United States v. Abdullah

CourtCourt of Appeals for the Armed Forces
DecidedJune 12, 2026
Docket25-0070/AR
StatusPublished

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

Bluebook
United States v. Abdullah, (Ark. 2026).

Opinion

This opinion is subject to revision before publication.

UNITED STATES COURT OF APPEALS FOR THE ARMED FORCES _______________

UNITED STATES Appellee

v.

Daytron Abdullah, Sergeant United States Army, Appellant

No. 25-0070 Crim. App. No. 20230223

Argued December 9, 2025—Decided June 12, 2026

Military Judge: Jacqueline L. Emanuel

For Appellant: Captain Andrew W. Moore (argued); Colonel Philip M. Staten, Lieutenant Colonel Au- tumn R. Porter, and Jonathan F. Potter, Esq. (on brief); Lieutenant Colonel William M. Grady and Lieutenant Colonel Robert D. Luyties.

For Appellee: Captain Meghan E. Moore (argued); Colonel Richard E. Gorini, Major Vy T. Nguyen, and Captain Andrew T. Bobowski (on brief); Major Marc B. Sawyer and Captain Anthony J. Scarpati.

Judge JOHNSON delivered the opinion of the Court, in which Judge SPARKS and Senior Judge EFFRON joined. Chief Judge OHLSON filed a separate opin- ion concurring in the judgment, in which Judge HARDY joined. Judge HARDY filed a separate opin- ion concurring in the judgment. _______________ United States v. Abdullah, No. 25-0070/AR Opinion of the Court

Judge JOHNSON delivered the opinion of the Court. A military judge sitting as a special court-martial con- victed Appellant, pursuant to his pleas, of one specification each of desertion, absence without leave, willfully disobey- ing a superior commissioned officer, and wrongful use of a controlled substance, in violation of Articles 85, 86, 90, and 112a, Uniform Code of Military Justice (UCMJ), 10 U.S.C. §§ 885, 886, 890, 912a (2018). The military judge sentenced Appellant to a reduction to E-1, confinement for a total of ninety days, and a bad-conduct discharge (BCD). The United States Army Court of Criminal Appeals (CCA) af- firmed the findings and affirmed so much of the sentence as included ninety days of confinement. United States v. Abdullah (Abdullah I), No. ARMY 20230223, 2024 CCA LEXIS 199, at *12, 2024 WL 2045391, at *5 (A. Ct. Crim. App. Apr. 30, 2024) (unpublished). On reconsideration, the en banc CCA affirmed the findings and affirmed the sen- tence as adjudged. United States v. Abdullah (Abdullah II), 85 M.J. 501, 510 (A. Ct. Crim. App. 2024). We granted review to determine whether a retired ap- pellate judge and an appellate judge on terminal leave im- permissibly participated in the en banc decision of the CCA. For the reasons stated below, we hold that under the circumstances of this case, the retired appellate judge’s participation in the decision was impermissible, and this error requires remand for a new Article 66, UCMJ, 10 U.S.C. § 866 (Supp. III 2019-2022), review. Accordingly, we set aside the decision of the CCA. We reserve for another day the question whether the participation of a former ap- pellate judge on terminal leave was permissible. I. Background In a memorandum opinion issued on April 30, 2024, the CCA held that dilatory post-trial processing violated due process and warranted relief under Article 66, UCMJ. Ab- dullah I, 2024 CCA LEXIS 199, at *12, 2024 WL 2045391, at *5. The court affirmed the findings of guilty but affirmed only so much of the sentence as included ninety days of con- finement. Id., 2024 WL 2045391, at *5. The Government

2 United States v. Abdullah, No. 25-0070/AR Opinion of the Court

filed a suggestion for reconsideration en banc, which the CCA adopted on June 14, 2024, thereby vacating its opin- ion in Abdullah I. See Army Court of Criminal Appeals Rules of Appellate Procedure Rule 31.2(c) (Jan. 15, 2019) (“An order granting reconsideration vacates the decision to be reconsidered.”). In an opinion on reconsideration issued on November 5, 2024, the en banc CCA held that there was no unreasona- ble post-trial delay in violation of due process or Article 66, UCMJ, and that setting aside the BCD was not appropriate relief under Article 66(d)(2), UCMJ. Abdullah II, 85 M.J. at 510. Accordingly, it affirmed the original findings and sentence. Id. Senior Judge Walker authored the opinion of the eight-judge court, in which Chief Judge Smawley and three other judges concurred. Id. at 503, 510. In a footnote, the CCA noted that “Chief Judge SMAWLEY took final ac- tion on this case prior to his departure from the court,” while “Senior Judge WALKER took final action in this case prior to her retirement.” Id. at 503 n.1. Three judges wrote separately, one concurring in part and in the judgment, id. at 510 (Morris, J., concurring in part), and two dissenting. Id. at 511 (Arguelles, J., dissenting), 514 (Penland, J., with whom Arguelles, J., joined, dissenting). Appellant petitioned this Court for review of the ques- tion whether the CCA lawfully conducted its en banc re- view of his case where former Senior Judge Walker and for- mer Chief Judge Smawley were not in regular active service when Abdullah II was issued. 1 Attached to the Sup- plement to the Petition for Grant of Review were two mem- oranda concerning the composition of Army CCA panels. The first, dated July 22, 2024, identifies Colonel Pond as Chief Judge and reflects that Senior Judge Walker was as- signed to CCA Panel 4 as of that date. Former Chief Judge

1 Appellant also argued the decision to grant en banc review

was itself an abuse of discretion and challenged the CCA’s ruling that post-trial delay did not violate his due process rights. We denied review of these assertions of error, which are not at issue on this appeal.

3 United States v. Abdullah, No. 25-0070/AR Opinion of the Court

Smawley was not assigned to any panel. The second, dated September 30, 2024, and effective September 23, 2024, identifies Colonel Pond as Chief Judge and reflects that neither former Chief Judge Smawley nor former Senior Judge Walker was assigned to a panel. Both memoranda state that the panel reorganization did not affect this case. Appellant subsequently filed a motion requesting that this Court take judicial notice of the panel composition memos attached to the Supplement. Upon consideration of Appellant’s Supplement to the Petition for Grant of Review and his request for judicial no- tice, we concluded there was insufficient evidence to an- swer the assigned issue. Accordingly, on March 24, 2025, we ordered the Government to file an answer to the Sup- plement and provide an affidavit answering the following questions: 1. For former-Chief Judge Smawley: (a) On what date did his assignment to the United States Army Court of Criminal Appeals end? (b) If he retired, on what date did he retire from the United States Army? (c) If he retired, what date did he begin terminal leave? 2. For former-Senior Judge Walker: (a) On what date did she retire? (b) On what date did she begin terminal leave? United States v. Abdullah, 85 M.J. 406 (C.A.A.F. 2025) (or- der). The motion for judicial notice was denied as moot. Id. On April 21, 2025, the Government filed an affidavit with this Court providing the following information: 1. For former-Chief Judge Smawley: (a) Chief Judge Smawley relinquished com- mand on 22 July 2024. (b) Chief Judge Smawley retired from the Army on October 31, 2024.

4 United States v. Abdullah, No. 25-0070/AR Opinion of the Court

(c) Chief Judge Smawley’s transition leave started on September 1, 2024. Chief Judge Smawley completed his uncharged transition absence (transition administrative absence/in- voluntary separation administrative absence) from August 13, 2024, through August 31, 2024. 2. For former-Senior Judge Walker (a) Colonel Walker retired on November 30, 2024. (b) Colonel Walker’s terminal/transition leave ran from October 10, 2024, until her retire- ment.

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