Short answer: Officers fight a toxic leadership GOMOR by attacking the AR 15-6 investigation behind it, because these reprimands usually rest on anonymous climate surveys and selected subordinate interviews. Civilian military defense lawyer Alexandra González-Waddington of Gonzalez & Waddington advises that this is a case for rebuttal, not quiet acceptance: get the full investigation, expose a one-sided method, put each allegation in context with documents, and bring your own witnesses.
In this video, Alexandra González-Waddington explains what a toxic leadership finding is, why these cases are winnable, and the six-part rebuttal officers and senior NCOs use to fight back.
What is a toxic leadership allegation in the Army?
“Toxic leadership” is not a crime under the UCMJ. It is a term from AR 600-100 and Army leadership doctrine that describes a pattern of self-centered, abusive, or demeaning behavior that harms the unit and its people.
It turns into a GOMOR when a command climate survey shows a problem, an Inspector General complaint comes in, or a subordinate makes an allegation. A commander appoints an AR 15-6 investigating officer, who interviews people and concludes the pattern exists.
What usually comes with a toxic leadership GOMOR?
A toxic leadership GOMOR rarely arrives alone. It usually comes with a relief for cause and a referred evaluation.
For officers, a permanently filed GOMOR also means a likely promotion review and a possible show-cause board. Each of these actions has its own process, and each one has to be fought on its own terms.
Why are toxic leadership GOMORs often beatable?
The investigating officer is usually a fellow officer, not a lawyer, with little training in interviewing witnesses. The witnesses are often subordinates who were counseled, denied leave, or held to a standard they resented.
“Toxic” is vague enough that demanding results, correcting poor performance, and being direct can all be recast as abuse. And many 15-6 reports quote the three harshest interviews while ignoring the fifteen that called the leader tough but fair.
How do I write a rebuttal to a toxic leadership GOMOR?
This is not a case for simply accepting responsibility and asking for mercy. A strong rebuttal does six things:
- Get the complete 15-6. Request every interview summary, exhibit, the appointment memo, and the legal review. If interviews were done but left out, ask for them.
- Attack the method. Were witnesses sworn? Were questions leading? Were disciplined soldiers identified as such? Did the investigator interview anyone who supported you?
- Reframe the conduct with documents. Answer each allegation with records, such as the counseling packets and safety directives that show you were enforcing standards, not abusing people.
- Bring your own witnesses. Peers, superiors, subordinates, and prior commanders who will say what the investigation left out, plus your prior evaluations.
- Address the climate survey. Surveys are anonymous and unverified, and they often reflect a deployment, a reorganization, or a predecessor’s problems. Show the trend and the context.
- Ask for withdrawal, then local filing. Argue the GOMOR, the relief for cause, and the referred evaluation separately.
What mistakes should officers avoid in a toxic leadership case?
Do not contact the subordinates who made statements against you. That can look like retaliation and create a new problem.
Do not write an angry rebuttal, because anger confirms the allegation. And do not let a relief for cause go through without a fight; a relief-for-cause evaluation can do more long-term damage than the GOMOR itself.
What to do right now
- Find the response deadline in the GOMOR memo and request an extension in writing to get the full investigation.
- Request the complete AR 15-6 file, including all interviews, exhibits, and the legal review.
- Collect your prior evaluations, counseling records, and unit directives that explain your decisions.
- Make a list of peers, superiors, and subordinates who will give statements on your leadership.
- Do not contact any witness who spoke against you.
- Talk to a military defense lawyer before you respond to the GOMOR, the relief, or the evaluation.
Key takeaways
- Toxic leadership is a term from AR 600-100 and Army doctrine, not a UCMJ offense.
- These GOMORs rest on AR 15-6 investigations that are often one-sided and run by untrained investigators.
- Enforcing standards is not toxic leadership, and documents can prove the difference.
- Fight the GOMOR, the relief for cause, and the referred evaluation as separate actions.
- Never contact adverse witnesses, and never write your rebuttal in anger.
Frequently asked questions
Can I be punished for toxic leadership under the UCMJ?
Toxic leadership itself is not a UCMJ offense. Specific conduct, such as maltreatment under Article 93, can be charged, but most toxic leadership cases are handled with administrative actions like a GOMOR, relief for cause, and a referred evaluation.
Can I see the AR 15-6 investigation used against me?
You should receive the materials the general relied on in issuing the GOMOR. If the packet is incomplete or interviews are missing, request them in writing and ask for more time to respond.
Does a toxic leadership GOMOR end an officer’s career?
Not always. A permanent filing often leads to a promotion review or show-cause board, but a rebuttal that exposes a one-sided investigation can lead to withdrawal or local filing. Your response is your best chance to change the outcome.
Should I get statements from my current subordinates?
Be careful. Statements from supportive subordinates can help, but reaching out to anyone in your former unit while an investigation is open can look like pressure. Have your lawyer guide who to ask and how.
Related questions
- An AR 15-6 investigating officer wants to interview me: what should I do?
- Army officer elimination and show-cause boards
- Officer vs. enlisted GOMORs: why your defense strategy must be different
Video transcript
Read the full transcript of this video
You’re an officer or a senior NCO and you’ve been reprimanded for toxic leadership. How do you fight back? By attacking the investigation that produced the finding because toxic leadership general officer memorandums of reprimand rest on AR 15-6 investigations built from anonymous climate surveys and subordinate interviews and those investigations are often the weakest part of the case. I’m Alexandra González-Waddington, civilian military defense lawyer and co-founder of Gonzalez & Waddington. These allegations have ended more commands than any other in the last decade and they’re beatable when the response is built right. Here’s how.
First, understand what you’re facing. Toxic leadership isn’t an offense under the UCMJ. It’s a term from AR 600-100, an Army doctrine describing a pattern of self-centered, abusive, or demeaning leadership that harms the unit. It becomes a general officer memorandum of reprimand when a command climate survey shows a problem, an IG complaint comes in, or a subordinate makes an allegation and a commander appoints an AR 15-6 investigating officer who interviews people and concludes the pattern exists. The general officer memorandum of reprimand usually comes with a relief for cause, a referred evaluation, and for officers, the near certainty of a promotion review board and possible show cause.
Second, why these cases are winnable. The investigating officer is usually a peer, not a lawyer, with no training in interviewing. The witnesses are subordinates who may have been counseled, denied leave, or held to a standard they resented. Toxic is undefined enough that demanding results, correcting substandard performance, and being direct can all be recast as abuse. And the 15-6 report frequently quotes the harshest three interviews and ignores the 15 that said the leader was tough but fair.
Third, the response strategy. This is not a case for accepting responsibility and mitigating. This is a case for rebuttal.
One, get the complete 15-6. Every interview summary, every exhibit, the appointment memo, and the legal review. You’re entitled to the packet the general relied on. If interviews were done but not included, ask for them.
Two, attack the methodology. Were witnesses interviewed under oath? Were leading questions used? Were the people who’d been disciplined by you identified as such? Did the investigating officer interview anyone who supported you? A rebuttal that shows the investigation was one-sided gives the general a reason to doubt the finding.
Three, reframe the conduct. Take each specific allegation and put it in context with documents. The allegation that I berated the platoon after the range failure. Attached is the counseling packet showing three prior safety violations and the brigade safety directive I was enforcing. Standards enforcement is not toxicity and the documents prove which one it was.
Four, bring your own witnesses. Peers, superiors, and subordinates who’ll say what the 15-6 left out. Prior commanders, your prior evaluations, especially any that praise your leadership. A pattern of strong evaluations followed by one investigation is itself evidence.
Five, address the climate survey directly. Surveys are anonymous, unverified, and often reflect a unit under stress for reasons that have nothing to do with you. A deployment, a reorganization, a predecessor’s problems. Show the trend and the context.
Six, ask for withdrawal and if not, local filing. And argue the relief for cause and the referred evaluation separately because each has its own process.
Fourth, what not to do. Don’t contact the subordinates who made statements. Don’t submit a rebuttal that reads as angry because that confirms the allegation. And don’t let the relief happen without a fight. A relief for cause evaluation is often more damaging than the general officer memorandum of reprimand.
So, toxic leadership general officer memorandum of reprimand. How do officers fight back? Get the 15-6, attack the method, reframe the facts with documents, bring your witnesses, and never write in anger. I’m Alexandra González-Waddington, a civilian military defense lawyer and co-founder of Gonzalez & Waddington. We defend service members worldwide facing military investigations, courts-martial, administrative separation boards, and military disciplinary actions. If your career, reputation, or freedom is on the line, you need experienced military defense lawyers fighting for you. When the government builds a case, we build your defense. Visit ucmjdefense.com or call 1-800-921-8607 for a free, confidential consultation.
Talk to a military defense lawyer
Gonzalez & Waddington helps service members worldwide respond to GOMORs and letters of reprimand, Article 15s, investigations, courts-martial, and administrative separation boards. Michael Waddington, a former Army JAG officer, has been a lawyer for over 25 years. Call 1-800-921-8607 or visit ucmjdefense.com for a confidential consultation.
This article is general information, not legal advice. Every case is different, and reading it does not create an attorney-client relationship.

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