throbber
No. 23A858
`In the Supreme Court of the United States
`___________________________________________
`
`ISRAEL ALVARADO, ET. AL.,
`Applicants,
`v.
`LLOYD AUSTIN, III, ET. AL.,
`Respondents.
`___________________________________________
`
`On Application for a Writ of Injunction Pending Petition for a Writ of Certiorari
`
`___________________________________________
`
`To the Honorable John G. Roberts, Jr., Chief Justice of the United States and
`Circuit Justice for the Fourth Circuit
`
`___________________________________________
`
`SUPPLEMENTAL BRIEF IN SUPPORT OF ALVARADO, ET AL, APPLICATION FOR
`WRIT OF INJUNCTION PENDING PETITION FOR A WRIT OF CERTIORARI
`___________________________________________
`
`BRANDON JOHNSON
`DEFENDING THE REPUBLIC
`2911 Turtle Creek Blvd.
`Suite 300
`Dallas, Texas 75219
`(214) 707-1775
`bcj@defendingtherepublic.org
`
`J. ANDREW MEYER
`FINN LAW GROUP, P.A.
`8380 Bay Pines Blvd.
`St. Petersburg, Florida 33709
`(727) 709-7668
`ameyer@finnlawgroup.com
`
`ARTHUR A. SCHULCZ, SR.
` Counsel of Record
`CHAPLAINS COUNSEL, PLLC
`21043 Honeycreeper Place
`Leesburg, Virginia 20175
`(703) 645-4010
`art@chaplainscounsel.com
`
`Counsel for Applicants
`
`

`

`TABLE OF CONTENTS
`
`TABLE OF CONTENTS................................................................................................................. i
`
`TABLE OF AUTHORITIES .......................................................................................................... ii
`
`INTRODUCTION........................................................................................................................... 1
`
`REASONS TO GRANT THE APPLICATION ............................................................................. 2
`
`I. FIKRE CLARIFIED THE APPLICATION OF MOOTNESS DOCTRINE TO
`EVALUATING A DEFENDANT’S PROOF OF MOOTNESS........................................2
`
`II. UNDER FIKRE, APPLICANTS’ RELIGIOUS LIBERTY AND RETALIATION CLAIMS
`WERE AND ARE NOT MOOT ........................................................................................4
`
`
`III. SECRETARY AUSTIN’S HOSTILITY TO CONGRESS’S ORDER TO RESCIND HIS
`VACCINE MANDATE BARS HIS CLAIM OF MOOTNESS........................................7
`
`IV. GRANTING THE APPLICATION IS IN THE PUBLIC INTEREST BECAUSE IT
`WOULD FORCE THE SECRETARY TO REMOVE A MAJOR STUMBLING
`BLOCK TO RECRUITING CHAPLAINS, A NATIONAL SECURITY INTEREST
`GIVEN THE CURRENT WORLD SITUATION.............................................................8
`
`CONCLUSION .............................................................................................................................10
`
`CERTIFICATE AS TO FORM.....................................................................................................12
`
`i
`
`

`

`TABLE OF AUTHORITIES
`
`Cases:
`
`FBI v. Fikre, 601 U.S. ___, 144 S.Ct. 777 (2024) ................................................................. 1-7, 10
`
`Long v. Pekoske, 38 F.4th 417 (4th Cir. 2022) ................................................................................... 1,2, 5, 6
`
`Rules and/or Regulations
`
`S.CT. R. 15.8................................................................................................................................... 1
`
`ii
`
`

`

`APPLICANTS’ SUPPLEMENT TO THEIR APPLICATION FOR A WRIT OF
`INJUNCTION FOR INTERIM RELIEF
`
`To the Honorable John G. Roberts, Jr., Chief Justice of the United states and Circuit Justice for
`
`the Fourth Circuit:
`
`INTRODUCTION
`
`The Alvarado v. Austin petitioners in Case No. 23-717 filed an Application for a Writ of
`
`Injunction for Interim Relief, No. 23A858, on March 19, 2024.
`
`Parties to the Proceeding, Application (“Applic.”) at I; Rule 29.6 Disclosure Statement,
`
`id.; Statement of Related Cases, id. at ii- iii; and Jurisdiction, id. at iii, as presented in the
`
`Application remain unchanged.
`
`Pursuant to S.CT. R. 15.8, Applicants respectfully file this supplemental brief addressing
`
`two distinct but related topics that impact and support both this Application and the Applicant’s
`
`pending petition for certiorari, No. 23-717.
`
`First, FBI v. Fikre, 601 U.S. ___, 144 S.Ct. 771 (2024) addresses the criteria for a
`
`defendant to prove mootness, id. at 777-78. The Application at 15-16, § II.A, argued: “The Court
`
`is likely to grant a writ of certiorari on the issue of mootness.” Sections I and II below shows
`
`Applicants’ facts 12-31, Applic. at 8-12, which Fikre requires courts accept as true, 144 S.Ct. at
`
`778, preclude mootness as Respondents have failed to meet Fikre’s standard. Fikre’s emphasizes
`
`the courts’ “virtually unflagging obligation” to hear and resolve questions over which they have
`
`jurisdiction, id. at 777.
`
` Fikre expressly abrogated the Fourth Circuit’s decision in Long v. Pekoske, 38 F.4th 717
`
`(4th Cir. 2022) and the mootness standard therein that Respondents successfully advocated to
`
`affirm dismissal of the Applicants’ complaint, see App.747a-749a. Fikre was issued after the
`
`1
`
`

`

`filing of Petitioner’s petition and Application. It clarifies the application of the mootness
`
`doctrine and the voluntary cessation exception thereto for similar claims of religious liberty
`
`violations justified by the government on broad, yet undisclosed national security grounds.
`
`The second topic or factor that Applicants bring to the Court’s attention is the Navy
`
`Chaplain Corps’ April 5, 2024, “Quarterly Newsletter”, Supplemental Appendix 738a-39a
`
`(attached) presenting the Navy Chaplain Recruiting Numbers for FY (“fiscal year ”) 24, “20
`
`added with a goal of 82 (24%)” halfway through the FY. Section IV addresses the Application’s
`
`reference to the reported shortage of military chaplains as reflective of Secretary’s and DOD’s
`
`hostility to people of faith as shown in their attempt to purge the military of those who believe in
`
`following their conscience and their “malicious implementation of Congress’s 2023 Order to
`
`rescind the mandate”, Applic. at 10.
`
`REASONS TO GRANT THE APPLICATION
`
`I.
`
`FIKRE CLARIFIED THE APPLICATION OF MOOTNESS DOCTRINE TO
`EVALUATING A DEFENDANT’S PROOF OF MOOTNESS.
`
`Fikre covers known ground on the law of mootness in many respects, but in addition to
`
`expressly abrogating the Fourth Circuit’s decision in Long, it clarifies the standard defendants
`
`must meet to carry their burden of establishing mootness generally and specifically the showing
`
`required to demonstrate that it cannot reasonably be expected to resume the challenged conduct
`
`or policy.
`
`M Fikre restates mootness doctrine, making clear the respondents here cannot
`
`show mootness:
`
`M To find a lack of jurisdiction, the defendant accepts the complaint’s allegations unless
`
`denied or controverted. Fikre, 144 S.Ct. at 777.
`
`2
`
`

`

`M “A court with jurisdiction has a ‘virtually unflagging obligation’ to hear and resolve
`
`questions properly before it.” Id. (citation and quotation marks omitted).
`
`M To show mootness, the defendant—not the plaintiff—bears the “formidable burden”
`
`to show that “no reasonable expectation remains that it will return to its old ways.” Id. (interior
`
`quotation marks and alterations omitted).
`
`M A case’s procedural posture informs the mootness showing a defendant must make,
`
`which can be more difficult when a “case comes to [a court] in a preliminary posture, framed
`
`only by uncontested factual allegations and a terse declaration.” Id. at 779.
`
`M The foregoing “holds for governmental defendants no less than for private ones.” Id.
`
`at 777.
`
`All these known issues that Fikre restates support Applicants’ arguments that
`
`the complaint was not mooted when the Mandate was allegedly rescinded or by
`
`subsequent factual developments.
`
`What is new in Fikre is the rigor and focus applied to parsing the defendants’
`
`mootness evidence versus the foregoing mootness standards. In Fikre, the district court
`
`had dismissed Mr. Fikre’s complaint based on the government’s declaration that Mr.
`
`Fikre had been removed from the No Fly List. The Court affirmed the Ninth Circuit’s
`
`reversal.
`
`The government's declaration might mean that Mr. Fikre will not
`be placed on the No Fly List now based on what he did in the past. But,
`the Ninth Circuit reasoned, the declaration does not disclose what
`conduct landed Mr. Fikre on the No Fly List, and it does not ensure that
`he will “not be placed on the List if ... he ... engag[es] in the same or
`similar conduct” in the future. As a result, the [Ninth Circuit] concluded,
`the government had still failed to meet its burden of establishing that its
`allegedly unlawful conduct cannot reasonably be expected to recur.
`
`3
`
`

`

`Id. at 777-78 (citations omitted). The government’s removal of Mr. Fikre without any
`
`explanation of the factors or facts that the government actually relied on in deciding
`
`to place him on the No Fly List did not moot the case.
`
`Nor could the government carry its burden of showing that this action could not
`
`reasonably be expected to occur by submitting a declaration baldly asserting Mr. Fikre
`
`would not be placed on the list again based on “currently available information”
`
`because the declaration did not disclose what previously available information was
`
`used to place him on the list in the first place or whether this decision was based on
`
`constitutionally impermissible reasons.
`
`Viewed in that light, this case is not moot. To appreciate why, it is
`enough to consider one aspect of Mr. Fikre’s complaint. He contends that
`the government placed him on the No Fly List for constitutionally
`impermissible reasons, including his religious beliefs.
`Id. at 778 (citation omitted). To carry its burden of demonstrating mootness, and
`
`for the voluntary cessation exception to mootness, the government must disclose to the
`
`court—relying only “non-classified information” and discovery materials, but not
`
`“classified information”, id. at 780 (Alito, J., concurring)—the specific facts or factors
`
`were considered in making the challenged decision or taking the challenged action.
`
`This information is required for the reviewing court to determine what the government
`
`is committing not to do or not to consider and whether the challenged actions are likely
`
`to recur.
`
`II.
`
`UNDER FIKRE, APPLICANTS’ RELIGIOUS LIBERTY AND
`RETALIATION CLAIMS WERE AND ARE NOT MOOT.
`
`This Court must reject the Fourth Circuit’s dismissal of Applicants’ complaint
`
`4
`
`

`

`and their appeal as moot, because it directly conflicts with this Court’s decision in
`
`Fikre, which expressly abrogated the Fourth Circuit’s decision in Long and the
`
`mootness standard therein on which the government expressly relied in successfully
`
`moving to dismiss. App. 747a-749a.
`
`Unlike in Fikre, the government’s May 16, 2023, motion to dismiss consists solely
`
`of a brief and does not include any declarations attesting to factual developments after
`
`the mandate” alleged rescission January 10, 2023. Instead, the only declarations
`
`supporting the motion are from U.S. Army Colonel Kevin Mahoney (dated July 11,
`
`2022), U.S. Navy Admiral William Merz (dated Aug. 9, 2022), U.S. Air Force Major
`
`Matthew Streett (dated July 7, 2022), and U.S. Air Force Colonel Elizabeth Hernandez
`
`(dated Apr. 7, 2022). These declarations did not provide any factual information
`
`whatsoever regarding the rescission of the mandate, nor could they have provided the
`
`Fourth Circuit with any factual basis for finding that the government carried its
`
`burden of showing that the challenged conduct could not reasonably be expected to
`
`recur or career injuries cured. Respondents never disputed Applicants’ identified
`
`injuries caused by filing a religious accommodation request (“RAR”), e.g., promotion
`
`failures, separation. Under these facts, neither Respondents nor the lower courts can
`
`show mootness under Fikre.
`
`The Court’s decision in Fikre supports granting the petition and ordering a full
`
`merits briefing—or alternatively to summarily grant, vacate the lower courts’
`
`decisions, and remand to be decided in accordance with Fikre. This resolution and
`
`relief is consistent with Fikre, and the Court’s express abrogation of the Fourth
`
`5
`
`

`

`Circuit’s decision in Long, which underpinned the government’s successful motion to
`
`dismiss, see App.747a-749a, because the petition presents largely similar facts and
`
`legal issues.
`
`Applicants here, like Mr. Fikre, allege substantial violations of their religious
`
`liberties, which the government has sought to justify on national security grounds.
`
`While the government has strenuously denied what Applicants allege—that the
`
`military adopted a uniform “No Religious Accommodation Policy”—it has refused to
`
`disclose whatever the actual facts or factors considered may be that could have
`
`resulted in denying 99 percent or more of RARs. Nor has it explained how or whether
`
`these purported actual facts or factors included constitutionally impermissible actions
`
`or criteria alleged by Applicants. Identification and disclosure of these facts and factors
`
`are required preconditions for courts to determine what the government has done in
`
`the past and what it commits not to do in the future. Here, the government’s
`
`declarations regarding post-rescission policies is not just sparse, it is non-existent; as
`
`such it necessarily “falls far short of demonstrating that it cannot reasonably be
`
`expected to do again what it is alleged to have done in the past.” Id. at 778 (citation
`
`omitted).
`
`The government has never claimed that its decisions are based on classified
`
`information that need not be disclosed. Id. at 780 (Alito, J., concurring). Accordingly,
`
`to carry its burden under Fikre, it must disclose the basis for the challenged actions,
`
`and this showing must include post-rescission declarations or evidence that could
`
`support a finding that the challenged actions cannot reasonably be expected to recur.
`
`6
`
`

`

`Here, Respondents failed to provide any declarations or other factual support that
`
`could have carried their burden under Fikre, and the Fourth Circuit’s dismissal must
`
`therefore be reversed, especially since it was on notice of DOD’s continuing retaliation
`
`and irreparable injuries that are unaddressed.
`
`Finally, under the rigor and focus that Fikre applies to analyzing mootness, the
`
`case was not moot because the complaint stated claims on which relief could have been
`
`granted.
`
`III.
`
`SECRETARY AUSTIN’S HOSTILITY TO CONGRESS’S ORDER TO RESCIND
`HIS VACCINE MANDATE BARS HIS CLAIM OF MOOTNESS
`
`Fikre addressed the question whether the defendant had to repudiate its previous
`
`activities or admit its actions were wrong to establish that it would not continue the challenged
`
`action at a later time, after the case’s dismissal. The Court stated, “What matters is not whether a
`
`defendant repudiates its past actions, but what repudiation can prove about its future conduct. It
`
`is on that consideration alone—the potential for a defendant’s future conduct—that we rest our
`
`judgment.” 144 S.Ct. at 779. Here, the Secretary has made it abundantly clear he does not intend
`
`to fully rescind his mandate.
`
`The Chaplains’ opposition to DOD’s 4th Cir. mootness motion, 23-1419, ECF No. 14 at
`
`7-8, Fact 13, highlighted the Secretary and DOD’s hostility to Congress’ order to rescind the
`
`mandate. Rather than acknowledge that Congress has the authority to make choices about
`
`vaccines that did not protect, DOD made clear it did not accept the meaning of “rescind.”
`
`13. The Assistant Secretaries of DoD and each Armed Forces testified to the
`House Armed Services Committee (“HASC”) on 2/28/2023 concerning the
`impact of COVID and DoD’s compliance with the NDAA’s order to rescind the
`Mandate. CA70-80 (Excerpts from Transcript of HASC hearing (hereafter
`“HASC TR”)).
`A.
`
`DoD showed no remorse for issuing the Mandate, identified no
`
`7
`
`

`

`harms, and agreed DoD opposed and disagreed with the NDAA.1
`B.
`DoD stated it was still considering whether to punish those who
`had refused the COVID vaccine; DoD’s mantra in response to questions about
`fixing records and/or restoring service members and their careers who had refused
`the vaccine was they “violated a lawful order.” CA71-72, 75 (HASC TR at
`timestamps 27:52, 28:34, 29:30, 29:46, 30:38:31:00, 44:58).
`C.
`DoD showed no repentance or acknowledgment that issuing the
`Mandate or changing the definitions of vaccine and vaccination were beyond
`DoD’s authority and no concern for the damage done to the careers and lives of
`military personnel or exacerbating existing shortages of skilled personnel,
`including Chaplains who are below their authorized strength, or overseeing and
`participating in the destruction of the volunteer military service.
`
`DOD’s belief that the vaccine refusers violated a “lawful order” shows it has not
`
`accepted the reality that “rescind” means the mandate became void ab initio, and therefore could
`
`not be considered a lawful order once Congress spoke.
`
`The Chaplains’ Petition Reply at 4 points out that DOD’s failure to restore the chaplains
`
`to their status before the mandate, a necessary condition for rescission, was an attempt to do
`
`what it could not do directly, separate chaplains who believe in following their conscience.
`
`Instead, DOD purges them indirectly through chaplains’ failures of selection due to the bad
`
`reports given in retaliation for filing RARs. Only this Court can correct that behavior. Failure to
`
`do so creates the appearance of approving religious retaliation, rewarding lawlessness.
`
`IV.
`
`GRANTING THE APPLICATION IS IN THE PUBLIC INTEREST BECAUSE IT
`WOULD FORCE THE SECRETARY TO REMOVE A MAJOR STUMBLING
`BLOCK TO RECRUITING CHAPLAINS, A NATIONAL SECURITY INTEREST
`GIVEN THE CURRENT WORLD SITUATION
`
`The Application on page 2 states “DOD’s open hostility to religion likely corresponds to
`
`the Armed Services’ recent and repeated failure to meet their recruiting goals.”
`
`The Chaplains’ Fact 30 (page 12) specifically drew attention to the shortage of military
`
`chaplains and quoted RADM Todd’s 11/23/23 public broadcast.
`
`1 https://www.cnn.com/2022/12/07/politics/biden-military-covid-mandate-ndaa /(last
`accessed 4/22/2024). WH publicly calls Congress’ mandate rescission direction a “mistake.”
`
`8
`
`

`

`30. The military is short chaplains, and the number of military chaplains is
`plummeting. Ivonne Spinoza, The Complex Role and Diverse Array of
`Chaplains in the Military, Public Broadcasting Service (Nov. 23, 2023)
`(App:683a-693a); RADM Gregory N. Todd [Navy Chief of Chaplains],
`The Navy needs more chaplains: All three sea services want and need
`more chaplain—but the recruiting deficit is extreme, Religion News
`Service (May 15, 2023) (App:673a-675a).
`
`The Chaplains Application again mentions recruiting on Page 38:
`
`Given the Armed Services’ shortage of chaplains and their recent and repeated
`failure to meet their recruiting goals, this Court should not only defer to the
`support that Congress—with the President’s assent—showed for people of faith in
`the 2023 NDAA but also resoundingly reject DoD bureaucrats’ indifference and
`antipathy.
`
`The April 5, 2024, Navy Chaplain Corps “Endorsers Quarterly Newsletter” is in fact an
`
`update of a critical and continuing problem that impacts our National Security. Supplement
`
`Application App. 738a-39a. The other services have not shared their recruiting results.
`
`The “Endorsers Quarterly Newsletter”, dated April 5, 2024, is a message from the Navy
`
`Chief of Chaplains providing an update on the Navy’s recruiting efforts. The FY 24 “Recruiting
`
`Numbers” show “As of March 31, 2024":
`
`Active Duty: 20 added with the goal of 82 (24%)
`
`Reserve Duty: six sided with the goal of 15 (40%)
`
`Chaplain Candidates: 15 added with the goal of 40 (38%)
`
`The message is that halfway through FY 24 the Navy has met only 24% of its Active
`
`Duty Chaplain recruiting goal. Applicants ask the Court to take judicial notice of the hostilities
`
`involving the Navy now taking place in the Middle East and threats thereof in other locations
`
`worldwide. The facts the Navy is over 100 chaplain short as explained by RADM Todd on page
`
`2, his plea, “We desperately need chaplains”, id., and the Navy’s involvement in significant
`
`active combat in the Middle East, with other major power threats in Europe and the Far East
`
`9
`
`

`

`suggest the chaplain shortage is a serious problem.
`
`A 7/16/2003 Epic Times article by JM Phelps, “In-Depth: Military Families No Longer
`
`Want Their Children to Enlist”, https://www.theepochtimes.com/audio/us/in-depth-military-
`
`families-no-longer-want-their-children-to-enlist-5402430 (last checked 4/19/24), is not alone
`
`reporting serious moral problems due to DOD policies.
`
`RADM Todd at 2 wants names of potential chaplains “to inform them of this amazing
`
`ministry.” It would help if he were able to respond to questions about chaplains punished for
`
`following their conscience that this Court has enjoined DOD from further retaliation and is
`
`fixing the destroyed careers. The Petitioners Reply at 9-13 shows that is an easy thing for the
`
`Secretary to do, the problem is he will not fix anything absent a Court order.
`
`Theses 38 Applicants were the named plaintiffs in a putative class action. Other
`
`chaplains were asking to join or seeking information when the case was dismissed. A military
`
`area defense counsel based on her interviews reported to the undersigned the class would be
`
`more than several hundred. DOD has not reported how many chaplains requested RARs. The
`
`point is this is not small problem.
`
`CONCLUSION
`
`The record shows that the Secretary cannot meet FBI v. Fikre’s criteria for mootness. He
`
`has not and will not return chaplains who filed RARs to their pre-mandate status nor addressed
`
`the continuing retaliation resulting from his policies and violation of the law. The record is also
`
`clear the Secretary does not intend to repair the destroyed careers of chaplains who requested a
`
`religious accommodation concerning the Covid alleged vaccine. This is contrary to Congress’s
`
`specific order to rescind the mandate. An injunction should issue as requested to protect these
`
`chaplains from further destruction while the petition process unfolds and thereafter.
`
`10
`
`

`

`Respectfully submitted,
`
`Arthur A. Schulcz, Sr.
`Counsel of Record
`Chaplains Counsel, PLLC
`21043 Honeycreeper Place
`Leesburg, Virginia 20175
`(703) 645-4010
`art@chaplainscounsel.com
`
`11
`
`

`

`CERTIFICATE AS TO FORM
`
`Pursuant to Sup. Ct. Rules 21.2(c) and 33.2, I certify that the foregoing
`
`Supplement is proportionately spaced, has a typeface of Times New Roman, 12 points,
`
`and contain 2,874 words, less that the 3,000 word limit excluding this Certificate as to Form, the
`
`Table of Authorities, and the Table of Contents
`
`Dated: April, 22, 2024
`
` Respectfully submitted,
`
`/s/
`ARTHUR A. SCHULCZ, Sr.
`Counsel of Record
`CHAPLAINS’ COUNSEL, PLLC
`21043 Honeycreeper Place
`Leesburg, Virginia 20175
`(703) 645-4010
`art@chaplainscounsel.com
`Counsel for Applicants
`
`12
`
`

`

`No. 23A858
`In the Supreme Court of the United States
`___________________________________________
`
`ISRAEL ALVARADO, ET. AL.,
`Applicants,
`v.
`LLOYD AUSTIN, III, ET. AL.,
`Respondents.
`___________________________________________
`
`On Application for a Writ of Injunction Pending Petition for a Writ of Certiorari
`
`___________________________________________
`
`To the Honorable John G. Roberts, Jr., Chief Justice of the United States and
`Circuit Justice for the Fourth Circuit
`
`___________________________________________
`
`APPENDIX FOR SUPPLEMENTAL BRIEF IN SUPPORT OF ALVARADO, ET AL,
`APPLICATION FOR WRIT OF INJUNCTION PENDING PETITION FOR A WRIT OF
`CERTIORARI
`___________________________________________
`
`BRANDON JOHNSON
`DEFENDING THE REPUBLIC
`2911 Turtle Creek Blvd.
`Suite 300
`Dallas, Texas 75219
`(214) 707-1775
`bcj@defendingtherepublic.org
`
`J. ANDREW MEYER
`FINN LAW GROUP, P.A.
`8380 Bay Pines Blvd.
`St. Petersburg, Florida 33709
`(727) 709-7668
`ameyer@finnlawgroup.com
`
`ARTHUR A. SCHULCZ, SR.
` Counsel of Record
`CHAPLAINS COUNSEL, PLLC
`21043 Honeycreeper Place
`Leesburg, Virginia 20175
`(703) 645-4010
`art@chaplainscounsel.com
`
`Counsel for Applicants
`
`

`

`ENDORSERS
`
`Quarterly Newsletter
`
`April 5, 2024
`
`Recruiting Numbers FY24
`As of March 31, 2024
`Active Duty: 20 added with a goal of 82 (24%)
`Reserve Duty: 6 added with a goal of 15 (40%)
`Chaplain Candidates: 15 added with a goal of 40 (38%)
`
`Accessions Board Notes
`
`Designator requirements
`
`On 3 April 2024, we held a Chaplain
`Appointment and Retention Eligibility
`Advisory Group (CARE-AG) to review
`applications and provide
`recommendations of the best and fully
`qualified to the Chief of Chaplains. The
`applicants selected as Active and
`Reserve component Chaplains or
`Chaplain Candidate Program Officers
`must meet the Professional Naval
`Chaplaincy requirements, have proven
`pastoral leadership with the highest
`potential, facilitate religious ministry
`in a pluralistic environment, care for
`all Service members, and provide
`relevant advice to commanders. The
`next CARE-AG will be held 15 May 2024
`and will ensure applicants are the best
`qualified to serve in Naval Chaplaincy.
`
`Direct Accession (4100) & Direct Commission (4105)
`
`RO ENDORSEMENT: DD2088
`Email Chief of Chaplain’s office: chiefofchaplains1@us.navy.mil
`EDUCATION: Bachelors degree ≥ 120 semester hours
`3.0+ GPA on a 4.0 scale (recommended)
`Must have a qualifying graduate degree ≥ 72 semester hours
`3.4+ GPA on a 4.0 scale (recommended)
`EXPERIENCE: 2 years of full-time ministry experience, post grad. degree
`AGE: Commissioned prior to the age of 42
` U.S. Citizenship
`Requirements are the same for Active Duty and the Reserve Component
`
`Chaplain Candidate Program Officer, CCPO (1945)
`
`RO ENDORSEMENT: DD2088
`Email Chief of Chaplain’s office: chiefofchaplains1@us.navy.mil
`EDUCATION: Bachelors Degree > 120 semester hours
`3.0+ GPA on a 4.0 scale (recommended)
`Enrolled full-time in a qualifying graduate school (at least 72 hours)
`Maintain GPA of 3.0+ while in the program
`AGE: Commissioned prior to the age of 38
`U.S. Citizenship
`EXPERIENCE: No ministry experience required to become a CCPO
`WHILE IN THE PROGRAM:
`Complete ODS, PNC-BLC Phase I, and OJT
`Develop Pastoral identity while in the program
`
`Facebook
`
`Instagram
`
`Twitter
`
`LinkedIn
`
`Application 738a
`
`

`

`Message from The chief of chaplains
`
`Dear Partners in ministry to Sea Service personnel and their families,
`
`I pray this finds you strengthened by a connection to the Divine, participating in a community of faith, sacrificing for a greater
`good, or living a life directed by meaning, purpose, and values. These four avenues are proven means leading to Spiritual
`Message from the board:
`Readiness and are championed by the Navy Chaplain Corps.
`This will be the section we use to copy and paste the
`Let me share an opportunity with which I believe you can help.
`message the board sends out to the field thanking them for
`preparing quality candidates to serve in the Navy Chaplain
`Corps. This will be the section we use to copy and paste the
`message the board sends out to the field thanking them for
`The Department of the Navy has asked the Navy Chaplain Corps to grow from 932 authorized billets to 958 by FY28. Several
`preparing quality candidates to serve in the Navy Chaplain
`factors have influenced this need for growth. Navy Chaplains are proving themselves to be a valuable resource in
`Corps. This will be the section we use to copy and paste the
`strengthening our service members. Current combat operations in the Red Sea have accentuated this truth, and potential
`future conflicts only serve to underscore it. Additionally, rising rates of suicide have signaled a greater need for mental health
`resources. Chaplains are well-suited to address sub-clinical concerns, freeing up mental health providers to address more
`acute clinical needs. Finally, studies have identified new areas of ministry that need to be addressed. Simply put, we need
`more chaplains.
`
`The challenge is that we currently have 869 chaplains on active duty. This deficit is compounded by the fact that we have
`been unable to recruit enough chaplains to fill the growing need. As of March 31, 2024, we have only recruited 20 chaplains to
`serve on active duty with a goal of 82 by the end of the fiscal year. Additionally, we have only recruited six chaplains out 15
`needed in the reserve community, and only 15 Chaplain Candidates toward our goal of 40. These shortfalls will continue to
`compound from year to year unless we turn it around now. This is where I need your help.
`
`First, please pray for more chaplains. As people of faith, we cry out to God in our time of need. We desperately need
`chaplains, so please pray daily that God would send them.
`
`Secondly, please share with everyone that the Navy wants the ministry of Navy Chaplains. In talking with Navy, Marine Corps,
`and Coast Guard leaders, the consistent message has been we need more chaplains. I believe there has never been a time in
`my career when the Chaplain Corps was more appreciated than right now. I am asking you to share this message with every
`interested person in your faith group. Please help me tell the story about the fulfilling ministry of being a Navy Chaplain.
`
`Finally, I am asking you to send us names of possible candidates. We would relish the opportunity to talk with those whom
`you think have what it takes to be Navy Chaplains, even if they have never considered it. We would simply like the
`opportunity to inform them of this amazing ministry. If you have a candidate, please send the names and contact information
`to N312_Chaplain_Program_Accessions@us.navy.mil.
`
`Again, the success of Professional Naval Chaplaincy rests on a partnership between you, our religious organizational partners,
`and the Department of the Navy. Thank you for your faithfulness to that covenant.
`
`Sincerely Yours,
`
`Application 739a
`
`

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