Moskowitz v. Wormuth

District Court, District of Columbia·Decided March 25, 2025·No. Civil Action No. 2023-2461·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

LESLIE A. MOSKOWITZ,

Plaintiff,

Civil Action No. 23 - 2461 (LLA)

v.

DANIEL P. DRISCOLL, Defendant.

MEMORANDUM OPINION

Retired Lieutenant Colonel Leslie A. Moskowitz brings this action against Daniel P.

Driscoll, the Secretary of the Army (the “Secretary”), 1 for violations of the Administrative Procedure Act (“APA”), 5 U.S.C. § 701 et seq., arising out of the denial of her request to correct her military records. ECF No. 1. Before the court are the parties’ cross-motions for summary judgment, which are fully briefed. ECF Nos. 14, 15, 18, 20. For the following reasons, the court will grant Ms. Moskowitz’s motion for summary judgment, deny the Secretary’s motion for summary judgment, and remand the matter for further proceedings.

I. FACTUAL BACKGROUND AND PROCEDURAL HISTORY A. Army Retirement and Separation Policies Beginning in 1994, the age of retirement for Army Reserve officers—set by federal statute—was sixty. 10 U.S.C. § 14509 (1994); see Administrative Record (“AR”) 45. In 2006,

1 Ms. Moskowitz named former Secretary of the Army Christine E. Wormuth as Defendant, but the current Secretary of the Army is “automatically substituted” under Federal Rule of Civil Procedure 25(d).

Congress increased the statutory age of retirement to sixty-two, 10 U.S.C. § 14509, but under Army regulations, with a few exceptions, the age of retirement remained sixty, see Army Reg. 140-10 ¶ 7-3. To retire from the Army with full retirement benefits, a servicemember must serve for twenty years. 10 U.S.C. § 12731(a)(2). Officers who have served for fewer than twenty years at the time they turn sixty are mandatorily separated and are not eligible for retirement benefits. See id. § 12731(f)(1). There is an exception, however, for servicemembers who have served for eighteen years at the time they turn sixty; specifically, a servicemember who is within two years of receiving retirement pay “may not be involuntarily released from that duty before [she] becomes eligible for that pay unless the release is approved by the Secretary.” Id. § 12686(a); AR 21.

B. Ms. Moskowitz’s Enlistment and Separation The facts are undisputed. ECF No. 14, at 1 n.1; ECF No. 15, at 5. In March 1998, Ms. Moskowitz joined the United States Army Reserve as a First Lieutenant at the age of forty-two. AR 59. Her area of concentration (“AOC”) was as a dietitian and her occupation designation was “65C.” AR 59. 2 Because she was past the age requirement for enlistment, Ms. Moskowitz was granted age- and age-in-grade waivers that allowed her to serve. AR 59. Based on the date of her sixtieth birthday, Ms. Moskowitz’s Mandatory Removal Date (“MRD”) was October 31, 2015. AR 438. This meant that she would have “completed 17 years, 7 months, and 22 days of active service” at the time of her removal, leaving her just over four months shy of the eighteen-year safe harbor to receive retirement benefits. AR 9, 17.

2 As the parties note, “throughout the record, Plaintiff’s occupation is variously referred to as a ‘military occupational specialty,’ or ‘MOS,’ and an ‘area of concentration,’ or ‘AOC.’” ECF No. 14, at 1 n.2; ECF No. 15, at 5 n.2. The court will refer to the occupational specialty as “AOC” throughout to enhance clarity.

In October 2014, about a year before her MRD, Ms. Moskowitz emailed the Army’s Human Resources Command (“HRC”) to inquire about extending her MRD. AR 188. The HRC informed Ms. Moskowitz that the “strength numbers for 65C are currently over [their] max”— meaning that there was no demand for officers in 65C positions—“but we cannot tell you not to submit.” AR 194. The HRC also told her that if she intended to seek an extension, she should “do so as soon as possible.” AR 194.

In February 2015, Ms. Moskowitz submitted a request for an extension of her MRD.

AR 437. In it, she explained that she was seeking the extension so that she could “complete 20 years of service for retirement” and have “the opportunity to continue to serve.” AR 439. She included details on her educational and processional achievements and memoranda of support from the Director of the Graduate Program in Nutrition at the Army Medical Command and the Chief of the Dietitian Section of the Army Medical Specialist Corps. AR 439-43. In June 2015, the HRC denied her request. AR 444. The denial offered no explanation except that “retention of LTC Moskowitz is not in the best interest of the Army.” AR 444.

Because her original AOC was overstrength, Ms. Moskowitz looked for positions that were understrength—meaning understaffed—to which she could transfer, so that she could again request an extension of her MRD. ECF No. 1 ¶ 32. She applied for a transfer to a position within the Civil Affairs branch of the Army, AOC 38G, which was understrength at the time. Id. ¶ 33; AR 445, 460. While her application was pending, Ms. Moskowitz sought reconsideration of her MRD extension request, explaining to the HRC that an extension of her MRD would allow her to “complete . . . critical mission projects and also obtain [her] 20 years of service.” AR 162. In September 2015, the HRC denied her request for reconsideration. AR 169-74.

In October 2015, Ms. Moskowitz submitted a request to the Army Inspector General, seeking general statistics about how MRD extension requests are processed and specific details on her own extension request. AR 446. In the letter, she explained that she had applied for the 38G position and been told that her application “[was] very strong,” but that she would not hear back about it until two weeks after her MRD date. AR 446.

The request was referred to the HRC Inspector General’s Office, which responded to Ms. Moskowitz on October 26, 2015. AR 447-48. The Office did not provide her with the requested statistics, explaining only that “[e]ach request for extension is reviewed individually” and that “there [was] no system to identify and justify each denial.” AR 447. It did explain how it had processed Ms. Moskowitz’s MRD extension request, detailing that it had received her request on April 20, 2015, begun processing it on April 25, 2015, and rendered a final decision on June 23, 2015. AR 447. The Office concluded its response by stating: “Bottom line: Your request does not meet the criteria for MRD extension. Had your request to transfer to a shortage [AOC] been previously approved, there may have been a possibility for an MRD extension.” AR 448.

On the same day that Ms. Moskowitz received the Office’s response, she learned that she had been selected for a transfer to the understrength 38G position that she had applied for. AR 445. Despite her selection, Ms. Moskowitz was separated from the Army Reserves five days later, on October 31, 2015. AR 745.

C. Procedural History In December 2015, Ms. Moskowitz filed a request with the Army Board for Correction of Military Records (“Corrections Board”) asking it to grant her request for an MRD extension. AR 423-29. She explained that she was challenging her “unjust separation” because the denial of her initial MRD extension request had been based on her AOC “being overstrength,” but she had

thereafter been accepted into the “[38G] program . . . which has extreme shortages . . . prior to [her] MRD removal date.” AR 429. The Corrections Board denied Ms. Moskowitz’s request in October 2017. AR 415-22.

In July 2018, Ms. Moskowitz submitted Freedom of Information Act (“FOIA”) requests to the Army, seeking information about the number of servicemembers who were holding 65C positions at the time she submitted her MRD extension request and at the time the HRC denied it. See AR 273-92. In June 2020, Moskowitz received an email from the Army USAR Command Headquarters in response to her request, which provided data showing that in Fiscal Year 2015— the year that Ms. Moskowitz had been separated—there were sixty-four servicemembers with the 65C AOC, but by Fiscal Year 2017, there were 74 servicemembers with the 65C AOC. AR 276.

Free access — add to your briefcase to read the full text and ask questions with AI

Moskowitz v. Wormuth, (D.D.C. 2025).

Moskowitz v. Wormuth (Moskowitz v. Wormuth) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Cone, George E. v. Caldera, Louis
223 F.3d 789 (D.C. Circuit, 2000)
John F. Kreis v. Secretary of the Air Force
866 F.2d 1508 (D.C. Circuit, 1989)
Dennis A. Dickson v. Secretary of Defense
68 F.3d 1396 (D.C. Circuit, 1995)
Piersall v. Winter
507 F. Supp. 2d 23 (District of Columbia, 2007)
Kenneth Haselwander v. John McHugh
774 F.3d 990 (D.C. Circuit, 2014)
Christopher Code v. Ryan McCarthy
959 F.3d 406 (D.C. Circuit, 2020)
Hugh McKinney v. Christine Wormuth
5 F.4th 42 (D.C. Circuit, 2021)
Stewart v. Stackley
251 F. Supp. 3d 138 (District of Columbia, 2017)