United States v. Benoit

CourtUnited States Air Force Court of Criminal Appeals
DecidedJanuary 3, 2025
Docket40508
StatusUnpublished

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

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United States v. Benoit, (afcca 2025).

Opinion

U NITED S TATES A IR F ORCE C OURT OF C RIMINAL APPEALS ________________________

No. ACM 40508 ________________________

UNITED STATES Appellee v. Jacques D. BENOIT, Jr. Staff Sergeant (E-5), U.S. Air Force, Appellant ________________________

Appeal from the United States Air Force Trial Judiciary 1 Decided 3 January 2025 ________________________

Military Judge: Michael A. Schrama. Sentence: Sentence adjudged 13 January 2023 by GCM convened at Joint Base Charleston, South Carolina. Sentence entered by military judge on 13 April 2023: confinement for 8 months, reduction to E-1, and a reprimand. For Appellant: Major Samantha P. Golseth, USAF. For Appellee: Lieutenant Colonel J. Pete Ferrell, USAF; Lieutenant Colonel Jenny A. Liabenow, USAF; Lieutenant Colonel G. Matt Osborn, USAF; Major Brittany M. Speirs, USAF; Major Jocelyn Q. Wright, USAF; Mary Ellen Payne, Esquire. Before RICHARDSON, MASON, and KEARLEY, Appellate Military Judges. Judge MASON delivered the opinion of the court, in which Senior Judge RICHARDSON and Judge KEARLEY joined.

1 Appellant appeals his conviction under Article 66(b)(1)(A), Uniform Code of Military

Justice (UCMJ), 10 U.S.C. § 866(b)(1)(A), Manual for Courts-Martial, United States (2024 ed.). United States v. Benoit, No. ACM 40508

________________________

This is an unpublished opinion and, as such, does not serve as precedent under AFCCA Rule of Practice and Procedure 30.4. ________________________ MASON, Judge: A general court-martial composed of officer and enlisted members convicted Appellant, contrary to his pleas, of one specification of reckless operation of a vehicle causing injury, in violation of Article 113, Uniform Code of Military Justice (UCMJ), 10 U.S.C. § 913.2,3 The military judge sentenced Appellant to confinement for eight months, reduction to the grade of E-1, and a reprimand. Appellant requested that the convening authority defer the adjudged reduction in grade until the entry of judgment and waive the automatic forfeitures for six months. The convening authority denied Appellant’s requests, took no ac- tion on the findings or sentence, and provided the language of the reprimand. Appellant raises four issues on appeal, which we have reworded: (1) whether Appellant’s conviction is factually sufficient; (2) whether the sentence is inappropriately severe; (3) whether the Government can prove 18 U.S.C. § 922 is constitutional because its application is not consistent with the na- tion’s historical tradition of firearm regulation, and whether the court can de- cide that question; and (4) whether the convening authority abused her discre- tion in denying Appellant’s requests for deferment and waiver.4 We have carefully considered issues (3) and (4) and find they do not require discussion or relief. See United States v. Matias, 25 M.J. 356, 361 (C.M.A. 1987). As to the remaining issues, we find no error that materially prejudiced Appellant’s substantial rights, and we affirm the findings and sentence.

I. BACKGROUND In July 2020, Appellant deployed from Joint Base Charleston to Ali Al Sa- lem Air Base, Kuwait. He was assigned to the special handling section for the expeditionary logistics readiness squadron (ELRS). His job in that section was

2 Unless otherwise noted, all other references in this opinion to the UCMJ and Rules

for Courts-Martial are to the Manual for Courts-Martial, United States (2019 ed.). 3 Appellant was found not guilty of one specification of dereliction of duty, in violation

of Article 92, UCMJ, 10 U.S.C. § 892. 4 Appellant raises issue (4) pursuant to United States v. Grostefon, 12 M.J. 431 (C.M.A.

1982).

2 United States v. Benoit, No. ACM 40508

to provide handling of anything that was not general cargo, including explo- sives, hazardous materials, registered mail, and vehicles. Around 14 September 2020, a Polaris Ranger vehicle was delivered for han- dling to the ELRS. On that day, Appellant drove the Polaris in an unpaved, sandy, handling area for the unit. He did so with another member of the unit, RO, in the passenger seat. At some point during the drive, while making a sharp turn, the Polaris tipped over onto the passenger side. As a result, RO was trapped under the vehicle with part of the roll cage compressing his head into the ground. Security Forces members responded to the scene and immediately saw that RO was deceased. Medical responders confirmed RO’s death. Security Forces asked Appellant what had happened. Appellant said, “I’m not going to lie, we were out here joyriding and it just flipped.” At trial, an expert in accident reconstruction testified. He conservatively estimated that the Polaris would need to be driving at a minimum speed of 15.38 miles per hour to tip over. He further estimated that the Polaris was traveling 18.68 miles per hour at the time it tipped over. The military judge took judicial notice of the wing instruction that set a speed limit for the appli- cable area at six miles per hour.

II. DISCUSSION A. Factual Sufficiency 1. Law We review issues of factual sufficiency de novo. United States v. Washing- ton, 57 M.J. 394, 399 (C.A.A.F. 2002). “The test for factual sufficiency ‘is whether, after weighing the evidence in the record of trial and making allowances for not having personally observed the witnesses,’ [this] court is ‘convinced of the [appellant]’s guilt beyond a rea- sonable doubt.’” United States v. Reed, 54 M.J. 37, 41 (C.A.A.F. 2000) (quoting United States v. Turner, 25 M.J. 324, 325 (C.M.A. 1987)). “In conducting this unique appellate role, we take ‘a fresh, impartial look at the evidence,’ applying ‘neither a presumption of innocence nor a presumption of guilt’ to ‘make [our] own independent determination as to whether the evidence constitutes proof of each required element beyond a reasonable doubt.’” United States v. Wheeler, 76 M.J. 564, 568 (A.F. Ct. Crim. App. 2017) (alteration in original) (quoting Washington, 57 M.J. at 399). This court’s review of the factual sufficiency of evidence for findings is limited to the evidence admitted at trial. United States v. Beatty, 64 M.J. 456, 458 (C.A.A.F. 2007) (citations omitted); United States v. Rodela, 82 M.J. 521, 525 (A.F. Ct. Crim. App. 2021) (citation omitted).

3 United States v. Benoit, No. ACM 40508

Appellant was convicted of reckless operation of a vehicle causing injury, in violation of Article 113, UCMJ, which required the Government to prove the following three elements beyond a reasonable doubt: (1) that at or near Ali Al Salem Air Base, Kuwait, in the location in which terminal parked cargo is lo- cated, Appellant was in physical control of a vehicle; (2) that Appellant physi- cally controlled the vehicle in a reckless manner by attempting a sharp turn at an excessive speed in sandy terrain and did thereby cause said vehicle to roll; and (3) that Appellant thereby caused the vehicle to injure RO. See Manual for Courts-Martial, United States (2019 ed.) (MCM), pt. IV, ¶ 51.b. “The operation or physical control of a vehicle, vessel, or aircraft is reckless when it exhibits a culpable disregard of foreseeable consequences to others from the act or omission involved.” MCM, pt. IV, ¶ 51.c.(7). Recklessness is determined by evaluating whether, “under all the circum- stances, the accused’s manner of operation or physical control of the vehicle, vessel, or aircraft was of that heedless nature which made it actually or immi- nently dangerous to the occupants . . . .” Id. 2.

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