United States v. Barker

76 M.J. 748, 2017 CCA LEXIS 461, 2017 WL 3297214
CourtUnited States Air Force Court of Criminal Appeals
DecidedJuly 7, 2017
DocketACM 39086
StatusPublished
Cited by5 cases

This text of 76 M.J. 748 (United States v. Barker) is published on Counsel Stack Legal Research, covering United States Air Force 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. Barker, 76 M.J. 748, 2017 CCA LEXIS 461, 2017 WL 3297214 (afcca 2017).

Opinion

Chief Judge DREW delivered the opinion of the court, in which Senior Judge MAYBERRY and Senior Judge J. BROWN joined.

PUBLISHED OPINION OF THE COURT

DREW, Chief Judge:

A military judge sitting as a general court-martial convicted Appellant, consistent with his pleas and pursuant to a pretrial agreement (PTA), of knowingly and wrongfully possessing child pornography and knowingly and wrongfully viewing child pornography, both in violation of Article 134, Uniform Code of Military Justice (UCMJ), 10 U.S.C. § 934. 1 The military judge sentenced Appellant to a bad-conduct discharge, confinement for 30 months, total forfeiture of all pay and allowances, and reduction to E-l. The convening authority approved the sentence as ad•judged. 2

*751 On appeal, Appellant asserts one error: that the military judge erred when, in pre-sentencing, he admitted three written victim impact statements purportedly from an individual identified in the child pornography Appellant possessed and viewed. We find that the military judge erred in admitting two of the three statements. In so doing, we address for the first time whether a victim impact statement written before an accused wrongfully possesses or views child pornography is admissible as an exercise of a victim’s right to be reasonably heard at a sen-téncing hearing.

I. Background

Appellant admitted to knowingly and intentionally downloading and viewing approximately 155 videos and 12 photographs of children engaging in sexually explicit conduct between on or about 14 June 2014 and on or about 18 April 2015. The children in the videos and photographs appear to range in age from approximately 2 years old to about 16 years old. The Defense Computer Forensics Laboratory analyzed Appellant’s electronic equipment and confirmed that the child pornography he possessed included 19 video files and 10 image files involving specific child victims who have been identified by the National Center for Missing and Exploited Children (NCMEC). 3 NCMEC identified KF as the victim depicted in one of the videos Appellant downloaded to his computer. NCMEC refers to that video and others on the Internet involving KF as the “Vicky series.”

At Appellant’s trial, the Prosecution offered what they claimed were victim impact statements from KF. The first was entitled “UPDATED VICTIM IMPACT STATEMENT FROM [redacted] SERIES VICTIM—December 2011.” It was signed and sworn on 6 March 2012. The second was entitled “Supplement to Victim Impact Statement of [redacted] Series Victim,” It was signed on 31 January 2013. The third was entitled “UPDATED VICTIM IMPACT STATEMENT FROM [redacted] SERIES VICTIM—September 23, 2013.” It was signed and sworn on 30 September 2013. None of the statements indicates that it was written by KF and only the January 2013 statement mentions the “Vicky series” anywhere in the statement. The name and signature of the declarants in each document were redacted. There were no accompanying affidavits or testimony to establish the origin of these documents, the circumstances of their creation, or where these documents were maintained. Instead, the assistant trial counsel merely proffered that the Prosecution received the documents from the Federal Bureau of Investigation (FBI), they were victim impact statements from KF, and they were “redacted already.” 4 If the dates on the three letters were accurate, all of the documents were prepared before Appellant committed his offenses. The Prosecution offered the statements as a single Prosecution Exhibit and the military judge admitted it over Defense objection 5 during the presentencing portion of Appellant’s trial. 6

II. Discussion

Appellant asserts the military judge erred in considering, over Defense objection, the victim impact statements. We agree.

*752 We review a military judge’s admission or exclusion of evidence, including sentencing evidence, for an abuse of discretion. United States v. Stephens, 67 M.J. 233, 235 (C.A.A.F. 2009) (citing United States v. Manns, 54 M.J. 164, 166 (C.A.A.F. 2000)). “[T]hat discretion is abused when evidence is admitted based upon an erroneous view of the law.” United States v. Holt, 58 M.J. 227, 230-31 (C.A.A.F. 2003). “The Military Rules of Evidence are applicable to sentencing, ... thus providing procedural safeguards to ensure the reliability of evidence admitted during sentencing.” United States v. Safente, 59 M.J. 270, 273 (C.A.A.F. 2004) (omission in original) (quoting United States v. McDonald, 55 M.J. 173, 176 (C.A.A.F. 2001)); Military Rule of Evidence (Mil. R. Evid.) 1101. “[A]t the discretion of the military judge, [the rules] may be relaxed for the defense when it presents its evidence in extenuation or mitigation.” United States v. Boone, 49 M.J. 187, 198 n.14 (C.A.A.F. 1998) (emphasis added); Rule for Court-Martial (R.C.M.) 1001(c)(3). If the military judge relaxes the rales for the defense, the rales may be relaxed during rebuttal by the prosecution to the same degree. R.C.M. 1001(d).

Although the rales may be relaxed ... otherwise inadmissible evidence still is not admitted at sentencing. See United States v. Gudel, 17 M.J. 1075, 1077 (AFCMR 1984) (“While it is true that the application of the rales of evidence may be relaxed in sentencing proceedings ..., we, like the Court of Military Appeals, believe that the rales are not so relaxed as to eliminate the requirement that the government demonstrate that the proffered evidence meets generally accepted standards of relevance, materiality and reliability.”).

Boone, 49 M.J. at 198 n.14.

Generally, the admission of evidence in aggravation during presentencing is controlled by R.C.M. 1001(b)(4), which states:

The trial counsel may present evidence as to any aggravating circumstances directly relating to or resulting from the offenses of which the accused has been found guilty. Evidence in aggravation includes, but is not limited to, evidence of financial, social, psychological, and medical impact on or cost to any person or entity who was the victim of an offense committed by the accused ....

In addition to aggravation evidence offered by the prosecution, a crime victim has an independent “right to be reasonably heard at a sentencing hearing.” R.C.M. 1001A(a). “If the victim exercises the right to be reasonably heard, the victim shall be called by the court-martial. This right is independent of whether the victim testified during findings or is called to testify under R.C.M. 1001.” Id. (emphasis added). “In non-capital cases ... the ‘right to be reasonably heard’ means the right to make a sworn or unsworn statement.” R.C.M. 1001A(b)(4)(B). “The content of statements ...

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Cite This Page — Counsel Stack

Bluebook (online)
76 M.J. 748, 2017 CCA LEXIS 461, 2017 WL 3297214, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-barker-afcca-2017.