more difficult kinds of issues to treat.” Tr. at
104. He testified that, as of the hearing, the Individual had not yet made “significant progress” in
treating his psychological conditions. Tr. at 72. The DOE psychologist concluded that the
Individual should continue to undergo “regular, routine” and “protracted” treatment focused on
his personality and “characterological” issues, separate from any treatment of his alcohol-related
condition. Tr. at 104, 107.
Among the factors that may serve to mitigate security concerns raised by the diagnosis of
illnesses or mental conditions which cause, or may cause, significant defects in judgment or
reliability, such as the Individual’s psychological conditions in this case, the Adjudicative
Guidelines identify the following possible mitigating factors: “demonstrated ongoing and
consistent compliance” with a treatment plan; voluntary participation in counseling or treatment
with a favorable prognosis by a duly qualified mental health professional; a recent opinion by a
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duly qualified mental health professional that the condition is under control “and has a low
probability of recurrence or exacerbation;” and, “no indication of a current problem.”
Adjudicative Guidelines, Guideline I, ¶ 29. In this case, two mental health professionals
diagnosed the Individual with depression and a personality disorder, conditions which may cause
a significant defect in judgment and reliability. Moreover, the DOE psychologist testified that
the Individual was in the early stages of his treatment and required a “protracted” period of
treatment for his conditions. In the absence of any medical testimony to the contrary, I am
convinced by the DOE psychologist’s testimony that the Individual continues to have an illness
or mental condition which causes, or may cause, a significant defect in his judgment or
reliability. Consequently, I find that the Individual has not sufficiently mitigated the Criterion H
concerns cited in the Notification Letter regarding his psychological conditions.
B. Criteria H and J – Excessive Alcohol Use
The Individual began consuming alcohol at age 18, when he typically “consumed [a] six-pack of
beer on a daily basis” while attending college. DOE Ex. 14 at 12. His consumption of alcohol
decreased when he began dating his former wife because she was opposed to his drinking.
During most of his marriage, the Individual typically consumed alcohol only in social settings
where his wife was not present. Id. In 2011, the Individual’s wife indicated during a marriage
counseling session that she no longer cared whether he drank alcohol. DOE Ex. 7 at 3; DOE Ex.
14 at 12. Subsequently, the Individual began drinking alcohol nightly, often drinking himself to
sleep. Id. That drinking pattern continued until May 2012, when, according to the Individual, he
began attending Alcoholics Anonymous (AA) meetings and working with a sponsor in the wake
of his separation from his wife. Tr. at 14-15.
At the hearing, the Individual asserted that he was abstinent from alcohol from August 2012 to
April 2013. Tr. at 14-15. According to the Individual, he decided to resume drinking in April
2013 because he “realized that he was not happy . . . with [AA] and the situation that [he] was
in.” Tr. at 15. The Individual continued to drink “two, three drinks a week, and maybe three or
four total on the weekend” until January 2014, when his HRP certification was suspended. Id.
Following the suspension of his HRP certification, the Individual met with the EAP counselor,
who suggested that the Individual abstain from alcohol until he met with the HRP psychiatrist.
Id. In her May 2014 report, the HRP psychiatrist opined that the Individual “recently met criteria
for Alcohol Use Disorder, Mild-Moderate.” DOE Ex. 14 at 18. She further noted that although
the Individual had recently attended AA, his participation was “short-lived and motivated by
[his] desire to get his ex-wife back. When it did not work, he stopped going to meetings.” Id. at
24. The HRP psychiatrist concluded that “in light of his other mental disorders,” the Individual’s
“risk of relapse for alcohol use disorder in the immediate foreseeable future [was] moderate to
high.” Id. After meeting with the HRP psychiatrist, the Individual resumed consuming alcohol
“at about the same rate that [he] had been previously” drinking. Tr. at 17.
After evaluating the Individual in May 2014, the DOE psychologist raised similar concerns
regarding the Individual’s alcohol consumption as those noted by the HRP psychiatrist in her
report. The DOE psychologist concluded that the Individual had a “protracted history” of
excessive alcohol use, and he noted that the Individual readily admitted that “during an almost
two-year period he was intoxicated on a daily basis.” DOE Ex. 7 at 7. In diagnosing the
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Individual with Alcohol Use Disorder, the DOE psychologist opined that the Individual’s
“reliance on excessive alcohol consumption for solace during difficult times” was of particular
concern. Id.
As noted above, in June 2014, the Individual completed an IOP in order to address his alcohol-
related condition. Tr. at 16-17; see also Indiv. Ex. B. The Individual also continued his
individual counseling sessions with the EAP counselor, resumed his participation in AA
meetings, and attended aftercare group sessions through the IOP. Tr. at 26, 47; see also Indiv.
Exs. B, C.
In “the last few weeks” prior to the hearing, despite having maintained several months of
abstinence, the Individual resumed consuming alcohol, drinking “three or four times” with his
significant other and at events with her family. Tr. at 27-28. When asked at the hearing why he
resumed drinking, the Individual testified that his decision to drink again was driven, in part, by
his desire to make a good impression on his significant other’s family at events he attended and
“not to make any waves” in the group. Tr. at 55. According to the Individual, his significant
other is supportive of his efforts not to drink. Regarding his most recent incidents of drinking,
the Individual stated that although his significant other did not dispute his decision to drink, she
did “express[] worry.”6 Tr. at 55-56. As of the date of the hearing, the Individual was uncertain
of his future intentions regarding his consumption of alcohol. Tr. at 52. When asked whether he
believed he had a problem with alcohol, the Individual vacillated in his answer. Ultimately, he
stated that alcohol “has been” a problem for him, and is currently a problem “from the fact that it
is important to DOE.” Tr. at 58-61.
After listening to all of the hearing testimony, the DOE psychologist did not change the opinions
that he offered in his May 2014 report regarding the Individual’s alcohol consumption, or his
ultimate diagnosis of Alcohol Use Disorder. Tr. at 68; see also DOE Ex. 7. The DOE
psychologist described the Individual’s decision to resume drinking – despite his repeated
participation in AA, his completion of an IOP, and the evaluations by several mental health
professionals who expressed concern regarding the Individual’s alcohol consumption – as
“troubling.” Tr. at 69, 108. The DOE psychologist stated that alcohol “cannot be a go-to coping
skill” for the Individual as it has been in the past. Tr. at 105. The psychologist added that “the
lack of [a] frank admission [by the Individual] that alcohol has been a problem” is itself
problematic in that it raises questions regarding the Individual’s insight into the impact of
alcohol on his life. Tr. at 69-70. Finally, during his testimony, the DOE psychologist did not
change his recommendation that, in order to establish rehabilitation from his alcohol-related
condition, the Individual should demonstrate at least one year of abstinence. Rather, he stated
that, as of the hearing, the Individual required additional treatment for alcohol-related condition.
Tr. at 105. In that regard, he noted that the Individual has not “ever done that for a year.” Tr. at
72.
With respect to security concerns raised by an individual’s excessive alcohol use, among the
possible mitigating factors are that “so much time has passed, or the behavior was so infrequent,
6 The Individual’s significant other did not testify at the hearing. Therefore, the Individual’s assertions regarding his
recent alcohol consumption and his significant other’s reaction to his decision to drink remain uncorroborated in the
record.
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or it happened under such unusual circumstances that it is unlikely to recur or does not cast doubt
on the individual’s current reliability, trustworthiness, or good judgment,” that “the individual
acknowledges his or her alcoholism or issues of alcohol abuse [and] provides evidence of actions
taken to overcome this problem . . .,” and that “the individual has successfully completed
inpatient or outpatient counseling or rehabilitation . . ., has demonstrated a clear and established
pattern of modified consumption or abstinence in accordance with treatment recommendations
. . . and has received a favorable prognosis by a duly qualified medical professional . . . .”
Adjudicative Guidelines, Guideline G, ¶ 23. Similarly, as indicated above, factors that may
serve to mitigate concerns raised by an individual’s mental or psychological condition include
the susceptibility of the condition to treatment, a favorable opinion by a duly qualified mental
health professional that the condition is “under control or in remission, and has a low probability
of recurrence or exacerbation,” and the absence of evidence of a “current problem.”
Adjudicative Guidelines, Guideline I, ¶ 29.
After considering the hearing testimony and evaluating the record as a whole, I am unable to find
that the Individual has mitigated the security concerns raised by his consumption of alcohol. As
an initial matter, although the Individual represented at the hearing that he had abstained from
consuming alcohol on various occasions for several months at a time, his testimony in that regard
is wholly uncorroborated in the record. Even assuming, however, that his statements regarding
his purported periods of abstinence are accurate, the Individual resumed drinking shortly before
the hearing. The Individual’s stated reason for drinking again – that he did not want to upset or
“make waves” with his significant other’s family – leaves me with doubts regarding the extent to
which the Individual is able to control his drinking, particularly in times of stress. In addition,
while the Individual established at the hearing that he has taken some positive steps to address
the concerns raised by his alcohol consumption, such as resuming his participation in AA and
completing an IOP, he appears to have done so because he believed it would reflect positively on
him and hasten the restoration of his suspended security clearance. Despite the assessments of
various mental health professionals regarding the Individual’s alcohol use, as well as his own
completion of an IOP and participation in AA, at the hearing, the Individual demonstrated a
marked lack of insight into the role alcohol that has played in his life. The Individual’s decision
to resume drinking only serves to underscore his lack of insight in this regard. Moreover, that he
resumed drinking despite his awareness of the underlying concerns related to his alcohol
consumption continues to call into question his judgment and reliability.
In the absence of any evidence to the contrary, serious doubts remain regarding the Individual’s
acceptance that his alcohol consumption is actually a problem, apart from the DOE’s concerns,
as well as the likelihood that he will continue to seek treatment for his alcohol-related condition
after the conclusion of this proceeding. Therefore, based on the evidence in the record before
me, I cannot conclude that the Individual’s alcohol-related condition is “under control” and “has
a low probability of recurrence,” or that there is “no indication of a current problem.” Id. In this
respect, I am convinced by the DOE psychologist’s testimony that the Individual has not yet
demonstrated rehabilitation or reformation from his Alcohol Use Disorder. Consequently, I find
that the Individual has not mitigated the security concerns cited under Criteria H and J regarding
his alcohol consumption.
V. CONCLUSION
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In the above analysis, I found that there was reliable information that raised substantial doubts
regarding the Individual’s eligibility for a security clearance under Criteria H and J of the Part
710 regulations. After considering all of the relevant information, favorable and unfavorable, in
a comprehensive, common-sense manner, including weighing all of the testimony and other
evidence presented at the hearing, I find that the Individual has not presented sufficient
information to resolve the cited security concerns. Therefore, I cannot conclude that restoring
the Individual’s suspended DOE access authorization “will not endanger the common defense
and security is clearly consistent with the national interest.” 10 C.F.R. § 710.7(a). Accordingly,
I find that the DOE should not restore the Individual’s suspended DOE access authorization at
this time.
The parties may seek review of this Decision by an Appeal Panel, under the regulation set forth
at 10 C.F.R. § 710.28.
Diane DeMoura
Administrative Judge
Office of Hearings and Appeals
Date: February 4, 2015