Wallish v. United States Department of Defense

CourtDistrict Court, District of Columbia
DecidedJune 4, 2025
DocketCivil Action No. 2024-0616
StatusPublished

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Wallish v. United States Department of Defense, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

ROBERT J. WALLISH III,

Plaintiff,

v. Civil Action No. 24-cv-00616 (TSC) UNITED STATES DEPARTMENT OF DEFENSE,

Defendant.

MEMORANDUM OPINION

On March 4, 2024, Plaintiff Robert Wallish—a fifteen-year veteran of the United States

Army—sued the United States Department of Defense (“DOD”), alleging that DOD unlawfully

denied him disability retirement benefits. Compl. ¶ 1, ECF No. 1. Specifically, he alleges that the

Physical Disability Board of Review (“PDBR”)—a review board within the Office of the Secretary

of Defense that reviews disability determinations—improperly evaluated his disabilities. Id. ¶ 2.

Plaintiff challenges the PDBR’s January 18, 2022, decision denying him disability retirement as

arbitrary and capricious, unsupported by substantial evidence, and contrary to law, in violation of

the Administrative Procedure Act, 5 U.S.C. § 706(2). Am. Compl. ¶¶ 99–103, ECF No. 19.

On February 14, 2025, DOD moved for a voluntary remand to the Army Board for

Correction of Military Records (“Board”)—the entity now responsible for acting on cases

previously under the purview of the PDBR—to reconsider the Board’s decision and to stay this

action during the pendency of the Board’s review. Def.’s Mot. for Voluntary Remand and Stay of

Proceedings (“Def.’s Mot.”), ECF No. 28. Plaintiff consents to a remand but requests that the

court’s remand order include specific instructions to the Board on time limits and on providing

Page 1 of 6 supplemental information. Pl.’s Partial Opp’n to Def.’s Mot. for Voluntary Remand and Stay of

Proceedings and Cross-Mot. for Voluntary Remand and Stay of Proceedings at 1–2 (“Pl.’s Mot.”),

ECF No. 30. Given that existing procedures safeguard Plaintiff’s interests, and finding no need to

amend or alter the Board’s policies and procedures, the court will GRANT Defendant’s motion

for a remand and stay and will DENY Plaintiff’s cross-motion.

Plaintiff served with distinction in the Army for more than fifteen years until he was

honorably discharged on March 31, 2005, due to severe physical disabilities he developed as a

result of his service. Am. Compl. ¶ 1. He argues that he is entitled to a disability retirement,

including lifetime medical benefits, but for fifteen years, DOD “has unlawfully denied him the

disability retirement he deserves.” Id. ¶ 1.

In order to decide whether a service member qualifies for medical retirement, the Army

must evaluate the service member and make certain determinations about their physical or mental

disability, which includes assigning the member a “disability rating.” See 10 U.S.C. § 1201. The

process for evaluating a service member’s fitness for duty because of a possible disability is

typically triggered upon a referral to the Army’s Medical Evaluation Board (“MEB”). Am. Compl.

¶ 9. If the MEB determines that the service member’s condition does not meet the standards to

stay in the Army, it refers the member’s case to an evaluative body governed by the DOD—the

Physical Evaluation Board (“PEB”). Id. The PEB evaluates the service member and makes

findings and recommendations about the member’s fitness for duty and statutory eligibility for

benefits. Id. ¶ 10. The PDBR is tasked with reassessing the PEB’s findings. See id. ¶ 23.

After Plaintiff submitted a series of rebuttals, reassessments, and appeals of the Army’s

findings on his disability rating, in 2006, PEB ultimately found that Plaintiff was unfit for

continued service but was not entitled to a medical retirement. Id. ¶ 46. On June 2, 2020, Plaintiff

Page 2 of 6 filed an application with the PDBR to appeal PEB’s decision, and on January 18, 2022, the PDBR

ultimately issued a decision slightly increasing Plaintiff’s disability rating. Id. ¶¶ 50–57. But,

according to Plaintiff, “[j]ust like the PEB, the PDBR’s decision relied on cherry-picked

evidence,” “ignor[ed] arguments and evidence submitted,” and “turn[ed] a blind eye to [Plaintiff’s]

severe medical conditions.” Id. ¶¶ 58–59. Accordingly, on March 4, 2024, Plaintiff filed suit in

this court challenging PDBR’s January 18, 2022, decision.

In February 2025, both parties moved to remand this case to the Board and consented to a

stay of proceedings before this court for the duration of remand proceedings. The parties disagree,

however, on the instructions that the court should include in its proposed order.

Accordingly, on May 12, 2025, the court issued a Minute Order directing the parties to

meet and confer and file a joint status report indicating whether they could agree on proposed

remand instructions and identifying any remaining disagreements. May 12, 2025 Min. Order. The

parties ultimately agreed that the remand order need not contain certain specific instructions that

Plaintiff initially requested. See Joint Status Report ¶ 5, ECF No. 33. The parties also agreed that,

as a condition of the remand, defense counsel will provide any materials that Plaintiff submits on

remand to the Board for its consideration. Id. ¶ 4.

There are two outstanding disagreements on the remand instructions: First, Plaintiff

requests a specific instruction that he shall submit a brief in support of his application, along with

any supporting documentation, for the Board’s consideration within 30 days of the court’s order.

Id. ¶ 7. He argues that this instruction “is necessary to ensure the Board reviews the relevant

portion of the administrative record.” Id. Second, Plaintiff requests that the “remand order include

a 180-day time limit for the Board to complete its reevaluation to ensure this matter is timely

resolved.” Id. ¶ 8.

Page 3 of 6 Administrative agencies have the inherent power to reconsider their own decisions through

a voluntary remand. Code v. McHugh, 139 F. Supp. 3d 465, 468 (D.D.C. 2015). An “agency may

request a remand (without confessing error) in order to reconsider its previous position.” Util.

Solid Waste Activities Grp. v. EPA, 901 F.3d 414, 436 (D.C. Cir. 2018) (citation omitted). A

“voluntary remand request . . . may be granted only when the agency intends to take further action

with respect to the original agency decision on review.” Limnia, Inc. v. United States Dep’t of

Energy, 857 F.3d 379, 386 (D.C. Cir. 2017). Courts have broad discretion to grant or deny a

remand motion. Util. Solid Waste, 901 F.3d at 436.

Courts prefer to allow “agencies to cure their own mistakes rather than wast[e] the courts’

and the parties’ resources reviewing a record that both sides acknowledge to be incorrect or

incomplete.” See Ethyl Corp. v. Browner, 989 F.2d 522, 524 (D.C. Cir. 1993). In deciding a

motion to remand, the court must consider whether remand would unduly prejudice the non-

moving party. Util. Solid Waste, 901 F.3d at 436. It is appropriate to deny remand if the agency’s

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