PSH-25-0192

*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: August 20, 2025 ) Case No.: PSH-25-0192
)
__________________________________________)
Issued: March 13, 2026
___________________________
Administrative Judge Decision
___________________________
Noorassa A. Rahimzadeh, Administrative Judge:
This Decision concerns the eligibility of XXXXXXXXXXXX (the Individual) to hold an access
authorization under the United States Department of Energy’s (DOE) regulations, set forth at 10
C.F.R. Part 710, “Procedures for Determining Eligibility for Access to Classified Matter and
Special Nuclear Material or Eligibility to Hold a Sensitive Position.”1 As discussed below, after
carefully considering the record before me in light of the relevant regulations and the National
Security Adjudicative Guidelines for Determining Eligibility for Access to Classified Information
or Eligibility to Hold a Sensitive Position (June 8, 2017) (Adjudicative Guidelines), I conclude
that the Individual’s access authorization should not be restored.
I. Background
In January 2025, the Individual’s supervisor escorted her to her employer’s Occupational Medicine
(Occ Med) office “based on observations of a heightened level of anxiety and some unusual
thoughts.” Exhibit (Ex.) 9 at 35.2 The Individual had endorsed the “belief that a ‘black ops’ group
had stolen and infiltrated her personal and professional devices.” Id. Pursuant to her employer’s
policies, the Individual’s “professional devices were scanned” and it was determined that they
were “clean.” Id. Occ Med decided that the Individual was in need of an immediate evaluation,
and she was accordingly referred to an emergency room. Id. Occ Med determined that the
Individual was “‘not fit for duty’ pending the results of the evaluation.” Id.; Ex. 8. The Individual
was soon permitted to return to work in February 2025 with some restrictions. Ex. 7 at 28; Ex. 6.
The Individual underwent a psychological evaluation at the behest of the Local Security Office
(LSO) in April 2025. Ex. 10. The psychological evaluation was conducted by a DOE-consultant
psychologist (DOE Psychologist), who issued a report (the Report) of his findings in May 2025.
1 The regulations define access authorization as “an administrative determination that an individual is eligible for access
to classified matter or is eligible for access to, or control over, special nuclear material.” 10 C.F.R. § 710.5(a). This
Decision will refer to such authorization as access authorization or security clearance.
2 The exhibits submitted by DOE were Bates numbered in the upper right corner of each page. This Decision will refer
to the Bates numbering when citing to exhibits submitted by DOE.
2
Id. In the Report, the DOE Psychologist concluded that pursuant to the Diagnostic and Statistical
Manual of Mental Disorders – Fifth Edition, Text Revision (DSM-5-TR), the Individual suffers
from Delusional Disorder, Persecutory Type, first episode, currently in acute episode. Id. at 50. He
indicated that these “[p]ersecutory delusions can lead to mistrust of others, inappropriate actions
taken to protect against perceived persecution, severe situational anxiety, and mistrust of other’s
actions.” Id. Furthermore, the Individual’s “lack of attunement with external reality, persecutory
belief set, and persistent severe anxiety impairs her judgment, reliability, stability and
trustworthiness.” Id.
The LSO began the present administrative review proceeding by issuing a letter (Notification
Letter) to the Individual in which it notified her that it possessed reliable information that created
a substantial doubt regarding her continued eligibility for access authorization. In a Summary of
Security Concerns (SSC) attached to the Notification Letter, the LSO explained that the derogatory
information raised security concerns under Guideline I (Psychological Conditions) of the
Adjudicative Guidelines. Ex. 1. The Notification Letter informed the Individual that she was
entitled to a hearing before an Administrative Judge to resolve the substantial doubt regarding her
eligibility to hold a security clearance. See 10 C.F.R. § 710.21.
The Individual requested a hearing, and the LSO forwarded the Individual’s request to the Office
of Hearings and Appeals (OHA). The Director of OHA appointed me as Administrative Judge in
this matter. At the hearing I convened pursuant to 10 C.F.R. § 710.25(d), (e), and (g), the Individual
testified on her own behalf and presented the testimony of her husband, four mental health
professionals, and three coworkers. See Transcript of Hearing, OHA Case No. PSH-25-0192
(hereinafter cited as “Tr.”) The Individual also submitted ten exhibits, marked Exhibits A through
J. The DOE Counsel submitted thirteen exhibits marked as Exhibits 1 through 13 and presented
the testimony of the DOE Psychologist.
II. Notification Letter
Under Guideline I, “[c]ertain emotional, mental, and personality conditions can impair one’s
judgment, reliability, or trustworthiness.” Adjudicative Guidelines at ¶ 27. Conditions that could
raise a security concern and may be disqualifying include “[a]n opinion by a duly qualified mental
health professional that the individual has a condition that may impair judgment, stability,
reliability, or trustworthiness.” Id. at ¶ 28(b).
Under Guideline I, the LSO alleged that following the April 2025 psychological examination, the
DOE Psychologist concluded that the Individual met sufficient diagnostic criteria for a diagnosis
of Delusional Disorder, Persecutorial Type, first episode, in acute episode, which impaired the
Individual’s trustworthiness, stability, reliability and judgment. Ex. 1 at 5. The LSO’s invocation
of Guideline I is justified.
III. Regulatory Standards
A DOE administrative review proceeding under Part 710 requires me, as the Administrative Judge,
to issue a decision that reflects my comprehensive, common-sense judgment, made after
consideration of all the relevant evidence, favorable and unfavorable, as to whether the granting
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or continuation of a person’s access authorization will not endanger the common defense and
security and is clearly consistent with the national interest. 10 C.F.R. § 710.7(a). The regulatory
standard implies that there is a presumption against granting or restoring a security clearance. See
Department of Navy v. Egan, 484 U.S. 518, 531 (1988) (“clearly consistent with the national
interest” standard for granting security clearances indicates “that security determinations should
err, if they must, on the side of denials”); Dorfmont v. Brown, 913 F.2d 1399, 1403 (9th Cir. 1990)
(strong presumption against the issuance of a security clearance).
The individual must come forward at the hearing with evidence to convince the DOE that granting
or restoring access authorization “will not endanger the common defense and security and will be
clearly consistent with the national interest.” 10 C.F.R. § 710.27(d). The individual is afforded a
full opportunity to present evidence supporting his eligibility for an access authorization. The Part
710 regulations are drafted so as to permit the introduction of a very broad range of evidence at
personnel security hearings. Even appropriate hearsay evidence may be admitted. Id. § 710.26(h).
Hence, an individual is afforded the utmost latitude in the presentation of evidence to mitigate the
security concerns at issue.
IV. Findings of Fact and Hearing Testimony
Precipitating Event and Security Incident
In early January 2025, the Individual was on vacation with her family, during which they utilized
a rental car.3 Ex. 11 at 41. While the car was parked at a meter on the side of the street, unattended,
it was “burglarized in a ‘smash-and-grab’ incident.” Id. The family’s electronics and luggage were
taken. Id. The Individual’s husband testified that prior to returning to the rental car, he received “a
telephone call that somebody had found [his] backpack that [he] had left in [his] car on some
adjacent street[.]” Tr. at 18. He indicated that he found this telephone call strange, and he did not
completely understand what was happening at the time. Id. A police report of the incident indicates
that the family returned to their car after approximately one hour and observed that the rear
passenger window had been broken. Ex. B at 8.4 They were approached by an individual, who told
them that he had taken photographs of the incident, and provided the photographs to the Individual
and her family. Id. “At some point between finding the police station and writing the [police]
report,” they received another communication from a different individual who explained to the
family that she had seen their luggage on the street. Id.; Tr. at 20–21. After completing the police
report, they followed the location pin that the individual had texted them and were thus able to
locate their belongings. Tr. at 21. Four personal tablets and a camera had been stolen.5 Id. at 21,
185. Among the stolen items were passwords and usernames that the Individual and her husband
had written down. Ex. 10 at 41; Tr. at 218. The Individual’s husband explained that as they were
looking through their items on the side of the road, they were approached by a woman who gave
them their passports and medications in a Ziploc baggie. Tr. at 21–22. He said that the woman
3 The Individual received training for counterintelligence awareness the week she went on vacation. Tr. at 184.
4 The exhibits submitted by the Individual were not page numbered. This Decision will refer to the PDF page number
when citing to the Individual’s exhibits.
5 The Individual’s husband explained that they used the “find my device” feature to locate their tablets. Tr. at 24, 41.
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explained to the family that she decided to “save” these items when she saw others going through
the family’s belongings. Id. at 22.
The Individual indicated that she was not initially concerned about the possibility of identity theft,
but after the burglary, the Individual experienced some difficulties in securing and recovering
online accounts. Ex. 11 at 42; Tr. at 187. The Individual’s husband explained that they had to
assume that every account for which their passwords had been stolen had been compromised. Tr.
at 23. Accordingly, with the help of their friends, they began the process of securing their accounts.
Id. at 23–24, 187, 210. They learned that several of their non-financial accounts had been
compromised. Id. at 24–25. The Individual’s husband indicated that they had secured their
accounts to the best of their ability around the end of January 2025, and that they “felt comfortable
with how things were left.” Id. at 28, 40.
The Individual ultimately felt that the theft of her personal information could compromise her
professional/work devices, and she made those concerns known to her employer’s Security
Incident Team (SIT) on multiple occasions following the burglary, but before the January 2025
incident where she was escorted to Occ Med. Id. at 187–88, 220–21. The first time, she sought
guidance on the steps she should take, as her “identity had been compromised.” Id. at 219. The
second time, she reported she was receiving social media notifications and timestamps on her
emails that were inconsistent with her social media and email activity. Id. The third time, she
reported that her work cell phone was being “glitchy.”6 Id. She made all three reports to SIT over
the course of four days. Id. at 220. The Individual indicated that she was “reporting what [she was]
taught to report.”7 Id. at 188.
On the morning of the mid-January 2025 incident, the Individual experienced technical issues that
confused and concerned her. Id. at 232. Accordingly, when she went into the office, she made a
list of everything she found concerning, documenting a description of every possible incident,
which she ultimately provided the DOE Psychologist. Id. at 233. She found her supervisor and
tried to explain to him what she believed was possibly happening. Id. at 234. The Individual
generally believed that she had been a victim of a black ops group that intended to secure the
access credentials of DOE or DOE contractor employees. Ex. 10 at 42. She admitted that she was
“freaking out” because she believed she had compromised national security. Tr. at 235, 241.
The Individual agreed that at the time she was taken to Occ Med, she needed help.8 Id. at 189. The
Individual’s husband indicated that before the Individual was admitted to the emergency room,
6 A coworker testified that the Individual had told him that “she was seeing unusual activity[]” on her phone but he
felt that it could just have been her “phone failing[,]” as he does not know how savvy the Individual is when it comes
to such devices. Tr. at 61.
7 A coworker testified that their work involves keeping certain assets safe “in any scenario[] that [they] can think of.”
Tr. at 69–70. The Individual was noted to be particularly good at thinking “outside the box” and thinking of things
“that other people miss[.]” Id. He indicated that he knew that the Individual had reported the potential hacking of her
various online accounts, and he explained that it is part of their training to report such matters. Id. at 79–80.
8 Prior to going to Occ Med, the Individual had concluded that her anxiety was severe enough to warrant some leave,
and she ultimately took approximately one month of leave pursuant to the Family Medical Leave Act after her
discharge from the emergency room. Tr. at 191.
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she was “very, very stressed[.]” Id. at 26. He confirmed that while at the emergency room, the
Individual underwent an interview in the early morning hours, following her admission, and she
was released shortly thereafter. Id. at 27, 190. The Individual’s husband indicated that he had never
seen his wife behave in the manner she did over the two-week period in January that culminated
in her hospitalization and leave, and that she has not behaved in that manner since. Id. at 30. He
also stated that since January 2025, she has not discussed any of the concerns that had been
documented in the Report with him. Id. at 34.
The Individual sought treatment through her employer’s Employee Assistance Program (EAP)
from April 2025 to September 2025 and attended the seven counseling sessions she was permitted
to attend. Id. at 195–96; Ex. J. She explained that at the time she began seeing the EAP therapist,
she was not “in a high anxiety kind of frame of reference[,]” so they focused their conversations
on “what [she] looks like when [she] get[s] anxious.”9 Tr. at 197. At the behest of Occ Med, she
saw a psychiatrist who consults with the employer’s Fitness for Duty program (FFD-consultant
psychiatrist) in February 2025. Id. at 198. Before her EAP sessions ended, she began reaching out
to other psychologists around the Fourth of July in 2025. Id. at 196. She secured a therapist in early
August 2025, and at the time of the hearing, continued to see her therapist on a weekly basis. Id.
at 155, 199.
After participating in the aforementioned evaluations and therapy, the Individual testified that she
believes that her anxiety is under control. Id. at 215. When asked whether she has asked her
providers about the possibility that she met the criteria for a diagnosis of Delusional Disorder, she
responded that “[e]verybody says no.” Id. at 238.
Expert Testimony and Reports
DOE Psychologist
During her April 2025 psychological evaluation, the Individual told the DOE Psychologist that she
believed that she was a “victim of ‘black ops.’”10 Ex. 10 at 42. The Individual’s concerns began
to increase following their return home, resulting in the belief that “unknown actors have been
using, and continue to use, her allegedly compromised accounts to attempt unauthorized access to
secure [government contractor] systems and information.” Id. She “expressed her frustration that
[the contractor’s] administration did not appear to take her concerns seriously.” Id. Accordingly,
in mid-January 2025, after experiencing what she perceived were technological anomalies, she
“began disclosing her concerns to members of her workgroup and became increasingly agitated.”
9 A January 2026 letter submitted by the EAP therapist indicates that the Individual and the therapist discussed how
anxiety presents in the Individual, how to process “information and experiences,” support in “better understanding her
communication style, and . . . resources for internal and external tools to support her in navigating current stressors.”
Ex. H at 9.
10 The Individual testified that during the evaluation with the DOE Psychologist, the Individual was explaining the
security concerns that she had in January, but that she did not have the same concerns at the time of the evaluation in
April. Id. at 43–44, 213–14. She explained that in relaying the information regarding the security breaches/issues that
she believed possibly existed in January 2025, she was trying to explain to the DOE Psychologist how she came to be
in his office. Id. at 214–15.
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Id. Because of the level of distress she was exhibiting, she was ultimately escorted to Occ Med.
Id.
The Individual told the DOE Psychologist that “espionage entities may have established a
coordinated theft operation targeting individuals associated with DOE in an effort to obtain access
credentials.” Id. She stated that her personal and work cell phones, social media account, and home
phone were all compromised and being controlled by other individuals who have intercepted
messages. Id. at 42–43. She told the DOE Psychologist that someone had intentionally moved two
of her cell phones from one secure locker in a DOE facility to the locker directly above it. Id. at
43. The Individual uncovered “two years of missed phone calls, which appeared to be robocalls”
on four different phones, which she assumed were coming from India, and while researching the
matter, she concluded that “she had been hacked a year ago.” Id. She expressed suspicion of two
of the fathers of her daughter’s friends, believing that they gained access to her usernames,
passwords, and other identifiable information, and that one of the men “may have planted bugs”
in her home.11 Id. She was also suspicious of one of the men, as he “has a high-quality camera and
takes photographs when he is out in public.” Id. She further stated that photo reels spontaneously
appeared on her phone, containing pictures of her daughter playing with the children of the
aforementioned men. Id. The reels contained photos of her daughter’s eye, causing her to believe
that “an unknown operative created the reels with the intention of using the photos to initiate
transfer of and gain control of accounts that use facial recognition.”12 Id. at 43–44. The DOE
Psychologist learned that the Individual had been “staying up to catch calls that she believe[d]
were coming in from India.”13 Id. at 43. Finally, the Individual told the DOE Psychologist about
an incident of strange activity with her work computer in her workspace, but that she was
“unable to report the incident because her workgroup managers had already gone home for the
day.”14 Id. at 44.
11 The Individual’s husband stated that although his wife had spoken to him about the possibility that her daughter’s
friends’ fathers posed some security threat, as they were of foreign origin, she did not “elaborate beyond that” to him.
Tr. at 37–38. The Report indicates that the Individual had her home “scanned for bugs and none were found.” Ex. 11
at 43. At the hearing, the Individual testified that approximately three days after they got home from their vacation,
the Individual’s home internet “was acting weird,” so she called a friend, who swept her home for bugs without being
asked to do so. Id. at 226–27.
12 At the hearing, the Individual explained that the devices that were stolen contained a large catalogue of photo reels,
and the account linked to these photo reels had been compromised. Tr. at 227–28. She went back into her “archives”
and began trying to delete photos. Id. at 228. As she was deleting the photos, photo reels began “playing
spontaneously.” Id. Two back-to-back photos appeared, depicting the daughters of the foreign nationals, which the
Individual found disconcerting. Id. The photos of her daughter’s eyes were ones that she had taken when the child was
an infant. Id. at 229. She had previously learned that “there [were] problems using facial recognition and Android
phones.” Id. She felt that the individuals who stole the devices could have used these photos to create accounts via
facial recognition technology. Id. She also reported these matters in mid-January 2025. Id.
13 The Individual felt that some of the aforementioned “unauthorized activity” was perpetrated by “actors operating
from India.” Ex. 11 at 44.
14 The Individual had observed “three files open on [her] computer desktop” and her “nuclear wallet card laying on
[her] desk” Tr. at 230. The Individual explained at the hearing that she always closes documents on her desktop before
shutting down her computer. Id. at 230–31. She denied putting the nuclear wallet card on her desk. Id. at 231. The
Individual testified that these incidents occurred the day before she was escorted to Occ Med in mid-January 2025.
Id.
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The DOE Psychologist conducted a Personality Assessment Inventory (PAI), which is “a
structured personality assessment instrument.” Id. at 48. The Individual’s validity scores fell within
the normal range, indicating that the Individual “answered in a reasonably forthright manner and
did not attempt to present an unrealistic or inaccurate impression[.]”Id. At the hearing, the DOE
Psychologist testified that “a person with [D]elusional [D]isorder does not believe they have an
issue,” and accordingly, “psychological testing does not show elevations.” Tr. at 281–82.
The DOE Psychologist spoke to the FFD case manager, a mental health professional qualified to
make diagnoses, who saw the Individual when she presented to Occ Med in January 2025. Ex. 10
at 46. The FFD case manager told the DOE Psychologist that he interviewed the Individual during
the mid-January 2025 event, and that he “expressed some concern about the possibility of a
[D]elusional [D]isorder but did not have sufficient information to reach a definitive conclusion.”
Id. He found her anxiety severe enough to recommend that she admit herself into an emergency
room. Id. As the FFD case manager, he was also responsible for placing the Individual in the FFD
program and sending her for an independent evaluation with the FFD-consultant psychiatrist. Id.
The FFD case manager told the DOE Psychologist that he had seven follow-up meetings with the
Individual, and he “remains concerned about her fitness for duty.” Id.
The DOE Psychologist also spoke to the FFD-consultant psychiatrist who examined the Individual
at the behest of Occ Med. Id. at 47. He told the DOE Psychologist that “[b]ecause of the nature of
[the Individual’s] work and the likelihood of covert intelligence gathering in general, he was
willing to consider that her report of the comprises to her account were accurate.” Id. Accordingly,
“he did not diagnose her with [D]elusional [D]isorder but did not rule out the possibility.” Id. The
Report indicates that the FFD-consultant psychiatrist stated that he “had difficulty following [the
Individual’s] train of thought due to her preoccupation with minutiae, as well as her tendency
toward disorganized thinking[,]” and he ultimately concluded that she had a “high level of
anxiety.” Id.
The DOE Psychologist reached out to the EAP therapist the Individual saw on seven occasions,
who told him that the Individual “has a long history of anxiety.”15 Id. Further, she felt that it was
“difficult to follow [the Individual’s] train of thought” and the Individual was confused by the
concerns over her mental state. Id. She “noted that some of [the Individual’s] statements may be
suggestive of a [D]elusional [D]isorder and that she continues to believe that her [work] and
personal accounts are being compromised.” Id. However, the Individual’s disjointed form of
communicating had “obscure[d] the overall clinical picture.” Id.
The DOE Psychologist opined in the Report that “[t]he persistence of [the Individaul’s]
persecutory beliefs despite contradictory objective findings is indicative of a [D]elusional
[D]isorder.” Id. at 49. Further, the Individual “appears to ascribe complex, coordinated motives to
multiple unrelated individuals and events, and she interprets ambiguous technological or
environmental changes as evidence of targeted surveillance and espionage.” Id. He concluded that
the “lack of corroborating evidence, combined with the elaboration and conviction of her beleifs,
indicates that these experiences are not grounded in reality.” Id. As stated above, he accordingly
diagnosed the Individaul with Delusional Disorder, Persecutory Type, first episode, currently in
15 At the time the DOE Psychologist reached out to the EAP counselor, she had seen the Individual twice. Ex. 10 at
47.
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acute episode. Id. He noted that the condition can result in “errors of judgment” and can cause her
to distrust her coworkers. Id. The “lack of attunement with external reality and persecutory belief
set can lead to poor judgment, unreliability, psychological instability, and lack of trustworthiness.”
Id.
The DOE Psychologist testified that the way in which the Individual relayed her concerns to him
during the psychological evaluation indicated “a stronger belief system than she related in [her]
testimony.” Tr. at 282. He indicated that Delusional Disorder was not his first thought, but as “[the
Individual’s] relation of the events became more chaotic and disjointed, [he] began then to be
concerned about delusional disorder, which led [him] to become more specific in the questions
that [he] was asking.” Id. at 283. He noted that if one “take[s] any one, two, or three parts of this
story, [] they make perfect sense” based on the nature of her profession for which “the possibility
of espionage is always there.” Id. at 284. However, when the pieces of her narrative are “put
together,” “it becomes unrealistic and not consistent with external reality.” Id. He believed that the
Individual’s feeling that she was not being believed when she was reporting the aforementioned
concerns to her management “elevated her distress to the level that they were concerned.” Id. at
286–87. He testified that these concerns crossed a line into a delusion when “she [was] not able to
solve things, but new things keep happening that prevent her from generating a secure
environment.” Id. at 287. “[T]he interpretation of that [burglary] event into paranoia is what makes
it delusional.” Id. at 288.
The DOE Psychologist explained that “[D]elusional [D]isorders are based in plausible events[,]”
and that when an individual with Delusional Disorder experiences a “negative consequence for
expressing [their] delusion,” the individual either becomes “very adamant that nobody believes
them” or they learn that they cannot “tell people what [they] believe to be true[.]” Id. at 307–08.
To treat Delusional Disorder, one must take antipsychotic medication, and in the Individual’s case,
also an antianxiety medication. Id. at 289–90. Although therapy is recommended, “efficacy is poor
. . . because the person with the [D]elusional [D]isorder [does not] believe [there is] anything
wrong.” Id. at 290. Although someone with Delusional Disorder cannot be talked out of a delusion,
a therapist can help them manage the distress that the delusion causes. Id. at 291. However,
managing anxiety is not sufficient for managing Delusional Disorder. Id.
The DOE Psychologist testified that based on the information he possessed at the time he wrote
the Report in May 2025, the diagnosis of Delusional Disorder was sound, but that “it is unclear
now whether that diagnosis still applies[,]” as an individual “can achieve . . . spontaneous
remission[] from [D]elusional [D]isorder, so [it is] possible that it does not exist at this time.” Id.
at 295. He also indicated that at the time of the hearing, he could not come to a conclusion regarding
her prognosis. Id. at 295–96. When asked if the Individual has “an illness or mental condition . . .
[that] can cause or may cause a significant defect in her judgment and reliability[,]” the DOE
Psychologist stated that he did not know. Id. at 297.
Occ Med Psychologist
The Occ Med psychologist, who supervises the FFD program, testified that she was not the person
who evaluated the Individual when the Individual was escorted to Occ Med in early January 2025.
Tr. at 95, 101. She explained that they determined the Individual was not fit for duty when she
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presented to Occ Med in January 2025 because they “had significant security concerns at that
moment.” Id. at 100. She discussed the Individual and her presentation with the FFD case manager
who interviewed her, specifically touching on the fact that the Individual thought that she was
being targeted by a “black ops” group. Id. at 101. They discussed the fact that although none of
her work devices had been taken in the burglary, she believed that they had been infiltrated and
that she reported this to the DOE Office of Counterintelligence. Id. at 101–02. She became privy
to the fact that the Individual’s work devices had been scanned and “found to be clean.” Id. at 102.
The Occ Med psychologist also learned of the Individual’s concerns about the fact that her
daughter’s friends have fathers of foreign origin. Id. The aforementioned facts suggested “potential
paranoia.” Id.
She decided to send the Individual to an FFD-consultant psychiatrist for a more comprehensive
evaluation. Id. at 102, 109. She explained that the FFD-consultant psychiatrist is “really good at
differentiating between” anxiety and a more concerning diagnosis. Id. at 118. The FFD-consultant
psychiatrist informed her that he diagnosed the Individual with Anxiety Disorder and that he “did
not see any psychotic features[.]” Id. at 109–10, 121. The Occ Med psychologist recommended
that the Individual seek private counseling. Id. at 110. The FFD case manager saw the Individual
once a week in March 2025 and the Occ Med psychologist met with the Individual once, and they
determined that they were not seeing the same symptoms that they had observed in January 2025.
Id. at 111. She noted that by March 2025, the Individual’s sleep had improved, and she was taking
antianxiety medication. Id. Based on her conversations with the FFD case manager and the FFD-
consultant psychiatrist, she does not agree with the DOE Psychologist’s assessment of Delusional
Disorder, Persecutorial Type.16 Id. at 113. She also spoke to the Individual’s therapist, who the
Individual began seeing in August 2025 and who diagnosed the Individual with Adjustment
Disorder with Anxiety, with other possible diagnoses of PTSD and Autism, which the Occ Med
psychologist feels also make sense for the Individual.17 Id. at 114. The Occ Med psychologist
noted that they administered the Minnesota Multiphasic Personality Inventory (MMPI) and the
Millon Clinical Multiaxial Inventory (MCMI), which were both significant for anxiety.18 Id. at
118–19. The Occ Med psychologist explained that it is not uncommon for someone in the
Individual’s profession to be hypervigilant. Id. at 121–22. At the time of the hearing, the Occ Med
psychologist indicated that she would not have any concerns should the Individual return to work
requiring an access authorization, but that she would ask the Individual to “check in” with Occ
Med “every once in a while.” Id. at 126–27.
FFD-Consultant Psychiatrist
16 She explained that the difference between someone with anxiety and someone with delusion is that someone with
anxiety can “understand [what is] right and wrong[,]” but if someone is experiencing a delusion, they believe “this is
actually happening.” Id. at 117–18.
17 The DOE Psychologist noted in his testimony that neither a diagnosis of PTSD nor Adjustment Disorder involves
a “separation from reality[.]” Tr. at 293.
18 The DOE Psychologist spoke to the mental health professional who interpreted the results of the tests that Occ Med
administered, and she told the DOE Psychologist that the test results were “unremarkable” but that there was an
elevation “consistent with bipolar disorder with psychotic features” in the MCMI. Ex. 10 at 46. However, she
“interpreted this as indicative of [the Individual’s] high level of anxiety and fears related to the belief that her [work]
and personal accounts had been compromised.” Id. She “acknowledged concerns regarding the possibility of
[D]elusional [D]isorder[,]” but “could not reach a definitive conclusion.” Id. at 46–47.
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The FFD-consultant psychiatrist, who saw the Individual in February 2025 and did not observe
any witness testimony, began his testimony by explaining that he believes that the Individual is
“qualified to go back to work” with a security clearance. Id. at 132, 143. He did not feel that her
anxiety was “debilitating” enough to keep her from going back to work. Id. at 133. At their
interview, the Individual presented “with a significant level of anxiety,” and presented her fears of
electronic surveillance as current concerns, but he believed that she had somewhat calmed since
the January 2025 burglary. Id. at 132–33, 143. At some point after the Individual began seeing her
therapist in August 2025, the FFD-consultant psychiatrist opted to speak to the Individual’s
therapist and her therapist informed him that the Individual has some autistic tendencies and
,
“chronic [PTSD]” Id. at 133. The therapist also told him that she felt that the Individual’s “severe
anxiety reaction” in early January 2025 was “exacerbated by the PTSD[.]” Id. at 134.
He disagreed with the DOE Psychologist’s conclusion that the Individual suffers from Delusional
Disorder, because based on his observations, the Individual “was highly anxious.” Id. at 135–36.
He found the Individual’s response to be “somewhat appropriate” to the burglary, but he did feel
that “she was very, very suspicious, if not . . . feeling somewhat paranoid.” Id. at 136. He did note
that the Individual was very worried about being the target of foreign intelligence, but he did not
“find that terribly unusual” when considering that she had an access authorization. Id. When asked
whether he felt that “her fears were generally grounded in reality,” he stated, “[g]iven the
information that I had, I [could not] verify 100 percent one way or the other, I just felt like those
were possibilities that she was describing to me.” Id. at 137. He later indicated that she believed
that being targeted by foreign entities could have been a possibility. Id. He stated that he believes
the Individual “could go back to work [requiring an access authorization] and continue to be
evaluated.” Id. at 139. As the DOE Psychologist’s Report indicates that the FFD-consultant
psychiatrist could not rule out Delusional Disorder, when the FFD-consultant psychiatrist was
asked about the matter at the hearing, and he stated that based on “what [he] saw, he ruled it out.”
Id. at 142. However, he acknowledged “that someone else might interpret that as delusional.” Id.
at 142–43.
Individual’s Therapist
Treatment notes from August 2025 provided by the Individual’s therapist indicate that the
Individual was diagnosed with Adjustment Disorder with Anxiety. Ex. G at 5. The Individual’s
therapy plan is to attend 55 minutes of therapy every week, and among other goals, she intends to
learn how to use “grounding and breath protocols” in order to “self-regulate” and to “[i]ncrease
understanding of methods to recognize and self-regulate anxiety.” Id. at 5–6.
The Individual’s therapist testified that she began treating the Individual in early August 2025,
after the Individual was referred by her employer’s EAP.19 Tr. at 152. She explained that the
19 The Individual’s therapist testified that in addition to reviewing the DOE Psychologist’s Report, she reviewed a
report submitted by a psychiatrist with the Human Reliability Program (HRP). Tr. at 153. The report created by the
HRP psychiatrist was not admitted into the record. However, the Individual’s therapist testified that the HRP
psychiatrist diagnosed the Individual with Adjustment Disorder with Anxiety. Id. at 154. The record indicates that the
report was produced by the HRP psychiatrist in July 2025. Id. at 260.
11
Individual described a “distressing” burglary incident, which the Individual found distressing not
only because it could affect her family, but also affect her work, as she felt that she had been
hacked. Id. at 153. She compared the information that the Individual gave her with the information
the Individual provided the DOE Psychologist, and noted that it was the same, “absolutely
precise.” Id. at 154–55. She explained that she gave the Individual “time to describe what it was
she wanted [her] to know,” allowing her to “relax, calm down, to trust the environment that she
was in, and she became much more coherent.” Id. at 156. They also covered the Individual’s past
traumas and the possibility of being autistic. Id. However, at the time of the hearing, the therapist
was primarily treating the Individual for Adjustment Disorder with Anxiety. Id. at 157. She
indicated that the Individual is “making good progress,” that she has moved through therapy more
quickly than other patients, and that she has the ability to understand “how her thought processes
can be distorted.” Id. at 157–59. She does not see any issue with the Individual returning to work
that requires access authorization, so long as she is compliant with her medications. Id. at 158–59.
The Individual’s therapist noted that the Individual was “diligent in looking for help” and that
“[s]he knew she needed help.” Id. at 160. She indicated that the Individual’s ongoing anxiety is
related to the hearing process. Id. The Individual’s therapist opined that the Individual’s “level of
anxiety has significantly reduced” since the January 2025 incident. Id. at 168. The Individual
manages her anxiety by journaling, taking walks, and doing breath work, in addition to antianxiety
and sleep medication. Id. at 171–72.
The Individual’s therapist disagreed with the DOE Psychologist’s diagnosis, stating that the result
of the testing the DOE Psychologist completed was unremarkable, and that she does not see any
evidence of Delusional Disorder while the Individual is in her office.20 Id. at 161–62. The
Individual’s therapist explained that if the Individual was delusional, then the behavior the
Individual exhibited in mid-January 2025 would have “surfaced” earlier, as it would have been an
“an ongoing process, an ongoing response to stressors[.]” Id. at 161. The Individual’s therapist
acknowledged the Individual “was putting together many disparate experiences and . . . coming
to a conclusion[,]” but stated that the Individual “is not unlike many of the patients that [she] works
with from” the Individual’s place of employment, “because [they are] trained in threat
assessment.” Id. at 165. Accordingly, they “look at the world differently[.]” Id. When asked if the
Individual still believes that she is being targeted, the Individual’s therapist stated that although
the Individual “mentioned it” when they began their relationship in August 2025, “they barely
even touched on it.” Id. at 166. She went on to state that she believes the matter was “resolved . .
. in her mind.”21 Id. She stated that although the Individual “still has some concerns about the
safety of her family . . . [she is] not highly stressed about that any longer.” Id. at 166–67.
Individual’s Expert
The Individual underwent another psychological evaluation in August 2025 with a psychologist
she retained to offer an opinion for this hearing. Ex. H; Tr. at 247. The Individual’s expert produced
a two-page report in January 2026. Ex. H. She reviewed the Individual’s medical/mental health
20 The Individual’s therapist explained that she has had experience with clients exhibiting symptoms of Delusional
Disorder. Tr. at 164.
21 She also explained that because the Individual felt that others did not understand her concerns, she became frustrated,
causing her to become “activated.”. Tr. at 170.
12
history and conducted an interview. Id. In her report, she concluded that the Individual suffered an
“isolated, unique extreme situational anxiety reaction closely related to her job duties.” Id. at 7.
She opined that because the Individual must think “outside the box” pertaining to safety and
security, she is hypervigilant. Id. She concluded that because this incident was the first of its kind
“over her long career, there should be little likelihood of any [recurrence] of such event.” Id. She
described the incident as a “situational anxiety” incident, and not indicative of a delusion. Id.
In her hearing testimony, the Individual’s expert indicated that she examined the DOE
Psychologist’s Report, consulted with the Individual’s therapist the week before the hearing, and
examined the report created by the HRP psychiatrist. Tr. at 249, 272. She diagnosed the Individual
with Adjustment Disorder with anxious features. Id.
She also suggested that as the Individual is “extremely intelligent,” it may be difficult for others
to “really understand [her,]” as they “may find it confusing.” Id. at 251. The expert specifically
noted that the Individual “was very anxious about the theft of national security materials, and she
had an intense anxiety response to it.”22 Id. at 255. In explaining her disagreement with the DOE
Psychologist’s diagnosis, she testified that it would be unusual for the Individual to have an acute
episode that lasted approximately four months, as “acute” means that it is occurring “right now.”
Id. at 251–52. When she saw the Individual, the Individual “had calmed down a lot.” Id. at 252.
She believes that the treatment the Individual is receiving from her therapist is appropriate, and
that it may prevent another “anxiety/panic attack” like the one the Individual experienced in
January 2025. Id. at 253. The expert also opined that the Individual is in touch with reality and that
the Individual does not suffer from Delusional Disorder. Id. at 256–57. The expert indicated that
the Individual likely suffered a panic attack on the day of the burglary and another one at work in
mid-January 2025. Id. at 269. She opined that the Individual’s prognosis is “very good[,]” as she
is “coming through it” and will be “better able to cope with her own fears and anxieties.” Id. at
258. She recommended ongoing treatment for anxiety, asserted that it is readily controllable with
appropriate treatment, and opined that there is no current problem. Id. at 276–77.
V. Analysis
The Adjudicative Guidelines indicate that an individual may mitigate Guideline I concerns if:
a) The identified condition is readily controllable with treatment, and the individual
has demonstrated ongoing and consistent compliance with the treatment plan;
b) The individual has voluntarily entered a counseling or treatment program for a
condition that is amenable to treatment, and the individual is currently receiving
counseling or treatment with a favorable prognosis by a duly qualified mental
health professional;
22 In later testimony, she stated that the Individual “was a victim of theft, and [it] just happened to be national security
material.” Tr. at 256. When asked what was compromised, the Individual’s expert indicated that “[t]here were some
laptop computers . . . and . . . some folders they [sic] had material . . . in” them but that she “[did not] ask her in
specific details” because she “[did not] need to know it at that level.” Id. at 260–61. She further concluded that the
Individual responded the way in which she did in mid-January 2025, because she “thought that the response of her
superiors was inadequate[,]” and that her “paranoia . . . kind of rippled out from that central point.” Id. at 264. She
indicated that a delusion is a “fixed false belief,” and she does not believe that the Individual was delusional when she
was upset about the burglary, as it involved “national security secrets.” Id.
13
c) Recent opinion by a duly qualified mental health professional employed by, or
acceptable to and approved by, the U.S. Government that an individual’s previous
condition is under control or in remission, and has a low probability of recurrence
or exacerbation;23
d) The past psychological/psychiatric condition was temporary, the situation has been
resolved, and the individual no longer shows indications of emotional instability;
e) There is no indication of a current problem.
Adjudicative Guidelines at ¶ 29.
As stated above, the regulatory standard implies that there is a presumption against granting or
restoring a security clearance, and there are facts about this case that give me pause. While it is
within the realm of possibility that nefarious groups with nefarious intentions would target access
authorization holders, the details that the Individual provided to the DOE Psychologist concern
me. For instance, following the burglary, the Individual came to suspect the fathers of her
daughter’s friends, both of whom were of foreign origin, and believed that there was some
involvement from “scam callers” in India. I was not given a convincing reason as to why she began
suspecting these men or the scam callers. For instance, the DOE Psychologist’s Report indicates
that one father used a camera to take pictures and would do so in public. There is, of course, a very
simple explanation for such behavior that does not include espionage or some other covert
operation. It is also concerning that she drew a direct line between the January 2025 burglary and
seemingly unrelated events, like receiving scam/spam calls. It should be noted that the Individual
never denied making these statements to the DOE Psychologist. Rather, she explained that she
held those beliefs closer in time to the actual January 2025 burglary, not the date of her evaluation.
Regardless of when the Individual felt that these concerns were real, and even considering the fact
that the Individual has hypervigilant professional sensibilities, the stated concerns are so extreme
in nature that I am concerned that she believed them at all.
In reviewing the information provided by the Individual’s expert, my attention is drawn to the fact
that she testified that the Individual was “very anxious about the theft of national security materials,
and she had an intense anxiety response to it.” Tr. at 255. However, the record is bereft of any
evidence that national security materials were stolen or compromised. The Individual’s personal
devices were taken, and although she felt that these personal items could have offered a way for
bad actors to access her work devices, the record does not indicate that her work devices were
taken or infiltrated. In fact, a scan of her computer was conducted, and it failed to produce evidence
that would bear out any such concerns. The Individual knew about the scan’s lack of findings.
Further, when asked about what she knew about what was stolen, the Individual’s expert noted
that she did not really need to know the particulars of the burglary and therefore did not ask for
23
Guideline I states that “[a] duly qualified mental health professional . . . employed by, or acceptable to and approved
by the U.S. Government, should be consulted when evaluating potentially disqualifying and mitigating information
under this guidance and an opinion, including prognosis, should be sought.” Adjudicative Guidelines at ¶ 27. This
indicates, therefore, that the duly qualified professional who is approved by the U.S. Government in this matter is the
DOE Psychologist.
14
details. Id. at 260–61. Accordingly, I am left questioning the expert’s conclusions, especially as it
pertains to the appropriateness of the Individual’s response in mid-January 2025, as her
understanding of what actually occurred has been thrown into question. I was also struck by how
the FFD-consultant psychiatrist could not definitively rule out Delusional Disorder when he spoke
to the DOE Psychologist. Further, the mental health professionals with whom the DOE
Psychologist spoke could not foreclose the possibility of Delusional Disorder or stated that it was
difficult to get a clear understanding of the “clinical picture.” The inability to confidently foreclose
the possibility of Delusional Disorder or to even get a clear picture of the Individual’s state is
unfavorable to the Individual, especially when considering the fact that the individuals with whom
the DOE Psychologist consulted saw the Individual closer in time to the January 2025 incident.
When I consider this fact in light of expert testimony that individuals with Delusional Disorder
can modify their behavior in response to undesirable feedback, I am left wondering whether the
Individual still holds these concerning beliefs about black ops activity but has learned to manage
her emotional response when relaying her concerns.
The record before me contains two diagnoses that are important to the analysis, Delusional
Disorder and Adjustment Disorder. The record before me also indicates that while Adjustment
Disorder is temporary in nature and very amenable to treatment, Delusional Disorder is far more
difficult to treat. Although more than one testifying mental health professional disagreed with the
DOE Psychologist’s diagnosis, the fact remains that every mental health professional found the
Individual’s worries following the burglary concerning and indicative of an illness and/or a
condition. As indicated by the mental health professionals involved in this matter, Delusional
Disorder is characterized by a persistent belief in delusions irrespective of any objective evidence
to the contrary. Based on the information before me, this does not appear to be a hallmark of
Adjustment Disorder. I have evidence that the Individual attributed seemingly disparate and
coincidental occurrences to the burglary and she continued to believe that her work
devices/computers had been compromised despite the fact that the work devices were not stolen
and a scan had been conducted, revealing that they were “clean.” Accordingly, I cannot discount
the possibility that a condition other than Adjustment Disorder was responsible for the Individual’s
unstable, paranoid behavior, and I cannot conclude that the Individual’s condition is readily
controllable with treatment or amendable to treatment, as the treatment she is receiving now is
only designed to treat Adjustment Disorder and not anything more serious. Mitigating factors (a)
and (b) have not been met.
The DOE Psychologist could not provide a current prognosis for the Individual, and when he was
asked if the Individual has “an illness or mental condition . . . [that] can cause or may cause a
significant defect in her judgment and reliability[,]” the DOE Psychologist stated that he does not
know. Id. at 297. As the DOE Psychologist did not opine that the Individual’s condition is under
control or in remission, and has a low probability of recurrence or exacerbation, and the prognoses
offered by the other experts pertained to Adjustment Disorder, which diagnosis I am uncertain is
appropriate in this case, I cannot conclude that mitigating factor (c) has been met.
As indicated above, two different mental health professionals indicated that if the Individual is
returned to work requiring a security clearance, she should be monitored. I believe that this is a
strong indication that while the Individual may be fit for work in the estimation of the
aforementioned mental health professionals, the condition may not be entirely resolved or there
15
may be some concern the condition is not temporary. In the same vein, although some mental
health professionals testified that the Individual was “on the other side” of the matter, not one
mental health professional suggested that treatment is no longer necessary. As treatment is still
necessary, and because it is possible that the Individual should be treated for something more
serious than Adjustment Disorder, requiring different medication and/or therapeutic approach, and
as the Individual remains concerned for the security of her family to a degree that was notable to
her therapist, I cannot conclude that the past psychological/psychiatric condition was temporary,
the situation has been resolved, and the individual no longer shows indications of emotional
instability. I cannot conclude that mitigating factor (d) has been met.
At the hearing, the DOE Psychologist could not definitively conclude whether the Individual has
an illness or mental condition that can cause or may cause a defect in her judgment and reliability.
Thus, the DOE Psychologist could not preclude the possibility that Delusional Disorder is still an
active condition for the Individual. Accordingly, there is still some question as to whether there is
a current problem. Mitigating factor (e) has not been satisfied.
For the aforementioned reasons, I find none of the mitigating conditions under Guideline I
applicable to the facts of this case. Accordingly, the Individual has not resolved the security
concerns asserted by the LSO.
VI. Conclusion
For the reasons set forth above, I conclude that the LSO properly invoked Guideline I of the
Adjudicative Guidelines. After considering all the evidence, both favorable and unfavorable, in a
comprehensive, common-sense manner, including weighing all the testimony and other evidence
presented at the hearing, I find that the Individual has not brought forth sufficient evidence to
resolve the Guideline I concerns set forth in the SSC. Accordingly, the Individual has not
demonstrated that restoring her security clearance would not endanger the common defense and
security and would be clearly consistent with the national interest. Therefore, I find that the
Individual’s access authorization should not be restored. This Decision may be appealed in
accordance with the procedures set forth at 10 C.F.R. § 710.28.
Noorassa A. Rahimzadeh
Administrative Judge
Office of Hearings and Appeals