Marrero v. United States

CourtUnited States Court of Federal Claims
DecidedAugust 12, 2025
Docket25-158
StatusUnpublished

This text of Marrero v. United States (Marrero v. United States) is published on Counsel Stack Legal Research, covering United States Court of Federal Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Marrero v. United States, (uscfc 2025).

Opinion

In the United States Court of Federal Claims No. 25-158 Filed: August 12, 2025 NOT FOR PUBLICATION

RAMON M. MARRERO,

Plaintiff,

v.

UNITED STATES,

Defendant.

Wojciech Z. Kornacki, Pentagon Law Office, Washington, DC, for the plaintiff.

Evan Wisser, Civil Division, U.S. Department of Justice, Washington, DC, Capt. Ellen Denum, U.S. Army Legal Services Agency, Ft. Belvoir, VA, of counsel, for the defendant.

MEMORANDUM OPINION

HERTLING, Judge

The plaintiff, Ramon M. Marrero, served as a non-commissioned officer (“NCO”) in the United States Army. He was accused and tried at a court-martial of five specifications arising from two sexual assaults against lower-ranking military personnel. He was acquitted of three specifications but convicted of two specifications arising from the first of the alleged assaults. Upon his appeal, the Judge Advocate General (“JAG”) of the Army overturned one of the convictions but sustained the other. The plaintiff was sentenced to a period of confinement and a reduction in rank, with a commensurate reduction in pay. He was discharged from the Army at the end of his confinement.

After exhausting his appeals through the military courts, the plaintiff brought this suit, alleging that his court-martial proceedings and conviction were constitutionally defective. As a result, he seeks to have his conviction overturned and to recover back pay and associated benefits.

The defendant has moved to dismiss the complaint under Rules 12(b)(1) and 12(b)(6) of the Rules of the Court of Federal Claims (“RCFC”) for lack of jurisdiction and failure to state a claim. The defendant argues that the court lacks jurisdiction over the complaint because it does not rely on a money-mandating source of law, and the plaintiff waived most of his claims by failing to present them during his court-martial and appeal. The defendant also argues that even if the court has jurisdiction over the complaint, the complaint fails to state a claim upon which relief can be granted and must still be dismissed. The plaintiff has failed to demonstrate that his claims fall within the Court of Federal Claims’ narrow ability to conduct a collateral review of a court-martial conviction. Even if the court possessed jurisdiction over the claims, the plaintiff has failed to show that any of the violations alleged in the complaint rendered his court-martial proceedings constitutionally unfair. He has therefore failed to state a claim upon which relief can be granted. The defendant’s motion to dismiss is granted.

I. FACTUAL BACKGROUND1

The plaintiff enlisted in the Army in 2000. During his service, he deployed to Iraq, Afghanistan, and South Korea. The plaintiff received numerous awards and medals during his service and was promoted to serve as an NCO. On February 27, 2012, while off-duty during training at Fort Meade, Maryland, the plaintiff was with two other soldiers, one of whom was a female NCO at the same training, at a tavern. After an evening of drinking, the group returned to the base and continued to socialize in the plaintiff’s quarters. The other male soldier returned to his quarters after a brief period, and the female NCO remained in the plaintiff’s room. Afterward, the female NCO accused the plaintiff of sexual misconduct. The accusation triggered an investigation by the Army.

The plaintiff never denied having been intimate with the complainant. The factual dispute was over whether the complainant had consented and whether she was intoxicated and, as a result, able to give her consent. The investigation and trial focused on these issues.

The Army’s investigation resulted in a preliminary hearing conducted on January 10, 2014, under Article 32 of the Uniform Code of Military Justice, 10 U.S.C. § 832.2 During the Article 32 hearing, three specifications of misconduct against the plaintiff were considered. As required by 10 U.S.C. § 832(e), the proceedings were recorded. At the hearing, the complainant and her boyfriend, whom the complainant had called both while at the plaintiff’s residence and

1 The facts outlined here reflect the allegations of the complaint and related factual materials provided by the defendant with its motion to dismiss that add detail to the facts alleged by the plaintiff. For example, the complaint does not specify the underlying facts of any of the five specifications with which the plaintiff was charged and on which he was tried. Exhibits attached to the motion to dismiss provides these details, which do not contradict or put in question any of the plaintiff’s allegations. They may therefore be relied on in resolving the motion to dismiss. See Dimare Fresh, Inc. v. United States, 808 F.3d 1301, 1306 (Fed. Cir. 2015). For purposes of resolving the motion, the facts alleged in the complaint are assumed to be true, and this recitation of the facts therefore makes no findings of fact. 2 During an Article 32 hearing, a hearing officer determines: (a) whether the specification alleges an offense under the Uniform Code of Military Justice, (b) whether there is probable cause to believe the accused committed the charged offense, (c) whether the convening authority has court-martial jurisdiction over the accused and the offense, and (d) a recommendation on the disposition of the case. 10 U.S.C. § 832(a)(2).

2 after leaving it, testified about their recollections of the events of the evening at issue. The Army lost the recording of the proceeding sometime between January and July 2014. Following the Article 32 hearing, the plaintiff’s defense team recommended that he plead guilty, but the plaintiff rejected that advice. The plaintiff’s defense counsel never sought dismissal of the charges due to the lost recording.

The Army held a second Article 32 hearing on July 8, 2014, to consider evidence that the plaintiff had sexually assaulted the NCO in 2012 and to hear new allegations that he sexually assaulted a second female servicemember in January 2014. (ECF 1 at ¶¶ 101-08.)3

After the second Article 32 proceeding, the plaintiff was referred for a court-martial on five specifications: the three charged after the first Article 32 proceeding involving the NCO and two new ones arising from the alleged assault on the second servicemember. The first specification alleged that the plaintiff had slapped the complainant on the buttocks without the complainant’s permission; the second specification alleged that the plaintiff had kissed the complainant’s breasts when she was incapacitated due to intoxication; the third specification alleged that the plaintiff had engaged in sexual intercourse with the complainant when she was incapacitated due to intoxication; the fourth and fifth specifications alleged that the plaintiff had committed two non-consensual sexual acts against the second female servicemember. (ECF 9-1 at 2.)

The plaintiff pleaded not guilty to all five specifications. Prior to trial, the prosecution filed a notice of intent under Military Rule of Evidence 413, that it intended to argue that the similarities between the two separate sexual assaults charged in the five specifications “demonstrate[d the plaintiff’s] propensity to commit crimes of sexual misconduct.”4 (ECF 9-3 at 19 (quoting the prosecution’s Rule 413 notice).)

The plaintiff was tried by a court-martial before a military jury, called panel members, in October 2014. At the close of the trial, the military judge instructed the jury as follows:

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