Hanna v. Secretary of the Army

Mary Hanna (plaintiff) was a captain in the US Army (defendant). Hanna joined the army through its Health Professions Scholarship Program (HPSP). Through the program, the army paid for Hanna’s medical school, and afterward Hanna would serve active duty. In Hanna’s HPSP application, she stated that she possessed the strength and determination to practice medicine in the army. During Hanna’s residency and shortly before she was scheduled to report for active duty, Hanna filed an application for discharge as a conscientious objector (CO), claiming that war was incompatible with her Christian faith. In her CO application, Hanna stated that her faith had been uncertain at the time of her HPSP application but that her faith had solidified by the time of her CO application. The colonel who received Hanna’s application recommended that the army deny the application, in part because of the late timing. Hanna was interviewed by an army chaplain and psychiatrist, who both questioned her sincerity. Thereafter, an army officer conducted an investigation, determined that Hanna’s belief was sincere, and recommended that her application be approved. All officers who subsequently reviewed the investigator’s report agreed that Hanna’s belief was sincere and recommended approval. However, the army’s review board denied the application, finding Hanna’s belief insincere and the late timing of her application questionable. Hanna challenged the denial in district court. The army alleged that Hanna’s statement in her HPSP application (that she had the strength and determination to practice medicine in the army) was inconsistent with Hanna’s statement in her CO application (that her faith was uncertain at the time of her HPSP application). The army argued that the inconsistent statements coupled with the questionable timing of Hanna’s CO application provided a sufficient basis in fact to find that Hanna’s beliefs were insincere. However, the review board never suggested that Hanna’s statements were inconsistent. The district court granted Hanna’s petition, held that the review board had no basis in fact to deny Hanna’s application, and enjoined the army from forcing Hanna into active duty. The army appealed.