It turns out that Carly Simon’s famous lyrics, “You’re so vain…” don’t just apply to Warren Beatty. In the case of one federal agency employee, they were an apt descriptor of her own narcissistic personality – at least according to her employing agency, which deemed her a national security risk because of it.

If that sounds incredible, imagine what it was like actually reading a Statement of Reasons that outlined as purported security risks the following facts and circumstances:

  • The clearance holder was observed by colleagues on multiple occasions preening before a mirror at her desk
  • The clearance holder was known to frequently re-apply makeup, lipstick, and perfume throughout the work day
  • The clearance holder refused to partake in junk food brought into the office by a colleague because she was watching her figure
  • The clearance holder wrote fictional romance stories, which she shared online, with a lead character of the same name
  • The clearance holder posted excessive “glamour shots” and “selfies” on social media

I’ve changed a few details and am withholding the name of the agency in question to preserve the clearance holder’s privacy. But the thrust of the allegations is entirely accurate and serves to reinforce a sad reality: The national adjudicative guidelines for security clearances are written so broadly that they can be applied to almost any fact pattern security officials dream up. Even one as ridiculous, patronizing, and sexist as what you just read.

This particular clearance holder opted to represent herself in the appeal process (bad idea), so I regrettably don’t know the outcome of her case. I suspect, however, that the allegations were a pretext for something else – reading between the lines, that she rubbed people in the office the wrong way – and the outcome was an effectively predetermined human resources action in disguise.  It wouldn’t be the first time I’ve seen something like that, although it’s usually not such an obvious “screw you”.

The agency’s theory of the case, if it was to be taken seriously, was that this woman’s narcissism was so far off the charts that she could be theoretically compromised by a dashing male spy who showered her with compliments and attention, sweeping her off her feet. Indeed, the SOR conjured up images of a cheesy romance novel cover with Fabio shirtless atop a horse. Unfortunately, it was no laughing matter for the clearance holder, who faced losing her career, livelihood, and dignity all over claims that could be boiled down to some sort of purported and unidentifiable personality disorder.

Had my office defended the case, we would have attacked it on numerous grounds. Among them, that agency security officials are not qualified to diagnose narcissism or personality disorders that may increase vulnerability to manipulation; that the allegations were insufficient to raise a concern under any adjudicative guideline; and that the allegations evidenced unlawful gender discrimination that could be ripe for judicial review notwithstanding Supreme Court precedent that generally bars courts from second-guessing federal agency security clearance decisions.

Since none of those challenges likely came to pass with the clearance holder representing herself, consider this a cautionary tale for all you clearance holders by day and romance novel writers, selfie-stick users, and social media influencers by night. There are dangerously few safeguards in place to protect against abuses of the security clearance system – even blatantly obvious ones. Guard your clearance jealously.

 

This article is intended as general information only and should not be construed as legal advice. Consult an attorney regarding your specific situation. 

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Sean M. Bigley retired from the practice of law in 2023, after a decade representing clients in the security clearance process. He was previously an investigator for the Defense Counterintelligence and Security Agency (then-U.S. Office of Personnel Management) and served from 2020-2024 as a presidentially-appointed member of the National Security Education Board. For security clearance assistance, readers may wish to consider Attorney John Berry, who is available to advise and represent clients in all phases of the security clearance process, including pre-application counseling, denials, revocations, and appeals. Mr. Berry can be found at https://www.berrylegal.com/.