United States v. Captain LAMARIO D. THOMAS

CourtArmy Court of Criminal Appeals
DecidedJuly 8, 2026
Docket20240080
StatusUnpublished

This text of United States v. Captain LAMARIO D. THOMAS (United States v. Captain LAMARIO D. THOMAS) is published on Counsel Stack Legal Research, covering Army 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. Captain LAMARIO D. THOMAS, (acca 2026).

Opinion

UNITED STATES ARMY COURT OF CRIMINAL APPEALS Before FLOR, POND, and STEELE Appellant Military Judges

UNITED STATES, Appellee v. Captain LAMARIO D. THOMAS United States Army, Appellant

ARMY 20240080

Headquarters, Fort Bragg Tyler J. Heimann and Gregory B. Batdorff, Military Judges Colonel Joseph B. Mackey, Staff Judge Advocate

For Appellant: Frank J. Spinner, Esquire (on brief and reply brief).

For Appellee: Colonel Richard E. Gorini, JA; Major Elizabeth G. Van Dyck, JA; Captain Meghan E. Moore, JA (on brief).

8 July 2026

MEMORANDUM OPINION

This opinion is issued as an unpublished opinion and, as such, does not serve as precedent.

STEELE, Judge:

An officer panel convicted appellant, contrary to his pleas, of one specification of sexual assault, two specifications of sexual assault of a child, and one specification of conduct unbecoming an officer and a gentleman, in violation of Articles 120, 120b, and 133, Uniform Code of Military Justice, 10 U.S.C. §§ 920, 920b, and 933 (2016) [UCMJ]. The panel sentenced appellant to a dismissal, twenty years of confinement, total forfeitures, and a reprimand.

On appeal, appellant raises three assignments of error, two of which warrant discussion but no relief. Appellant argues that: (1) the Army lost jurisdiction to try him by operation of law based upon his mandatory removal date; and (2) the THOMAS - ARMY 20240080

evidence is legally and factually insufficient to support his conviction of conduct unbecoming an officer for committing a sexual act upon the victim while acting in a parental role over her. 1 For the reasons set forth below, we disagree and conclude the Army maintained jurisdiction to try appellant and the evidence to support his convictions is legally and factually sufficient.

BACKGROUND

Between 5 July 2018 and 21 December 2021, appellant was investigated by local authorities and the Army's Criminal Investigation Division for sexual assault of a child and sexual assault. After appellant was twice non-selected for promotion to major, on 30 June 2022, he was notified by the U.S. Army Human Resources Command (HRC) that consequently he would be mandatorily removed from the Army, by either separation or retirement, with a mandatory removal date (MRD) of 31 December 2022. Appellant, having served nearly twenty-six-and-a-half years on active duty, elected to retire and received retirement orders, dated 27 October 2022, with an effective retirement/separation date of 31 December 2022. On 22 December 2022, after the conclusion of the four-plus year investigation and his sexual battery conviction in the North Carolina court system, court-martial charges were preferred against appellant. On 11 January 2023, appellant was informed by his commander that his retirement orders were revoked, and he received a copy of his revocation orders which were dated 10 January 2023. Appellant was arraigned upon the preferred charges on 23 February 2023.

LAW AND DISCUSSION

A. Jurisdiction

1. Additional Background

After arraignment, appellant's defense counsel filed a motion to dismiss all charges due to a lack of jurisdiction. The defense asserted appellant's retirement orders were not properly revoked prior to becoming effective, were not revoked by the proper authority, and he was not recalled to active duty. The government opposed the motion asserting appellant never received delivery of a final discharge certificate (Department of Defense (DD) Form 214) which was not located in his Interactive Personnel Electronics Records Management System (iPERMS) or the Transition Processing System (TRANSPROC) database; never received a final

1 Appellant raised an additional assignment of error, alleging his other convictions are factually insufficient, of which we have given full and fair consideration and find to be without merit. We have also given full and fair consideration to the matters personally raised by appellant pursuant to United States v. Grostefon, 12 M.J. 431 (C.M.A. 1982), and determine they warrant neither discussion nor relief.

2 THOMAS - ARMY 20240080

accounting of pay; never completed the clearing process; and preferral of appellant's court-martial charges automatically suspended all favorable actions, including appellant's retirement.

During the Article 39(a) motions, Mr. , who worked in the Out-Processing Section of the installation's Military Personnel Division (MPD) testified appellant never received a preclearance stamp or completed an out-processing packet to clear the installation, and that his supervisor, Ms. , instructed him to not clear appellant because he was flagged. Ms. , a supervisor in the out-processing section, testified the office was unable to complete DD Form 214s or issue orders from 23 December 2022 through 10 January 2023 due to a transitional "brownout" period when legacy Army human resources and pay systems were taken offline so that data could be transferred into the new Integrated Personnel and Pay System - Army.2 She further testified that appellant's unit S-1 personnel office informed her that appellant was being court-martialed, after which she revoked his retirement orders on 10 January 2023. Because of this, appellant, who had not finalized his DD Form 214 prior to the end of December 2022, did not receive a final DD Form 214.

Regarding final pay, Mr. , who also worked in the MPD out-processing section, testified that an MRD stopped all pay at the MRD date even if a soldier was not being out-processed or discharged. He further testified that, in appellant's case, any discharge would not be effective unless a completed DD Form 2656, establishing appellant's retirement pay account, 3 was on file and uploaded to the Defense Finance and Accounting Service. He stated this would be the case even if the MPD had finalized the DD Form 214 without the soldier's signature, for instance, if the soldier was unavailable or refused to sign. Mr. then testified his supervisor, Ms. processed the revocation of appellant's retirement when he was on leave and appellant did not have a final DD Form 214.

Appellant testified that Ms. informed him that no matter what appellant did, he would be separated on 31 December 2022. Appellant testified further that he

2 During this period, S1 (Personnel) shops and Human Resource professionals working in MPD, could not process transactions (i.e. separations, assignments, and updates to records) in the legacy programs (i.e. Electronic Military Personnel Office (eMILPO)) while data was converted. 3 The DD Form 2656 is a mandatory document retiring U.S. military members use to establish their retired pay accounts. It records direct deposit instructions, federal tax withholdings, beneficiary designations, and Survivor Benefit Plan elections.

3 THOMAS - ARMY 20240080

had a retiree ID card4 and was reassigned to retiree Tricare yet acknowledged that he knew he needed to clear the installation, that his Commander informed him that his retirement orders were revoked, and that he did not have a final DD Form 214 nor a final accounting of pay.

Mr. who worked at the installation's Military Pay Office, testified he revoked appellant's retirement processing and cancelled his separation transaction in the pay system after receiving the revocation orders on 12 January 2023.

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United States v. Captain LAMARIO D. THOMAS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-captain-lamario-d-thomas-acca-2026.