Ellis v. Board for Correction of Naval Records

District Court, S.D. Ohio·Decided December 5, 2024·No. 2:23-cv-03261·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

ERNEST R. ELLIS, SR.,

Plaintiff,

v. Case No. 2:23-cv-3261

JUDGE EDMUND A. SARGUS, JR.

Magistrate Judge Elizabeth P. Deavers

BOARD FOR CORRECTION OF

NAVAL RECORDS,

Defendant.

ORDER This matter is before the Court sua sponte regarding the sufficiency of Plaintiff Ernest Ellis, Sr.’s Complaint and service on Defendant. Plaintiff filed suit against Defendant “Board for Correction of Naval Records” (“BCNR”) on October 4, 2023. (Compl., ECF No. 1.) Plaintiff’s Complaint appears to raise claims stemming from his general honorable discharge from the United States Navy in 1975 and the denial of his requests for an upgrade to his service characterization. (See id., PageID 10; 2019 BCNR Letter, ECF No. 1, PageID 35–36.) For the reasons stated in this Order, this Court DIRECTS Plaintiff to serve the United States Attorney for the Southern District of Ohio and the United States Department of the Navy within 21 days of this Order as instructed below. The Court WARNS Plaintiff that if he fails to do so, his case may be dismissed. I. Nature of the Complaint and Exhaustion of Administrative Remedies Plaintiff was discharged from the United States Navy in August 1975 following his conviction by summary court-martial for two periods of unauthorized absence from service earlier in 1975. (2019 BCNR Letter, PageID 35.) He was discharged “with a general, under honorable conditions (GEN), characterization of service by reason of unsuitability.” (Id.) Since then, Plaintiff has repeatedly asked courts to review adjudications by BCNR denying his requests to correct his naval records regarding the characterization of his discharge. Relevant to this current litigation, Plaintiff applied to BCNR in June 2018 for a correction of his naval records, arguing he “should have been honorably medically discharged due to [his]

diagnosed neurosis and accompanying symptoms.” (2019 BCNR Letter, PageID 36.) Attached to his Complaint, Plaintiff includes two letters from the United States Department of the Navy, BCNR. The first, dated August 31, 2019, informs Plaintiff that his June 7, 2018 request for correction of his Naval records has been disapproved (BCNR Docket # NR20180004911). (Id., PageID 35.) BCNR stated that it considered Plaintiff’s application for correction “in light of the Secretary of Defense’s 3 September 2014 memorandum,” which, in part, provided policy guidance on Naval records corrections requests made by veterans with Post-Traumatic Stress Disorder (PTSD).1 (See id., PageID 36.) BCNR concluded Plaintiff should not be granted relief because his two periods of unauthorized absence from the military in 1975 were unjustified and because his discharge

designation already accounted for a determination that he was suffering from early stages of a psychotic disorder at the time. (Id., PageID 36–37.) It determined that a designation of “medical discharge was not warranted.” (Id., PageID 37.) In BCNR’s second letter to Plaintiff, dated February 22, 2023, the Board informed Plaintiff

1 The memo, titled “Supplemental Guidance to Military Boards for Correction of Military/Naval Records Considering Discharge Upgrade Requested by Veterans Claiming Post Traumatic Stress Disorder,” was not attached to Plaintiff’s Complaint. It was authored by Secretary of Defense Chuck Hagel and is accessible on the Secretary of the Navy’s website. The memo included policy guidance “intended to ease the application process for veterans who are seeking redress and assist the Boards [for Correction] in reaching fair and consistent results in” cases where veterans request discharge upgrades “based on previously unrecognized [PTSD].” United States Secretary of Defense, Supplemental Guidance to Military Boards for Correction of Military/Naval Records, https://www.secnav.navy.mil/mra/bcnr/Documents/HagelMemo.pdf. that it would not consider his February 21, 2022 application for correction of records because he was previously denied relief. (Id., PageID 30.) It informed Plaintiff that he may submit a new DD Form 149 (“Application for Correction of Military Record”), along with new evidence, to initiate BCNR’s reconsideration of its August 31, 2019 decision. (Id.) BCNR also stated “[i]n the absence

of sufficient new and material evidence for reconsideration, the decision of the Board is final, and your only recourse would be to seek relief, at no cost to the Board, from a court of appropriate jurisdiction.” (Id.) BCNR was created “for the purpose of determining the existence of error or injustice in the naval records of current and former members of the Navy and Marine Corps, to make recommendations to the Secretary or to take corrective action on the Secretary's behalf when authorized.” 32 C.F.R. § 723.2(b). “Federal courts have the authority to review the decision of a military board of correction under the Administrative Procedure Act (APA).” Bolton v. Department of the Navy Board for Correction of Naval Records, 914 F.3d 401, 406 (6th Cir. 2019) (citing 5 U.S.C. § 701 et seq.; Piersall v. Winter, 435 F.3d 319, 323–25 (D.C. Cir. 2006)).

“Decisions of the BCNR are ‘subject to judicial review and can be set aside if they are arbitrary, capricious or not based on substantial evidence.’” Id. (quoting Chappell v. Wallace, 462 U.S. 296, 303 (1983)); see also 10 U.S.C. § 1558(f)(3)(A) (authorizing a court to set aside an action of the Secretary of any military department “only if the court finds that the recommendation or action was—(A) arbitrary or capricious; (B) not based on substantial evidence; (C) a result of material error of fact or material administrative error; or (D) otherwise contrary to law”). Here, Plaintiff essentially asks this Court to review an adjudication by BCNR denying the application for correction of military records he submitted in light of the Secretary of Defense’s September 2014 memorandum. Plaintiff has provided evidence that he sought such relief in June 2018 and was denied relief in August 2019. (See Compl., PageID 35.) Based on BCNR’s letters to Plaintiff, Plaintiff’s only available option for further administrative review would be to file another DD Form 149, along with new evidence, for reconsideration of the denial. (See id., PageID 30.) It appears from the record that there is no apparent cap on the number of times Plaintiff can apply

for reconsideration of BCNR’s denial of his application for correction. Accordingly, Plaintiff likely has sufficiently exhausted available administrative remedies. See Seepe v. Department of the Navy, 518 F.2d 760, 762, 765 (6th Cir. 1975) (holding that plaintiff failed to exhaust his administrative remedies because “he never appealed to the Board for Correction of Naval Records” at all). Even so, this Court reserves a decision on that question and would consider Defendant’s arguments to the contrary in future filings. II. Insufficiency of Service On September 27, 2024, this Court advised Plaintiff that he had not properly served the United States Attorney for the Southern District of Ohio. (Opinion and Order, ECF No. 48, PageID 560–61; see ECF Nos.

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Related

Chappell v. Wallace
462 U.S. 296 (Supreme Court, 1983)
Piersall, Charles v. Winter, Donald C.
435 F.3d 319 (D.C. Circuit, 2006)