RYAN, Chief Judge.
Plaintiff moves for summary judgment on the pleadings and the administrative record; defendant concedes that there is no question of fact and in turn seeks summary judgment in its favor (although it has not so moved).
Plaintiff is a merchant seaman who was denied by the Commandant of the Coast Guard special validation endorsement of his Mariner's documents and thus foreclosed from shipping on vessels of 100 gross tons and over.
The...
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