Bilecki Answers Orlando Reserve Major’s Leadership Investigation; No Adverse Action

Bilecki Answers Orlando Reserve Major’s Leadership Investigation; No Adverse Action

July 2024

Orlando, Florida

Army Reserve Major – O-4

Allegations: Counterproductive Leadership; Dereliction of Duty; Inappropriate Comments; Failure to Treat a Peer with Dignity and Respect

Facts

This was a Major in the U.S. Army Reserve serving as Chief of Mobilization & Readiness at a Reserve Sustainment Command in Orlando, facing an AR 15-6 administrative investigation that had returned substantiated findings on counterproductive leadership, dereliction of duty in mobilization and CRE funding, inappropriate comments to a junior officer, and failure to treat a peer Major with dignity and respect. For an O-4 Reserve officer, an adverse action package built on substantiated counterproductive leadership findings runs to GOMOR, OER referral, and Show Cause Board exposure.

The investigation had a context the AR 15-6 file did not put in front of the disposition authority. Our client had filed an IG complaint against the higher Theater Sustainment Command in late September 2023 over the absence of authoritative mobilization and CRE documents. The IG closed that complaint in May 2024 as an assistance inquiry: the IG had obtained the missing documents and acknowledged the gap our client had flagged. Five weeks later, the AR 15-6 substantiating findings against our client were issued.

The defense AR 15-6 Rebuttal went in early July 2024. It was drafted and signed by Tim Bilecki of BLG.

The rebuttal had two parallel tracks.

Tim Bilecki used the IG complaint and the documents obtained through that inquiry to explain what our client had been trying to resolve. He also raised the timing of the later AR 15-6 and the roles of the officers whose conduct the complaint had questioned. The substantive accounts of the alleged conduct came from the same higher headquarters officers our client's IG complaint had questioned.

The defense supplemented the record by interviewing twenty-one witnesses across the chain of command. The witness record put the peer Major on the documentary record for ad hoc workarounds outside her chartered authority, unauthorized vehicle transfers, and ADOS funding requests for non CRE personnel she worked civilian side with. The "counterproductive leadership" the AR 15-6 had attached to our client was, on the defense record, the peer Major's own conduct, surfaced for the first time at the disposition stage.

No adverse action followed. No GOMOR. No OER referral. No administrative separation. No Board of Inquiry.

Result: No adverse action. No GOMOR. No OER referral. No AdSep. No Board of Inquiry.

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FAQ

Q: What did the IG inquiry add to the rebuttal?
It documented the problem our client had raised and the effort required to obtain the missing mobilization and funding documents. Bilecki used that history to explain his client's actions and to question the timing and sources of the later investigation. The timing supported a reprisal argument; it did not, by itself, establish unlawful reprisal.

Q: How did the defense develop the other side of the leadership allegations?
The defense interviewed twenty-one witnesses. Their accounts allowed Bilecki to address the disputed workarounds, vehicle transfers and funding requests in detail, rather than simply deny the leadership label. The rebuttal gave the command a substantially fuller account of the workplace conflict. No reprimand, adverse OER, separation or Board of Inquiry followed.