<p data-block-key="pz2vg">U.S. v. HOOPII, JR.</p>

CourtNavy-Marine Corps Court of Criminal Appeals
DecidedJuly 30, 2024
Docket<p data-block-key="q23jv">202300061</p>
StatusPublished

This text of <p data-block-key="pz2vg">U.S. v. HOOPII, JR.</p> (<p data-block-key="pz2vg">U.S. v. HOOPII, JR.</p>) is published on Counsel Stack Legal Research, covering Navy-Marine Corps Court of Criminal Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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<p data-block-key="pz2vg">U.S. v. HOOPII, JR.</p>, (N.M. 2024).

Opinion

This opinion is subject to administrative correction before final disposition.

Before HOLIFIELD, DALY, and GROSS Appellate Military Judges

_________________________

UNITED STATES Appellee

v.

Kimo N. HOOPII, Jr. Lance Corporal (E-3), U.S. Marine Corps Appellant

No. 202300061

Decided: 30 July 2024

Appeal from the United States Navy-Marine Corps Trial Judiciary

Military Judge: Andrea C. Goode

Sentence adjudged 18 November 2022 by a special court-martial tried at Marine Corps Base Camp Pendleton, California, consisting of a mil- itary judge sitting alone. Sentence in the Entry of Judgment: reduction to E-1, confinement for 4 months, and forfeiture of $610.00 pay per month for 4 months.

For Appellant: Commander Lindsay W. Pepi, JAGC, USN

For Appellee: Lieutenant Rachel E. Noveroske, JAGC, USN Lieutenant Blake R. Royall, JAGC, USN United States v. Hoopii, Jr., NMCCA No. 202300061 Opinion of the Court

This opinion does not serve as binding precedent, but may be cited as persuasive authority under NMCCA Rule of Appellate Procedure 30.2.

PER CURIAM: A special court-martial convicted Appellant, pursuant to his pleas, of two specifications of larceny, in violation of Article 121, Uniform Code of Military Justice (UCMJ). 1 This case is before us on direct appeal submitted by Appel- lant pursuant to Article 66(b)(1), UCMJ. Appellant asserts a single assignment of error (AOE), which we rephrase as follows: The military judge created a lack of jurisdiction when she instructed trial counsel to amend the convening order without approval from the convening authority. We find no prejudicial error and affirm.

I. BACKGROUND

After entering into a plea agreement with Appellant on 27 September 2022, the convening authority in this case referred the charge to a special court-mar- tial consisting of a military judge alone pursuant to Article 16(c)(2)(A). 2 He did so with the following language, contemporaneously convening a court-martial and referring the charge to it:

1 10 U.S.C. § 921.

2 10 U.S.C. § 816(c)(2)(A).

2 United States v. Hoopii, Jr., NMCCA No. 202300061 Opinion of the Court

At trial, the military judge asked trial counsel to state the jurisdictional data for the record. The following discussion occurred:

TC: This court-martial is convened by the charge sheet . . . dated 20 January—that’s incorrect—dated 2 November 22 . . . . ... MJ: All right, I know why you messed that one part up, it is because there is an error on the referral Section of the charge sheet. So come up here and grab the charge sheet. It looks like they did a cut-and-paste from a prior referral, because it says . . . “This special court-martial convened by this document on 20 January 2021 . . . dated 20 Jan- uary 2021.” It should all be 2 November 2022. ... MJ: So just come up here and make the pen change. ... MJ: Because this is an error to the referral Section of the charge sheet, defense, do you have any objections to making this pen change? DC: No, Your Honor. MJ: It is an obvious cut-and-paste error and the Court does not find it rises to the level of an improper referral. 3 Appellant’s guilty plea and sentencing then proceeded with no further mention of the matter.

II. LAW

We review questions of jurisdiction de novo. 4 We test administrative con- vening order and referral errors for prejudice. 5

3 R. at 2-4.

4 United States v. Begani, 81 M.J. 273, 276 (C.A.A.F. 2021) (citation omitted).

5 United States v. Gebhart, 34 M.J. 189, 193 (C.A.A.F. 1992).

3 United States v. Hoopii, Jr., NMCCA No. 202300061 Opinion of the Court

A court-martial has jurisdiction over a case if: (1) it is convened by an offi- cial empowered to convene it; (2) it is composed in accordance with the rules for courts-martial relating to the number and qualifications of personnel; (3) each charge before it is referred to it by competent authority; (4) the accused is subject to court-martial jurisdiction; and (5) the offense is subject to court-mar- tial jurisdiction. 6 While the UCMJ clearly defines who may convene (Article 22) and who may serve on (Article 25) a court-martial, it is nearly silent regarding the content and form of a convening order. Rule for Courts-Martial 504(d) requires only that a convening order for a special court-martial “designate the type of court- martial” and “detail the members, if any.” But Rule for Courts-Martial 503(d)(3) provides that “[a]dditional matters to be included in convening orders may be prescribed by the Secretary concerned.” At the time of Appellant’s trial, these “additional matters” included “a court-martial convening order number” and information identifying the convening authority. 7 This prescription also included the following provision: A military judge alone special court-martial authorized by Arti- cle 16(c)(2)(A) is convened with the use of a convening order or, at the time of referral, by annotating Section V of the charge sheet as follows: “Referred for trial to the special court-martial convened by (name of convening authority) (date), subject to the following instructions: This case is to be tried as a special court- martial consisting of a military judge alone pursuant to UCMJ, Article 16(c)(2)(A).” 8 Regardless of form, however, “[a]convening order which brings a court-mar- tial into being is but an expression of the intent of the convening authority. The particular document which is prepared is merely a formal recordation of that expressed intent.” 9 The statutory definition of “referral” is “the order of a convening authority . . . that charges and specifications against an accused be tried by a specific

6 Rule for Courts-Martial 201(b).

7 JAGINST 5800.7G CH 1, Manual of the Judge Advocate General (JAGMAN), 14

Feb 2022, para 0133c. 8 Id.

9 United States v. Glover, 15 M.J. 419, 421 (C.M.A. 1983).

4 United States v. Hoopii, Jr., NMCCA No. 202300061 Opinion of the Court

court-martial.” 10 A proper referral requires three things: (1) an authorized, but not disqualified, convening authority; (2) preferred charges received by that convening authority for disposition; and (3) a court-martial convened by that convening authority or a predecessor. 11 Procedural provisions regarding refer- ral are not statutory, and, normally, departures from these procedures are not defects of jurisdictional proportion. 12

III. DISCUSSION

A. The Convening Authority’s Intent is Clear The convening authority convened a special court-martial on 2 November 2022 when he signed Section V of the charge sheet. He contemporaneously re- ferred the charges to that court-martial. The words “This document” can mean nothing other than the charge sheet upon which they appear. While the con- flicting dates indicate a lack of attention to detail, they are not necessary for the parties in this case to understand what document—or court-martial—the convening authority referenced. There was no confusion regarding what spe- cific court-martial was to try the charge and specifications. Indeed, the charge and specifications were referred to this specific court-martial as part of a spe- cially negotiated provision in the plea agreement between Appellant and the convening authority. Additionally, we have the “Article 34 letter,” 13 indicating that the conven- ing authority consulted with a judge advocate “prior to referring the charge and specifications preferred in enclosure (1) to a special court-martial.” Enclo- sure (1) of that letter is the “Preferred Charge Sheet of 18 August 22”—i.e., the

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Related

United States v. Crumpley
49 M.J. 538 (Navy-Marine Corps Court of Criminal Appeals, 1998)
United States v. Simpson
16 C.M.A. 137 (United States Court of Military Appeals, 1966)
United States v. Glover
15 M.J. 419 (United States Court of Military Appeals, 1983)
United States v. Fields
17 M.J. 1070 (U S Air Force Court of Military Review, 1984)
United States v. Gebhart
34 M.J. 189 (United States Court of Military Appeals, 1992)

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