KEYWORD: Guideline F
DIGEST: Applicant failed to rebut the presumption that the Judge considered all of the evidence. 
The Government need not wait until someone has failed to safeguard classified information
before it can deny a clearance. Adverse decision affirmed.
CASE NO: 15-03334.a1
DATE: 09/20/2016
DATE: September 20, 2016 
In Re:
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Applicant for Security Clearance
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ISCR Case No. 15-03334
APPEAL BOARD DECISION
APPEARANCES
FOR GOVERNMENT
James B. Norman, Esq., Chief Department Counsel
FOR APPLICANT
Pro se
The Department of Defense (DoD) declined to grant Applicant a security clearance.  On
November 19, 2015, DoD issued a statement of reasons (SOR) advising Applicant of the basis for
that decision–security concerns raised under Guideline F (Financial Considerations) of Department
of Defense Directive 5220.6 (Jan. 2, 1992, as amended) (Directive).  Applicant requested a decision
on the written record.  On June 30, 2016, after considering the record, Defense Office of Hearings
and Appeals (DOHA) Administrative Judge Carol G. Ricciardello denied Applicant’s request for
a security clearance.  Applicant appealed pursuant to Directive ¶¶ E3.1.28 and E3.1.30.
Applicant raised the following issues on appeal: whether the Judge considered all of the
record evidence and whether the Judge’s decision was arbitrary, capricious, or contrary to law. 
Consistent with the following, we affirm.
The Judge’s Findings of Fact  
Applicant, who is 29 years old, began working for a Federal contractor in August 2014.  She
is not married and has no children.  She was unemployed from August 2008 to September 2008, but
has since been employed.
The SOR alleges 18 debts totaling about $46,000, including about $30,000 in student loans
and an overpayment of about $1,600 in unemployment benefits.  Insufficient evidence was presented
to conclude the student loans were delinquent.  For one of the other alleged debts, a creditor
accepted a settlement offer that consisted of 12 installment payments, and Applicant wrote that she
made a payment in March 2016.  She claimed she paid three other debts, but only provided
documentary proof of payment for two of them.  For another debt, she provide a copy of a settlement
offer she sent to the creditor, but provided no other evidence concerning that debt.  For the
remaining debts, she indicated that she was negotiating settlements, attempting to contact collection
agencies to make payment arrangements, or disputing the debt with the creditors or credit reporting
bureaus, but did not provide corroborating evidence of those actions. 
Applicant attributed her financial problems to a reduction in her working hours, moving out
of her parents’ house and living on her own, and costly car repairs.  She had moved back in with her
parents, found a new job, and was taking care of her financial difficulties.  She was in the process
of setting up financial counseling, but did not provide evidence that she followed through with the
counseling. 
The Judge’s Analysis
The Judge found that Applicant had numerous debts that began accumulating in 2011 and
remain unresolved.  Applicant did not provide evidence of her current financial situation.  There is
insufficient evidence to conclude her financial problems are unlikely to recur or that she acted
responsibly under the circumstances.  She provided evidence that she paid a couple of small debts,
was seeking to settle others, and was contacting creditors.  Without additional evidence, there was
not sufficient proof to conclude her financial problems were under control.  In her whole-person
analysis, the Judge noted that Applicant does not have a reliable financial track record and failed to
meet her burden of persuasion.   
Discussion
In the appeal brief, Applicant asserted that she believes the Judge failed to consider that she
has been performing the duties of her position for two years without any breach of sensitive
information and the Judge failed to take into account the steps she had taken to resolve her financial
problems even though her income was decreased due to maternity leave.  However, the Judge made
findings about her employment history and the efforts she took to address the delinquent debts. 
Applicant’s assertions are neither enough to rebut the presumption that the Judge considered all of
the evidence in the record nor are they sufficient to show that the Judge weighed the evidence in a
manner that was arbitrary, capricious, or contrary to law.  See, e.g., ISCR Case No. 14-01284 at 3
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(App. Bd. Apr. 6, 2015).  It also merits noting that the government need not wait until an individual
mishandles or fails to safeguard classified information before it can make an unfavorable security
clearance decision.  Even those with good prior records can encounter circumstances in which their
judgment and reliability might be compromised.  See, e.g., ISCR Case No. 14-04648 at 3 (App. Bd.
Sep. 9, 2015);  Adams v. Laird, 420 F. 2d 230, 238-239 (D. C. Cir. 1969), cert. denied 397 U.S. 1039
(1970).  
The Judge examined the relevant data and articulated a satisfactory explanation for the
decision.  The decision is sustainable on this record.  “The general standard is that a clearance may
be granted only when ‘clearly consistent with the interests of the national security.’”  Department
of the Navy v. Egan, 484 U.S. 518, 528 (1988).  See also Directive, Enclosure 2 ¶ 2(b):  “Any doubt
concerning personnel being considered for access to classified information will be resolved in favor
of the national security.”
Order
The Decision is AFFIRMED.  
Signed: Michael Ra’anan           
Michael Ra’anan
Administrative Judge
Chairperson, Appeal Board
Signed: James E. Moody          
James E. Moody
Administrative Judge
Member, Appeal Board
Signed: James F. Duffy            
James F. Duffy
Administrative Judge
Member, Appeal Board
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