The complication, as noted, was consistency. If the board was applying a strict reading of the civilian contractor exclusion, Leonard Wood should also have been excluded, since he had been a contract surgeon during the period of his award-eligible service. The board did not reach that conclusion. The specific reason — whether it was Nelson Miles’s recommendation of Wood that protected his medal, whether there was a distinction in Wood’s case the board considered dispositive, or whether the board simply applied its standards inconsistently — is not fully clear from the available record.
The 1917 board’s decisions were institutional and final within the Army’s own authority. They were also not legally subject to challenge by recipients: the Judge Advocate General’s finding that the Army could not compel return of medals was cold comfort for Walker, since the rescission was not about the physical object but about the official recognition and the name on the rolls.
## The 1977 Decision: What the Board Found
The Army Board for Correction of Military Records, reviewing Walker’s case in the mid-1970s, was not bound by the 1917 board’s conclusions. The Board for Correction of Military Records existed precisely to review Army administrative decisions and correct errors — and the 1977 board concluded, in its recommendation to the Army Secretary, that the 1917 board “may have erred.”
The hedging language — “may have erred” rather than “did err” — was characteristic of institutional caution in a case with complex legal history. But the direction was clear enough to support a recommendation for restoration, and Army Secretary Clifford Alexander acted on that recommendation on June 10, 1977.