United States v. ANTHONY M. ELMORE

CourtArmy Court of Criminal Appeals
DecidedJuly 2, 2024
Docket20220345
StatusUnpublished

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

Bluebook
United States v. ANTHONY M. ELMORE, (acca 2024).

Opinion

UNITED STATES ARMY COURT OF CRIMINAL APPEALS

Before FLEMING, MORRIS, and POND Appellate Military Judges

UNITED STATES, Appellee Vv. Private First Class ANTHONY M. ELMORE United States Army, Appellant

ARMY 20220345

Headquarters, 82nd Airborne Division J. Harper Cook, Military Judge Colonel Jeffrey S. Thurnher, Staff Judge Advocate

For Appellant: Captain Tumentugs Armstrong, JA; Robert Feldmeier, Esquire (on brief and reply brief).

For Appellee: Colonel Christopher B. Burgess, JA; Lieutenant Colonel Jacqueline J. DeGaine, JA; Major Chase C. Cleveland, JA; Captain Vy T. Nguyen, JA (on brief).

2 July 2024

This opinion is issued as an unpublished opinion and, as such, does not serve as precedent.

FLEMING, Senior Judge:

This case presents the rare factual scenario of a victim’s cell phone making a video recording of her sexual assault.

Appellant asserts five errors before this Court, one of which merits discussion but no relief. Appellant argues his defense counsel were ineffective for not presenting DNA evidence from the Sexual Assault Nurse Examiner (SANE) examination and for not objecting to the victim’s testimony supplementing the contents of appellant’s snapchat messages. As explained below, we find appellant’s counsel were not ineffective in their representation.

BACKGROUND

An enlisted panel sitting as a general court-martial convicted appellant, contrary to his pleas, of two specifications of sexual assault in violation of Article ELMORE — ARMY 20220345

120, Uniform Code of Military Justice [UCMJ], 10 U.S.C. § 920.! The military judge sentenced appellant to a dishonorable discharge and confinement for five years. The convening authority took no action on the findings and sentence as adjudged, but waived automatic forfeitures effective upon entry of judgment.

Appellant and victim both attended a party in the barracks room of a mutual friend in March of 2021 at which both consumed alcohol. Over the course of the party, other partygoers observed appellant and victim kissing each other, pulling each other close, and sitting on each other’s laps. At the conclusion of the party, victim gave appellant and his roommate, another, partygoer, a ride to their barracks in her car. Upon arrival at the barracks parking lot, appellant’s roommate went inside, while appellant remained behind, ultimately asking victim for a hug. Appellant then opened the driver’s door, pulled victim out of the car, turned her around, pushed her upper body back into the car leaving her bent over the driver’s seat, and pulled down her pants. Appellant moved victim’s underwear aside and penetrated her vulva with both his fingers and penis.

At some point, victim’s cell phone, apparently inadvertently, captured a video recording of some of the sexual assault. We closely reviewed this video recording, which was admitted as evidence by the government during their case-in-chief. The video recording occurred while victim’s cell phone was located on the passenger seat of her car with the camera oriented up and the windshield visible. Through a reflection in the windshield of the car, victim’s back and buttocks are visible on the video recording, which then further depicted appellant moving victim’s underwear aside and penetrating her vulva with both his penis and fingers. Victim can be heard telling appellant “please no," or words to that effect, during the sexual assault.

Two days after the sexual assault, victim underwent a Sexual Assault Forensic Examination (SAFE). DNA collected from victim’s bra and underwear showed appellant’s DNA on victim’s bra but excluded appellant’s DNA from her underwear. At trial, appellant’s trial defense counsel attempted to introduce these results of the DNA test through an agent from the Army Criminal Investigation Division (CID). This attempt did not survive a government hearsay objection.

Trial defense counsel then attempted to call an expert witness, for whom they had not previously provided notice, in order to admit the DNA evidence. Defense counsel were not permitted by the military judge to call this expert witness because of their late notice. Ultimately, once prompted by a panel member’s question, the parties stipulated to the admission of a redacted version of the DNA report, which showed the absence of appellant’s DNA on victim’s underwear.

' The enlisted panel found appellant not guilty of two additional specifications of sexual assault and one specification of obstruction of justice in violation of Articles 120 and 131b, UCMJ. ELMORE — ARMY 20220345

During victim’s testimony at appellant’s trial the government admitted into evidence an exhibit containing text communications between victim and appellant using the Snapchat application. The government further elicited testimony from victim of other statements she attributed to appellant in which she alleged he admitted his guilt. Appellant’s trial defense counsel did not object to victim testifying to the additional statements not contained within the admitted exhibit.

In affidavits ordered by this court, counsel asserted they did not plan to admit the DNA report because the video recording clearly showed appellant penetrating victim’s vulva with his fingers and penis, and because they felt arguing the lack of appellant’s DNA on victim’s underwear was inconsistent with their theory of the case (ie: that appellant’s penetration was consensual and victim had set appellant up to avoid trouble with her husband). Appellant’s counsel further stated, without explanation, they felt they had a good faith basis to admit the DNA evidence through the CID agent. As to victim’s testimony, appellant’s trial defense counsel asserted they did not object regarding her additional statements from appellant as a tactical choice. Counsel asserted they made the tactical decision not to object because they did not want to create a perception of defense counsel blocking a portion of the victim’s testimony, and because new assertions may have opened new avenues for cross examination.

LAW AND DISCUSSION

We review claims of ineffective assistance of counsel de novo. United States v. Furth, 81 M.J. 114, 117 (C.A.A.F. 2021) (citing United States v. Carter, 79 M.J. 478, 480 (C.A.A.F. 2020)). Military courts evaluate ineffective assistance claims using the Supreme Court’s framework from Strickland v. Washington, 466 U.S. 668 (1984). Id. “Under Strickland, an appellant bears the burden of demonstrating that (a) defense counsel’s performance was deficient, and (b) this deficient performance was prejudicial.” Jd. (citing Strickland, 466 U.S. at 687).

In evaluating performance, courts “must indulge a strong presumption that counsel’s conduct falls within the wide range of reasonable professional assistance.” Strickland, 466 U.S. at 689. This presumption can be rebutted by “showing specific errors [made by defense counsel] that were unreasonable under prevailing professional norms.” United States v. McConnell, 55 M.J. 479, 482 (C.A.A.F. 2001) (citing United States v. Scott, 24 M.J. 186, 188 (C.M.A. 1987)). With regard to defining what constitutes deficiency in a claim of ineffective assistance of counsel, the Supreme Court has stated that a “defendant must show that counsel’s representation fell below an objective standard of reasonableness.” Strickland, 466 U.S. at 688. Further, a court must “judge the reasonableness of counsel’s challenged conduct on the facts of the particular case, viewed as of the time of counsel’s conduct.” Jd. at 690. ELMORE — ARMY 20220345

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Harrington v. Richter
131 S. Ct. 770 (Supreme Court, 2011)
United States v. McConnell
55 M.J. 479 (Court of Appeals for the Armed Forces, 2001)
United States v. Scott
24 M.J. 186 (United States Court of Military Appeals, 1987)

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Bluebook (online)
United States v. ANTHONY M. ELMORE, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-anthony-m-elmore-acca-2024.