United States v. Bevacqua

37 M.J. 996, 1993 CMR LEXIS 340, 1993 WL 303976
CourtU S Coast Guard Court of Military Review
DecidedAugust 9, 1993
DocketCGCM 0064; Docket No. 1001
StatusPublished
Cited by8 cases

This text of 37 M.J. 996 (United States v. Bevacqua) is published on Counsel Stack Legal Research, covering U S Coast Guard Court of Military Review primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Bevacqua, 37 M.J. 996, 1993 CMR LEXIS 340, 1993 WL 303976 (cgcomilrev 1993).

Opinion

BAUM, Chief Judge:

At a general court-martial composed of officer and enlisted members, Appellant, despite his not guilty pleas, was convicted of three specifications of violating a lawful order, one specification of maltreatment of a person subject to his orders, two specifications of sodomy, one specification of assault consummated by a battery, three specifications of adultery, one specification of indecent language, and one specification of solicitation to commit sodomy in violation of Articles 92, 93, 125, 128, and 134, Uniform Code of Military Justice (UCMJ), 10 U.S.C.A. §§ 892, 893, 925, 928, 934. After the military judge found various of these offenses multiplicious for sentencing purposes, the court sentenced Appellant to a bad conduct discharge, confinement for six months, and reduction to pay grade E-1. That sentence was approved by the convening authority.

Before this Court, Appellant has' assigned seven errors, all but one of which are deemed to be without merit and need not be addressed. After considering the briefs and hearing oral argument, we are convinced that the one remaining assignment of error has merit and requires that the sentence be set aside in order that a rehearing on that portion of the trial may be held. Assignment II, the one error not rejected, asserts that:

RELIEF OF THE DETAILED DEFENSE COUNSEL AND PROCEEDING TO SENTENCING OVER THE OBJECTION OF APPELLANT CONSTITUTED AN ABUSE OF DISCRETION AND IMPROPER INTERFERENCE WITH APPELLANT’S RIGHTS TO ASSISTANCE OF COUNSEL

I

THE FACTS

The facts giving rise to this assignment are well stated in Appellant’s brief. The following is drawn from that account:

A detailed defense counsel was assigned prior to the Article 32, UCMJ hearing. The detailed counsel was relieved when requested Individual Military Counsel (IMC) was made available, but was reassigned, as Associate Defense Counsel (Assoc. DC) after a short hiatus. The Assoc. DC participated fully in the preparation and presentation of the defense case and was to conduct the sentencing portion of the trial.

Findings were announced on the evening of 21 May 1992 and sentencing proceedings were set to begin on the morning of 22 May. However, at that time Appellant was unable to proceed with sentencing, and the case was continued for an indefinite period. Appellant underwent a mental examination in accordance with R.C.M. 706, Manual for Courts-Martial, United States 1984 (MCM) during the continuance.

On 12 June 1992, the court-martial was reconvened for sentencing after Appellant was found to have sufficient mental capaci[998]*998ty to continue with the trial. The sentencing proceedings were conducted without the presence of Assoc. DC over the strong objections of Appellant. The Assoc. DC had been relieved because of a temporary assignment afloat and a substitute Assoc. DC was detailed.

II

GROUNDS FOR RELIEF OF COUNSEL BY STAFF JUDGE ADVOCATE

The relief of the originally detailed Assoc. DC and assignment of a substitute were effected by the Staff Judge Advocate, Maintenance and Logistics Command Atlantic, who cited as authority for his action Rule for Courts-Martial (R.C.M.) 505(d)(2)(B)(iii) and R.C.M. 506(b)(3).

A

Excusal of Detailed Counsel under R.C.M. 506(b)(3)

R.C.M. 506(b)(3) in its entirety reads as follows:

Excusal of detailed counsel. If the accused is represented by individual military counsel, detailed defense counsel shall normally be excused. The authority who detailed the defense counsel, as a matter of discretion, may approve a request from the accused that detailed defense counsel shall act as associate counsel. The action of the authority who detailed the counsel is subject to review only for abuse of discretion.

The staff judge advocate was the proper authority to detail counsel pursuant to Article 3-C-l of the Coast Guard’s Military Justice Manual, COMDTINST M5810.1C, in effect at the time. As authorized by R.C.M. 506(b)(3), he could have permanently excused the detailed defense counsel from further participation in the case when the IMC was first made available. Instead, the detailed defense counsel, after first being excused, was then reassigned as associate defense counsel.

Despite the stage of trial, the active role played by Assoc. DC to that point, counsel’s intended role at sentencing, and the accused’s strong desires in the matter, the military judge, nevertheless, ruled that the staff judge advocate had authority to excuse the Assoc. DC under the terms of R.C.M. 506(b)(3). The Government, citing that rule and Article 38(b)(6), UCMJ, argues that the judge correctly ruled in this regard, that the excusal of detailed counsel when an IMC has been assigned is within the sound discretion of the authority who detailed the counsel and such decision should not be reversed absent an abuse of discretion.

Appellant argued at trial that the relief of his Assoc. DC under R.C.M. 506(b)(3) was an abuse of discretion. We agree that such action was, indeed, an abuse of discretion, but it was also more than that. It was, as we see it, an act not authorized under either R.C.M. 506(b)(3) or Article 38(b)(6), UCMJ.

Both Article 38(b)(5) and (6), UCMJ, and R.C.M. 506(b)(3) provide for excusal of detailed defense counsel if the accused is represented by individual military counsel, but, if the accused requests the detailed defense counsel act as associate defense counsel, that request may be approved as a matter of discretion. The rule says nothing about excusing associate counsel after such a request is granted. Detailed defense counsel is the descriptive title for counsel before a request for retention as associate counsel is approved. Without a statement expressly authorizing excusal of an associate counsel in the same manner as detailed defense counsel, we believe the rule applies only to the situation when an individual military counsel is first made available.

At that point, the detailing officer must decide whether to excuse detailed counsel from further participation or allow retention in the case. If retention is permitted, it is our belief that subsequent removal must be for good cause shown, unless the accused consents. To read Article 38, UCMJ, and R.C.M. 506 otherwise would allow detailing officers unfettered authority to sever attorney-client relationships at any point in the trial. We do not believe [999]*999that is what either the Congress or the President intended. Accordingly, we find it was error to excuse Assoc. DC under color of R.C.M. 506(b)(3).

B

Severing the Attorney-Client Relationship for Good Cause Shown Under R.C.M. 505(d)(2)(B)(iii)

As his other basis for removing counsel, the staff judge advocate cited R.C.M. 505(d)(2)(B)(iii), which does call for a showing of good cause. Accordingly, we will review the staff judge advocate’s action under this rule also and determine whether good cause has been shown. In so doing, we note that R.C.M. 505(f) discusses the term “good cause” as it applies to changes of members, military judge and counsel. That rule reads as follows:

Good cause. For purposes of this rule, “good cause” includes physical disability, military exigency, and other extraordinary circumstances which render the member, counsel, or military judge unable to proceed with the court-martial within a reasonable time.

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Cite This Page — Counsel Stack

Bluebook (online)
37 M.J. 996, 1993 CMR LEXIS 340, 1993 WL 303976, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-bevacqua-cgcomilrev-1993.