United States v. Beauge

CourtCourt of Appeals for the Armed Forces
DecidedMarch 3, 2022
Docket21-0183/NA
StatusPublished

This text of United States v. Beauge (United States v. Beauge) 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. Beauge, (Ark. 2022).

Opinion

This opinion is subject to revision before publication

UNITED STATES COURT OF APPEALS FOR THE ARMED FORCES _______________

UNITED STATES Appellee v. Frantz BEAUGE, Personnel Specialist Chief Petty Officer United States Navy, Appellant No. 21-0183 Crim. App. No. 201900197 Argued December 7, 2021—Decided March 3, 2022 Military Judges: Hayes Larsen (arraignment) and Michael Luken (trial)

For Appellant: Lieutenant Commander Megan P. Marinos, JAGC, USN (argued); Lieutenant Commander Chris Riedel, JAGC, USN. For Appellee: Major Clayton L. Wiggins, USMC (argued); Lieutenant Colonel Christopher G. Blosser, USMC, Major Kerry E. Friedewald, USMC, and Brian K. Keller, Esq. (on brief); Lieutenant Colonel Nicholas L. Gannon, USMC. Amicus Curiae in Support of Appellee: Peter Coote, Esq. (on brief). Chief Judge OHLSON delivered the opinion of the Court, in which Judge SPARKS, Judge HARDY, and Senior Judge CRAWFORD joined. Judge MAGGS joined except in Part IV.A.2. _______________

Chief Judge OHLSON delivered the opinion of the Court. Broadly speaking, Military Rule of Evidence (M.R.E.) 513(a) establishes a privilege that allows a patient to refuse to disclose confidential communications between the patient and his or her psychotherapist if those communications were made for the purpose of diagnosing or treating the patient’s mental or emotional condition. M.R.E. 513(d)(3) creates an ex- ception to that privilege when a service regulation or state or federal law imposes a duty on the psychotherapist to report certain information derived from those communications, such as when the patient alleges child sexual abuse. We hold that United States v. Beauge, No. 21-0183/NA Opinion of the Court

this “duty-to-report” exception makes discoverable the infor- mation that was required to be reported to state authorities. We also hold, however, that the “duty-to-report” exception, standing alone, does not make discoverable the underlying confidential communications between the patient and the psychotherapist. In the instant case, we conclude that the lower court properly construed the psychotherapist-patient privilege and its exceptions, and that the military judge acted within his discretion in denying Appellant’s request for in camera re- view of the victim’s psychiatric records. We also conclude that Appellant was not denied the effective assistance of counsel. We therefore affirm the judgment of the United States Navy- Marine Corps Court of Criminal Appeals (NMCCA). I. Procedural Overview A general court-martial consisting of officer members with enlisted representation convicted Appellant, contrary to his pleas, of two specifications of sexual abuse of a child in viola- tion of Article 120b, Uniform Code of Military Justice (UCMJ), 10 U.S.C. § 920b (2018). Appellant was sentenced to a reduction to E-1 and confinement for one year. The conven- ing authority approved the sentence as adjudged. The NMCCA affirmed the findings and sentence as ap- proved by the convening authority. United States v. Beauge, No. 201900197, 2021 CCA LEXIS 9, at *26, 2021 WL 82854, at *10 (N-M. Ct. Crim. App. Jan. 11, 2021) (unpublished). We granted review to resolve the following issue: Did the lower court create an unreasonably broad scope of the psychotherapist-patient privilege by affirming the military judge’s denial of discovery, denying remand for in camera review, and denying Appellant’s claim of ineffective assistance of counsel? United States v. Beauge, 81 M.J. 301 (C.A.A.F. 2021) (order granting review). II. Background In 2016, the child victim in this case, C.G., reported to school officials that she had been sexually abused by her un- cle, Appellant. The school’s guidance counselor referred C.G.

2 United States v. Beauge, No. 21-0183/NA Opinion of the Court

to a counseling center in Florida where she received treat- ment from a psychotherapist. During the course of this coun- seling, C.G. made statements to the effect that she had been sexually abused by Appellant. Because Florida law mandates reporting evidence of child abuse, the psychotherapist made the required report to Florida’s reporting hotline in a recorded call. The Florida agency that received the report generated an investigative summary and an audio recording of the hotline call, both of which were disclosed to Appellant.1 Beauge, 2021 CCA LEXIS 9, at *5–7, 2021 WL 82854, at *2–3. Prior to trial, Appellant moved to compel production “of all records of communications between C.G. and [the psychother- apist] leading to a report of child sexual abuse.” In his bench brief regarding this motion, Appellant alleged an incon- sistency between (a) C.G.’s statement, as reported by the hot- line summary, that Appellant “attempted to penetrate her on some occasions,” and (b) C.G.’s statement to forensic inter- viewers where—from Appellant’s viewpoint—C.G. failed to renew that specific aspect of her allegation. Appellant argued to the military judge that this alleged inconsistency made it reasonably likely that the psychotherapist’s notes contained information that would be admissible to impeach C.G. The military judge denied Appellant’s motion to compel, citing the psychotherapist-patient privilege. III. Applicable Law Military Rule of Evidence 513 provides for a psychothera- pist-patient privilege in cases arising under the UCMJ. This rule specifically provides that: A patient has a privilege to refuse to disclose and to prevent any other person from disclosing a confidential communication made between the patient and a psychotherapist . . . if such communication was made for the purpose of facilitating diagnosis or treatment of the patient’s mental or emotional condition. M.R.E. 513(a).

1 Because of delays inprocuring the audio recording, it was only made available to Appellant on the day opening arguments began (Feb. 27, 2019), which was after Appellant’s motion to compel dis- covery was resolved (Jan. 29, 2019).

3 United States v. Beauge, No. 21-0183/NA Opinion of the Court

The rule also contains a number of exceptions in subsec- tion (d), which provide that “[t]here is no privilege under this rule” in certain enumerated circumstances. M.R.E. 513(d). For purposes of this case, the relevant exceptions are those which provide that there is no privilege “when federal law, state law, or service regulation imposes a duty to report infor- mation contained in a communication,” M.R.E. 513(d)(3), and “when the communication is evidence of child abuse or of ne- glect, or in a proceeding in which one spouse is charged with a crime against a child of either spouse,” M.R.E. 513(d)(2). For the sake of clarity, we will refer to the former exception as the “duty-to-report” exception and the latter exception as the “ev- idence-of-child-abuse” exception. M.R.E. 513(e) provides the procedure that must be fol- lowed when a party seeks to discover information pursuant to any of the enumerated exceptions. First, the moving party must file a written motion seeking an interlocutory ruling by the military judge. M.R.E. 513(e)(1). Then, “[b]efore ordering the production or admission of evidence of a patient’s records or communication, the military judge must conduct a [closed] hearing” to discuss the merits of the issue. M.R.E. 513(e)(2). If in camera review of the records or communications sought “is necessary to rule on the production or admissibility of pro- tected records or communications,” the military judge “may” conduct such a review. M.R.E. 513(e)(3).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Trammel v. United States
445 U.S. 40 (Supreme Court, 1980)
Pennsylvania v. Ritchie
480 U.S. 39 (Supreme Court, 1987)
Jaffee v. Redmond
518 U.S. 1 (Supreme Court, 1996)
Robinson v. Shell Oil Co.
519 U.S. 337 (Supreme Court, 1997)
Holmes v. South Carolina
547 U.S. 319 (Supreme Court, 2006)
United States v. Roy Lee Hayes
227 F.3d 578 (Sixth Circuit, 2000)
United States v. King
71 M.J. 50 (Court of Appeals for the Armed Forces, 2012)
LRM v. Kastenberg
72 M.J. 364 (Court of Appeals for the Armed Forces, 2013)
State Ex Rel. D.M. v. Hoester
681 S.W.2d 449 (Supreme Court of Missouri, 1984)
DuFresne v. State
826 So. 2d 272 (Supreme Court of Florida, 2002)
PRICE-WILLIAMS v. State
982 So. 2d 611 (Court of Criminal Appeals of Alabama, 2007)
State v. Denis L.R.
2005 WI 110 (Wisconsin Supreme Court, 2005)
Ross v. Blank
958 So. 2d 437 (District Court of Appeal of Florida, 2007)
State v. Snell
714 A.2d 977 (New Jersey Superior Court App Division, 1998)
People v. Stritzinger
668 P.2d 738 (California Supreme Court, 1983)
State v. Strauch
2015 NMSC 9 (New Mexico Supreme Court, 2015)
King v. Burwell
135 S. Ct. 2480 (Supreme Court, 2015)
State v. Orwick
790 N.E.2d 1238 (Ohio Court of Appeals, 2003)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Beauge, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-beauge-armfor-2022.