United States v. David Paul Bender

469 F.2d 235, 1972 U.S. App. LEXIS 6807
CourtCourt of Appeals for the Eighth Circuit
DecidedNovember 8, 1972
Docket72-1226
StatusPublished
Cited by7 cases

This text of 469 F.2d 235 (United States v. David Paul Bender) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. David Paul Bender, 469 F.2d 235, 1972 U.S. App. LEXIS 6807 (8th Cir. 1972).

Opinion

LAY, Circuit Judge.

David Paul Bender, upon waiver of a jury, was convicted for refusal to submit to induction into the Armed Forces of the United States in violation of 50 U. S.C.App. § 462. The trial court, 336 F. Supp. 763, held that since he had failed to appeal his I-A classification and thereby exhaust his administrative remedies within the Selective Service System he was precluded from obtaining judicial review of his classification. Additionally, the district court found that the local board did not mislead the defendant so as to deter him from exercising his right of administrative appeal. 1

The facts show that the defendant initially registered with Local Board No. 42, Hennepin County, Minnesota, on June 25, 1964. He received II-S deferments for five years to enable him to graduate from college. He graduated in August 1969. On August 19, 1969, appellant was reclassified I-A. In May 1969 he accepted a contract to teach at a private school for the school year beginning in September 1969. This information was duly forwarded to the local board and was a part of defendant’s record when he was reclassified I-A in August 1969. Defendant did not appeal his I-A classification and an order to report for induction was issued on October 6, 1969. However, due to his teaching engagement, defendant sought and received postponements issued October 14, 1969, January 7, 1970, and June 18, 1970, enabling him to teach until the end of the Spring 1970 semester. On July 17, 1970, defendant submitted a Form 150 requesting a 1-0 classification as a conscientious objector. Because of the pending induction order this request was rejected by the local board at their July 21, 1970, meeting. On August 14, 1970, defendant’s postponement was terminated and he was ordered to report for induction on September 21, 1970. From defendant’s failure to submit to induction as above ordered, his indictment, trial and conviction ensued.

The record reveals conflicting evidence as to whether the defendant was misled by the secretary of the local board concerning his appeal rights. The trial court found that the defendant was not misled by the information given by the secretary. There exists substantial evidence which supports the district court’s finding of fact. This finding, of course, cannot be set aside on appeal unless it is clearly erroneoús. We cannot assess the record in this light. 2

*237 The fundamental issue then is whether judicial review is precluded since the defendant had failed to exhaust his administrative appeal. The trial court felt bound by the principles of McGee v. United States, 402 U.S. 479, 91 S.Ct. 1565, 29 L.Ed.2d 47 (1971). We must respectfully disagree.

Prior to the McGee case, McKart v. United States, 395 U.S. 185, 89 S.Ct. 1657, 23 L.Ed.2d 194 (1969), was decided. The registrant in McKart claimed that he would have been exempt from military service because he was the “sole surviving son” within the meaning of 50 U.S.C.App. § 456(o). The district court held that he could not raise that defense since he failed to exhaust his administrative remedies. The Supreme Court disagreed and in doing so reviewed the proper role the exhaustion doctrine should occupy in selective service cases. The Court noted that the exhaustion doctrine should not be applied “blindly in every case” (McKart at 201) and recognized that the use of the exhaustion doctrine can be “exceedingly harsh” in criminal cases. Id. at 197. The Court went on to hold that the question of whether a registrant is entitled to a sole surviving son exemption is solely one of statutory construction. As such, its resolution does not require any particular expertise by the appeal board. Therefore, since administrative review of an issue involving only statutory construction would not significantly aid a subsequent judicial review, the Court found no “compelling reason why petitioner’s failure to appeal should bar his only defense to a criminal prosecution.” Id. at 199, 89 S.Ct. at 1665.

Two terms later the Court decided McGee v. United States, 402 U.S. 479, 91 S.Ct. 1565, 29 L.Ed.2d 47 (1971). The registrant in McGee applied for a conscientious objector status and submitted a Form 150 setting forth his views concerning participation in war. The registrant’s request was rejected by the local board and he was classified I-A. The registrant did not seek either a personal appearance before the board nor review by the appeal board. In fact, he returned, unopened, the letter sent by the board informing him of his specific appeal rights since he was pursuing a policy of noncooperation. At his trial for refusal to submit for induction, the registrant claimed that the local board erred in classifying him I-A. Both the trial court and the court of appeals held that such a defense was barred because petitioner failed to exhaust his administrative remedies. The Supreme Court agreed and affirmed the judgment of conviction.

The Court took note of the fact that “McKart expressly noted that as to classification claims turning on the resolution of particularistic fact questions, ‘the Selective Service System and the courts may have a stronger interest in having the question decided in the first instance by the local board and then by the appeal board, which considers the question anew.’ ” 402 U.S. at 486, 91 S.Ct. at 1570. The Court then stated:

“The exhaustion requirement is properly imposed where, as here, the claim to exemption depends on careful factual analysis and where the registrant has completely sidestepped the administrative process designed to marshal relevant facts and resolve factual issues in the first instance.” McGee at 488, 91 S.Ct. at 1571.

*238 It is true that a II-A deferment generally involves the same gathering and analysis of relevant facts as a 1-0 classification. 3 On this basis there is much force in the trial court’s observation that McGee is more controlling than McKart and the failure here by the defendant to exhaust all administrative remedies should not be excused. However, directly involved here and the apparent basis of the board’s rejection of defendant’s II-A deferment in August 1969 was the board’s construction of 32 C.F.R. § 1622.23(a)(1).

On June 9, 1969, when the defendant completed his application he stated that his occupation at that time was a “student” but that he was under contract to teach beginning in September 1969. One of the fundamental questions for the local board to resolve in applying § 1622.23 would be the proper interpretation to be given to § 1622.-23(a)(1).

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Bluebook (online)
469 F.2d 235, 1972 U.S. App. LEXIS 6807, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-david-paul-bender-ca8-1972.