United States v. Cauley

12 M.J. 484, 1982 CMA LEXIS 18685
CourtUnited States Court of Military Appeals
DecidedApril 19, 1982
DocketNo. 39,473/AR; SPCM 14370
StatusPublished
Cited by3 cases

This text of 12 M.J. 484 (United States v. Cauley) is published on Counsel Stack Legal Research, covering United States Court of Military 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. Cauley, 12 M.J. 484, 1982 CMA LEXIS 18685 (cma 1982).

Opinions

Opinion of the Court

COOK, Judge:

Although it noted certain illaudable actions at accused’s special court-martial trial, the United States Army Court of Military Review affirmed the findings of guilty and the sentence. We reverse the court’s decision.

Convened in Nellingen, Federal Republic of Germany, the court-martial convicted accused of six specifications alleging issuance of a worthless check, in violation of Article 123(a), Uniform Code of Military Justice, 10 U.S.C. § 923(a). The checks were drawn on a bank in Indiana between December 28, 1978, and January 18, 1979. All were cashed by accused at an American Express (AMEX) facility at Robinson Barracks, in Stuttgart, and all were returned by the Indiana bank for insufficient funds.

Article 123(a) provides, in material part, that the maker’s failure to pay the holder “within five days after receiving notice, orally or in writing, that ... [a] cheek . . . was not paid on presentment” “because of insufficient funds” constitutes “prima facie evidence of . . . intent to defraud” in the making of the check. See United States v. Margelony, 14 U.S.C.M.A. 55, 33 C.M.R. 267 (1963). Prosecution exhibit 9, admitted over defense counsel’s objection, is the AMEX file copy of a letter, dated February 21, 1979, from AMEX to accused’s commanding officer. The subject of the letter is accused’s “[¡Indebtedness” for “dishonoured checks.” After the signature, identified as that of the manager of the AMEX facility, the following typed notations appear:

end.: photo copies of checks and correspondence
cc.: Sp/4 Matthew Cauley

Convinced that the evidence “was insufficient to show that the letter had been mailed to the” commander and “that a copy had been sent to” accused, the Court of Military Review concluded “the Government . . . [could] not rely on the statutory presumption of intent to defraud.” 9 M.J. 791, 793 (C.M.R.1980). Without expressly ruling the trial judge erred in admitting the letter into evidence because of the absence of proof of mailing, the court observed that the judge “exacerbated the situation” (id., n. 5) by instructing the court members as follows (emphasis added):

As I advised before, proof of intent to defraud is an essential element with regard to the 123a offense. . . . [I]ntent may be proven by circumstantial evidence. ... In this regard, you may consider all relevant facts and circumstances, including but not limited to the nature and duration of the check writing, the amount of the checks, closeness in proximity of the written checks, the fact that the accused was notified in writing from the bank, apparently by his commander, if you believe an inference to be drawn and receiving that evidence, and believe the accused did receive notice as testified to, and thereafter the accused did not make payment or restitution to the bank.

At the time of trial, paragraph 138a, Manual for Courts-Martial, United States, 1969 (Revised edition), provided that “[p]roof that a letter correctly addressed and properly stamped ... was deposited in the mail . . . supports] an inference that it was delivered to the addressee.” See Leasing Associates, Inc. v. Slaughter & Son, Inc., 450 F.2d 174 (8th Cir. 1971). In his closing argument, trial counsel maintained that “[a] copy of . . . [the letter of February 21] was sent to the accused” so that he “had notice by that date” of the nonpayment of the checks in issue. The last part of the trial judge’s instruction seems to track trial counsel’s statement in that it authorized the court members to find that “the accused did receive notice as testified [486]*486to.” However, there is no factual basis for a finding that accused received the letter in the mail.

The manager did not testify that accused was sent a copy of the letter. His answer to trial counsel’s question as to whether “a copy of that” letter had been “sent to” accused was: “Yes, it’s so indicated on there.” However, the letter does not mention accused’s address, and no evidence was presented to show that the envelope in which the copy was placed was “correctly addressed” to the accused. Moreover, an entry in a document included in the AMEX file, which was also admitted into evidence, overwhelms the manager’s implication that the “cc” on the letter attests to its mailing. The document is titled, “Summary of Collection Efforts.” It contains two entries that deal with a letter to both the accused and his commanding officer. The first, dated February 12, refers to a letter “to Cauley and C.O.”; the second letter, which is prosecution exhibit 9, reads, in material part, “letter (second) to C.O.” The entry makes no mention of a copy of the letter to the accused. It follows that, as a matter of law, the trial judge erred in his representation to the court members that it could find from the evidence that accused directly “did receive notice” from AMEX of dishonor of the checks in issue. See para. 73c, Manual, supra; United States v. Grandy, 11 M.J. 270, 276-77 (C.M.A.1981).

The trial judge also erred in that part of his instruction which represented as “fact that the accused was notified in writing from the bank, apparently by his commander” of nonpayment of the checks. (Emphasis added). According to the evidence, AMEX wrote two letters to accused’s commanding officer regarding checks that had been refused payment by the drawee bank because of insufficient funds. One is dated February 8, 1979; it is included in the AMEX file admitted in evidence as prosecution exhibit 10; the other is the February 21st letter, admitted as prosecution exhibit 9. The manager was questioned about the mailing of “letters, like Prosecution Exhibit 9.” The examination by the military judge was as follows:

Q. Are these letters, like Prosecution Exhibit 9 for identification, sent out in the normal course of your banking business?
A. I didn’t get that, sir?
Q. Are copies of letters like Prosecution Exhibit 9, is that done in the normal course of your banking business?
A. Did we write this and send this letter?
MJ: Yes.
A. Yes, we do this.
MJ: For the record, I am examining a duplicate original photo copy of a letter being an exact copy of Prosecution Exhibit 9 for identification.
Now this copy that you have there in front of you from your file folder, is that maintained by the bank in the normal course of the bank’s business?
A. It is.
Q. Are you one of the custodians of the bank’s documents?
A. Yes.
MJ: Your objection is overruled. Prosecution Exhibit 9 for identification is admitted into evidence as Prosecution Exhibit 9.

We assume, but do not decide, that the manager’s testimony is sufficient to support a finding that both letters were mailed to, and received by, the commanding officer.

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Related

United States v. Cowan
39 M.J. 950 (U.S. Navy-Marine Corps Court of Military Review, 1994)
United States v. Alford
31 M.J. 814 (U S Air Force Court of Military Review, 1990)
United States v. Jefferson
13 M.J. 779 (U.S. Army Court of Military Review, 1982)

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Bluebook (online)
12 M.J. 484, 1982 CMA LEXIS 18685, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-cauley-cma-1982.