United States v. BABBITT

CourtNavy-Marine Corps Court of Criminal Appeals
DecidedMarch 31, 2025
Docket202300286
StatusPublished

This text of United States v. BABBITT (United States v. BABBITT) 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.

Bluebook
United States v. BABBITT, (N.M. 2025).

Opinion

This opinion is subject to administrative correction before final disposition.

Before HOLIFIELD, KISOR, and HARRELL Appellate Military Judges

_________________________

UNITED STATES Appellee

v.

Eric C. BABBITT Logistics Specialist Second Class Petty Officer (E-5), U.S. Navy Appellant

No. 202300286

Decided: 31 March 2025

Appeal from the United States Navy-Marine Corps Trial Judiciary

Military Judges: Hayes C. Larson (arraignment) Donald R. Ostrom (motions) Ryan J. Sears (trial) Mishonda M. Mosley (post-trial)

Sentence adjudged 1 August 2023 by a general court-martial tried at Region Legal Service Office Mid-Atlantic, Norfolk, Virginia, consisting of a military judge sitting alone. Sentence in the Entry of Judgment: reduction to E-1, confinement for thirteen years, forfeiture of all pay and allowances, and a dishonorable discharge. 1

1 Appellant received 422 days of pretrial confinement credit. United States v. Babbitt, NMCCA No. 202300286 Opinion of the Court

For Appellant: LT Jesse B. Neumann, JAGC, USN (on brief and argued)

For Appellee: Lieutenant Lan T. Nguyen, JAGC, USN (on brief) Major Mary Claire Finnen, USMC (on brief and argued)

Senior Judge KISOR delivered the opinion of the Court, in which Chief Judge HOLIFIELD and Judge HARRELL joined.

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

KISOR, Senior Judge: Appellant was convicted, consistent with his pleas, of one specification of attempted sexual abuse of a child by indecent exposure, in violation of Article 80, Uniform Code of Military Justice (UCMJ), one specification of sexual abuse of a child by indecent conduct, in violation of Article 120b, UCMJ, and one specification of assault consummated by a battery on a child under 16 years of age, in violation of Article 128, UCMJ. 2 Appellant asserts three assignments of error (AOE): (1) Did unlawful com- mand influence occur when the Region Legal Service Office intentionally in- terfered with the convening authority’s duty to perform under the plea agree- ment? (2) Has the Navy unlawfully increased the severity of Appellant’s sen- tence by failing to comply with the Interstate Agreement on Detainers Act (IADA)? And (3) was the Navy’s reliance on the sentence interruption provision of Article 14(b), UMCJ, in error because the provision has been repealed by implication under the facts of this case? We find no prejudicial error and affirm the findings and sentence.

2 10 U.S.C. §§ 880, 920, 928.

2 United States v. Babbitt, NMCCA No. 202300286 Opinion of the Court

I. BACKGROUND

Appellant resided in a military base housing community where military families lived. The community was gated, and had facilities including a com- munity center, several playgrounds, and a splash pad. Appellant lived alone, and most of his neighbors were military families with children. During the summer of 2019, Appellant inappropriately touched one of the neighborhood children, age 8, and pulled on another child’s shorts and under- wear in order to view her buttocks. She was 9 years old. In September 2019, Appellant moved off base. In the summer of 2022, Ap- pellant began an online conversation with “C.E.,” a person he believed to be a 10-year-old girl living in the United Kingdom. He would ask her to send him pictures of herself, both clothed and unclothed. He sent her several pictures of himself, including five pictures of his exposed penis. As it turns out, C.E. was not a 10-year-old girl but was instead an adult working with law enforcement. On 27 July 2022, Appellant was arrested by the Petersburg, Virginia Police Department and held in civilian jail. He was transferred to Navy custody on 22 August 2022 and placed in pretrial confinement. Appellant was charged with numerous offenses related to sexual abuse of the two children in base housing and the attempted sexual abuse of C.E. Appellant eventually reached a plea agreement with the convening author- ity resulting in the dismissal of the majority of the charges and guilty pleas to assault consummated by a battery on one child (by exceptions and substitu- tions), sexual abuse (indecent conduct) of another child, and attempted sexual abuse (indecent exposure) of C.E. The plea agreement provided for a term of confinement in the range of 8-15 years, although the maximum confinement for the charges to which he pleaded guilty was 32 years of confinement. A dis- honorable discharge, total forfeitures, and reduction to paygrade E-1 were also required by the plea agreement. The most serious charges of sexual abuse were withdrawn and dismissed. Appellant was tried on 1 August 2023. Relevant here, the plea agreement contained a provision—under the sub- heading “Agreements by the Accused”—that: 8.j. If pursuant to the adjudication of a sentence, I meet eligibility criteria established by Navy Personnel Command (PERS-00D1), or other applicable authority and the confinement facility, the con- vening authority will recommend in writing to the applicable au- thority that contact be established with PERS-00D1, the brig I am confined in, and the Naval Consolidated Brig Miramar, San Diego, California or the Military Correctional Complex, Fort Leaven- worth, Kansas, within 10 days to recommend that I be placed in either of those facilities, both of which are military facilities with

3 United States v. Babbitt, NMCCA No. 202300286 Opinion of the Court

a non-violent sex offender treatment program to serve the period of confinement. I understand that my placement in a military fa- cility with a non-violent sex offender treatment program can be recommended by the convening authority, but that my placement in such a facility cannot be guaranteed. I further agree to volun- tarily participate in any sex offender treatment program offered to me to include truthful admissions of my misconduct required for rehabilitation. 3 The convening authority did not make a written recommendation within ten days, because the Navy had received a request to transfer custody of Ap- pellant to the Commonwealth of Virginia (where he remains to this day). 4 In- stead, on 8 August 2023 the Region Legal Service Office (RLSO) (the prosecu- tion office in this case) requested, and the convening authority endorsed on 10 August 2023, a request to Commander, Navy Personnel Command (PERS 00D) to hold Appellant post-conviction in the Naval Brig in Chesapeake, Virginia pending his transfer to the Commonwealth. 5 On 31 August 2023, Appellant filed a post-trial motion to withdraw his pleas, and set aside the findings and sentence. 6 On 6 September 2023, the convening authority sent a recommendation to Commander, Navy Personnel Command (PERS OOD1) that Appellant “serve the period of his confinement at Naval Consolidated Brig, Miramar, San Diego, California or the Military Correctional Complex, Fort Leavenworth, Kansas, once his [permanent change of station] hold is lifted . . . .” 7 A post-trial Article 39(a) session occurred on 28 September 2023, and after taking evidence, the military judge made findings of fact and concluded that the convening authority’s agreement to write the recommendation letter was “ancillary and not a material term of clause 8[j] of the plea agreement.” 8 The

3 App. Ex. XV (plea agreement) at p 9 paragraph j.

4 The parties informed the Court at oral argument that he remains in the custody

of the Commonwealth of Virginia, pending arraignment on civilian charges of a similar nature to the charges in this case. 5 App. Ex. XXV(a) at 49, 52.

6 App. Ex. XXIV.

7 App. Ex. XXV(a) at 73.

8 R. at 66.

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United States v. BABBITT, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-babbitt-nmcca-2025.