Rodriguez v. Del Toro

CourtDistrict Court, District of Columbia
DecidedMarch 13, 2026
DocketCivil Action No. 2024-0738
StatusPublished

This text of Rodriguez v. Del Toro (Rodriguez v. Del Toro) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rodriguez v. Del Toro, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ____________________________________ ) JONATHAN RODRIGUEZ, ) ) Plaintiff, ) ) v. ) Civil Action No. 24-0738 (ABJ) ) CARLOS DEL TORO, ) Secretary of the Navy, ) ) Defendant. ) ____________________________________)

MEMORANDUM OPINION

Plaintiff Jonathan Rodriguez is a former member of the United States Marine Corps, a

branch of the military operating under the leadership of the Secretary of the Navy. He has brought

this case under the Administrative Procedure Act (“APA”) to challenge decisions made by the

Navy related to his disabilities, in particular, the classification code used for his separation and his

ability to receive disability retirement pay. Pending before the Court are the parties’ cross-motions

for summary judgment and defendant’s motion to dismiss in part for lack of subject matter

jurisdiction. After reviewing the record in accordance with the deferential standard that applies to

the review of military decisions, the Court will grant defendant’s motion to dismiss in part on

jurisdictional grounds and its motion for summary judgment on all counts. In light of that ruling,

the Court will deny plaintiff’s cross motion for summary judgment on the corresponding counts.

1 BACKGROUND

I. Governing Law and Regulations

A. Disability Retirement in the United States Navy

Title 10 of the United States Code, Section 1201 governs the retirement and separation of

members of the military due to disability. The Secretary of Defense and the secretaries of each

service branch have promulgated regulations to implement the statutory requirements. See 10

U.S.C. § 1216; 10 U.S.C. § 1201(a).

The Secretary may place a member on the Permanent Disability Retired List if several

conditions are met: 1) “based upon accepted medical principles,” the member must have a

disability which is “of a permanent nature and stable;” 2) “the disability is not the result of the

member’s intentional misconduct or willful neglect, and was not incurred during a period of

unauthorized absence;” and 3) “the disability is at least 30 percent under the standard schedule of

rating disabilities” (“Disabilities Rating Schedule”) in use by the Department of Veterans Affairs

(“VA”) at the time of the determination, or the member has at least 20 years of service. See 10

U.S.C. § 1201(b). Also, if a service member has a disability rated at least 30 percent under the

Disabilities Rating Schedule, one of four conditions must be satisfied: (1) the member had at least

eight years of service and the disability was not “noted at the time of the member’s entrance on

active duty;” (2) the disability was the “proximate result of performing active duty;” (3) the

disability was “incurred in line of duty in time of war or national emergency”; or (4) the disability

was “incurred in line of duty after September 14, 1978.” Id. at § 1201(b)(3)(B)(i)–(iv).

The Department of Defense’s (“DoD”) Disability Evaluation System (“DES”) sets out the

process for reviewing a service member’s medical conditions and determining whether those

conditions render that service member unfit for duty. See Department Directive 1332.18,

2 Separation or Retirement for Physical Disability (Nov. 4, 1996),

https://www.rand.org/content/dam/rand/www/external/paf/projects/dopma-ropma/DODD-1332-

18p.pdf1; Department Instruction 1332.38, Physical Disability Evaluation (Nov. 14, 1996),

https://palmcenterlegacy.org/wp-content/uploads/2019/03/DoD_Number_1332.38.pdf; see also

SECNAVINST 1850.4E encl. (8), § 8001(a), https://www.secnav.navy.mil/mra/CORB/

Documents/SECNAVINST-1850-4E.PDF. In the case of a member of the Navy or the Marine

Corps, the DES process begins with a medical evaluation board, see Department Instruction

1332.38, E3.P1.1.1; SECNAVINST 1850.4E encl. (3), § 3102(a), followed, if necessary, by a

physical evaluation board, see Department Instruction 1332.38, E3.P1.1.2; SECNAVINST

1850.4E encl. (3), § 3102(c), which makes a determination of fitness to continue naval service “on

behalf of the Secretary of the Navy . . . .” SECNAVINST 1850.4E encl. (1), § 1004(a).

The Navy has implemented the DES and established its own policies and procedures. See,

e.g., SECNAVINST 1850.4E, Navy Disability Evaluation Manual (April 30, 2002); U.S. Navy

MANMED, Ch. 18 – Medical Evaluation Boards (January 10, 2005),

https://www.med.navy.mil/Portals/62/Documents/BUMED/Directives/MANMED/MANMED%

20Chapter%2018%20Medical%20Evaluation%20Boards%20(Change%20120%20-

%20Complete%20Revision%2010%20Jan%202005).pdf?ver=bi9uM8KYr0cJWTb9Lzbcqw%3

D%3D. Under those directives, a medical evaluation board will refer a service member with a

disability that “call[s] into question” their fitness for continued naval service to the physical

evaluation board. See generally MANMED, Ch. 18, Art. 18-11, at 41. The physical evaluation

board then performs most of the DES functions, such as deciding the member’s fitness and

1 The citations to DOD and service-specific authorities in this opinion will refer to the versions in effect when plaintiff separated from the Navy. 3 entitlement to disability benefits. See SECNAVINST 1850.4E. The physical evaluation board has

the exclusive authority to determine a service member’s fitness for continued service. See

MANMED, Ch. 18, Article 18-11, at 41.

A service member is unfit for continued service if they cannot “reasonably perform” their

duties because of a physical disability. See SECNAVINST 1850.4E § 3302. To assess this

question, the physical evaluation board will consider such factors as the ability to perform common

military tasks, physical fitness, deployability, and any loss of a special qualification caused by

medical conditions. Id. § 3304. The physical evaluation board considers “all relevant evidence,”

including the “circumstances of referral” to the board. Id. § 3303. For example, a serious injury,

grave illness, or chronic impairment that prompted a service member’s referral to the physical

evaluation board can weigh in favor of a finding that the service member is unfit. See id.

If the service member adequately performed their duties until the time they were referred

to the physical evaluation board, that member may be “considered Fit even though medical

evidence indicates questionable physical ability to continue to perform duty.” See SECNAVINST

1850.4E § 3303(c). On the other hand, “inadequate performance of duty, by itself, shall not be

considered as evidence of unfitness due to physical disability unless it is established that there is a

cause and effect relationship between the two factors.” Id. § 3303(d). The physical evaluation

board determines a service member’s fitness for continued naval service by preponderance of the

evidence. Id. §§ 2070, 3306.

If the physical evaluation board finds a service member unfit for continued naval service,

it then determines the disability rating and the type of disability benefits that should be granted.

MANMED, Ch. 18, Article 18-11 at 41.

4 B. Regulations Applicable to the Marine Corps Reserve

This case arose from plaintiff’s service in the Marine Corps Reserve. At the time of his

separation, the Marine Corps Reserve Administrative Management Manual categorized injured

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