Fowler v. United States

United States Court of Federal Claims·Decided August 6, 2026·No. 26-570·Unpublished

Opinion

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

NOT FOR PUBLICATION

)

GERRY W. FOWLER, SR., )

)

Plaintiff, ) No. 26-570 )

v. ) Filed: August 6, 2026 )

THE UNITED STATES, )

)

Defendant. )

______________________________________ )

MEMORANDUM OPINION AND ORDER Pro se plaintiff Gerry W. Fowler, Sr., a retired member of the United States Navy, challenges the Board for Correction of Naval Records’ (“BCNR” or “Board”) 2026 denial of his request to reconsider his application for correction of military record to reflect disability retirement. Before the Court is the Government’s Motion to Dismiss pursuant to Rules 12(b)(1) and 12(b)(6) of the Rules of the United States Court of Federal Claims (“RCFC”). The Government contends that Plaintiff’s claim is barred by the statute of limitations because more than six years have elapsed since its accrual or, alternatively, that Plaintiff’s claim is barred under res judicata principles because the Court previously decided the jurisdictional issue raised by Plaintiff’s Complaint. For the reasons stated below, the Court GRANTS the Government’s Motion to Dismiss.

I. BACKGROUND

A. Factual History This Opinion assumes the reader’s familiarity with the Court’s decision in Fowler v. United States (Fowler I), 174 Fed. Cl. 423 (2025), which dismissed Plaintiff’s previous disability retirement claim based on similar facts for lack of subject-matter jurisdiction. Plaintiff enlisted in

the Navy in 1974 and was subsequently diagnosed with paranoid schizophrenia on August 17, 1991. Id. at 426; see also Pl.’s Compl. ¶¶ 17, 61, ECF No. 1. His condition triggered hallucinations, paranoid delusions, and several hospitalizations. Fowler I, 174 Fed. Cl. at 426; ECF No. 1 ¶ 18. On October 22, 1991, the Department of the Navy’s Physical Evaluation Board (“PEB”) found that Plaintiff’s schizophrenia diagnosis made him not physically qualified for service (“NPQ”). Fowler I, 174 Fed. Cl. at 426; ECF No. 1 ¶ 20. The PEB indicated that Plaintiff would be discharged or transferred to a retirement status. Fowler I, 174 Fed. Cl. at 426. On December 3, 1991, Plaintiff received a document outlining the PEB’s findings, which he initialed to indicate that he accepted the determination and did not request reconsideration. Id. In 1992, Plaintiff was medically separated from the Navy, transferred to retired service without pay, and placed on the Temporary Disabled Retirement List (“TDRL”). Id.

In 1995, Plaintiff filed his first petition with the BCNR, in which he sought to be removed from the TDRL and placed on the Permanent Disability Retirement List (“PDRL”). Id. at 426–27. The BCNR denied this petition. Id. at 427. Between 1995 and 2019, Plaintiff submitted additional petitions and requests for reconsideration asking that the Board correct his military record and grant him disability retirement. Id. After the Board’s 2020 denial, Plaintiff filed a complaint in the Court of Federal Claims on December 8, 2023. Id.; ECF No. 1 ¶ 16. He sought damages for back pay and benefits or, in the alternative, a remand back to the BCNR. See Pl.’s Compl. at 11, Fowler v. United States, No. 23-2095 (Fed. Cl. Dec. 8, 2023), ECF No. 1. Upon review, this Court held that it lacked subject-matter jurisdiction as Plaintiff’s disability retirement claim accrued in 1992, more than 30 years prior to the filing of the complaint. See Fowler I, 174 Fed. Cl. at 429. The Court accordingly granted the Government’s motion to dismiss for lack of subject-matter jurisdiction on January 6, 2025. Id. at 431.

Later the same year, Plaintiff submitted another application for reconsideration to the BCNR. See Exs. to Pl.’s Compl. at 12–22, ECF No. 1-2. Plaintiff claims that this application contained new evidence demonstrating his eligibility for disability retirement, which he obtained through a Freedom of Information Act (“FOIA”) request. See id. at 15–22; ECF No. 1 ¶¶ 12–13. Plaintiff requested that the Board re-open his case, correct his military record, place him on the PDRL, and grant him back pay and benefits. ECF No. 1-2 at 18. The Board denied his request on March 23, 2026, because it was “unable to find sufficient new evidence, other matters not previously considered by the Board, or material not available when [Plaintiff] submitted [his] previous application.” Id. at 10. The BCNR therefore determined that there was nothing for it to adjudicate, and it administratively closed Plaintiff’s case. Id.

B. Procedural History Plaintiff filed his Complaint on April 16, 2026, arguing that the BCNR’s 2026 denial was arbitrary, capricious, contrary to law, and unsupported by substantial evidence. ECF No. 1 ¶ 36. Plaintiff specifically attacks the Board’s alleged failure to apply the correct statutory standard, id. ¶¶ 38–40; meaningfully engage with the arguments and evidence presented by Plaintiff, id. ¶¶ 41– 50; and provide a reasoned explanation for its decision, id. ¶¶ 51–57. In addition, Plaintiff presents arguments as to why he is entitled to disability evaluation and retirement processing. Id. ¶¶ 58– 71. According to Plaintiff, the BCNR’s 2026 denial constitutes an independently reviewable agency action because it involved legal wrongs that are distinct from what the Court resolved in Fowler I. Id. ¶¶ 12, 16. As relief, Plaintiff requests a correction of his military record, placement on the PDRL, and back pay and benefits or, alternatively, a remand back to the BCNR. Id. at 10.

On June 11, 2026, the Government filed a Motion to Dismiss pursuant to RCFC 12(b)(1)

and 12(b)(6). Gov’t’s Mot. to Dismiss at 1, ECF No. 8. The Government argues that the Board’s

2026 denial did not create a new claim; and thus, the action is barred by the statute of limitations because Plaintiff’s claim to disability retirement accrued in 1992. Id. at 4–7. Alternatively, the Government claims that Plaintiff’s suit is barred under res judicata, as the Court has already determined the jurisdictional questions that govern Plaintiff’s ability to bring this new suit. Id. at 8–10.

Plaintiff filed his response on June 26, 2026, reiterating his contention that the BCNR’s denial is independently reviewable and claiming this suit does not involve a previously answered jurisdictional question because it challenges a new final decision involving a legal error separate from Fowler I. Pl.’s Opp’n to Gov’t’s Mot. to Dismiss at 2–3, 8–9, ECF No. 10; see also ECF No. 1 ¶¶ 14, 16, 34, 71–72. Specifically, Plaintiff argues that the BCNR failed to follow 10 U.S.C. § 1552(a)(3)(D), which mandates that the Board reconsider a prior determination if an applicant’s request for reconsideration is supported by materials not previously presented to or considered by the Board. See ECF No. 10 at 7–10.

The Government filed its reply on July 10, 2026, stating that, regardless of the Board’s alleged errors in connection with its 2026 denial, Plaintiff is seeking disability retirement, a claim that accrued in 1992. See Gov’t’s Reply in Supp. of Mot. to Dismiss at 2–3, ECF No. 11. Because the Board’s most recent decision did not restart the limitations period or establish grounds for a new cause of action, the Government asserts that Plaintiff’s claims are time-barred. Id. at 3. The motion is fully briefed and ready for decision.

II. LEGAL STANDARDS

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