United States v. Deremer

Court of Appeals for the Armed Forces·Decided July 23, 2026·No. 25-0158/MC·Published

Opinion

This opinion is subject to revision before publication.

UNITED STATES COURT OF APPEALS FOR THE ARMED FORCES _______________

UNITED STATES Appellant

v.

Danielle E. Deremer, Private First Class United States Marine Corps, Appellee

No. 25-0158 Crim. App. No. 202300205

Argued January 28, 2026—July 23, 2026

Military Judge: Benjamin A. Robles

For Appellant: Major Mary Claire Finnen, USMC (argued); Lieutenant K. Matthew Parker, JAGC, USN, Brian K. Keller, Esq. (on brief); Lieutenant Colonel Candace G. White, USMC.

For Appellee: Lieutenant Raymond E. Bilter, JAGC, USN (argued).

Amici Curiae for Appellee: Captain Daniel Cimmino, JAGC, USN, Lieutenant Sterling Gutierrez, JAGC, USN, and Lieutenant Girija Hathaway, JAGC, USN (on behalf of the U.S. Navy Victims’ Legal Counsel Program), Colonel Joseph I. Grimm, USMC (on behalf of the U.S. Marine Corps Victims’ Legal Counsel Organization), Colonel Andres Vazquez Jr. (on behalf of the U.S. Army Special Victims’ Counsel Program), and Elizabeth G. Marotta, Esq. (on behalf of the U.S. Coast Guard Special Victims’ Counsel Program) (on brief). United States v. Deremer, No. 25-0158/MC Opinion of the Court

Amicus Curiae: Sean J. Kealy, Esq., Boston University School of Law (in support of neither party) (on brief).

Judge JOHNSON delivered the opinion of the Court, in which Chief Judge OHLSON and Judge HARDY joined. Judge SPARKS filed a separate opinion concurring in the judgment, in which Judge MAGGS joined. _______________

2 United States v. Deremer, No. 25-0158/MC Opinion of the Court

Judge JOHNSON delivered the opinion of the Court. This certified case raises issues that require the Court to interpret the nature and scope of the rights set forth in 10 U.S.C. § 1044e, Special Victims’ Counsel for victims of sex-related offenses (SVC). 1 Appellee, 2 a recruit attending Marine Corps boot camp at Parris Island, South Carolina, reported that she was sexually abused and harassed by a female recruit in her training platoon. Naval Criminal Investigative Service (NCIS) agents conducted an initial interview with Appellee in the presence of her VLC. They also questioned several members of Appellee’s training platoon. As a result of these interviews, the agents began to suspect Appellee’s report was untruthful. NCIS agents interviewed Appellee a second time, without notifying her VLC. During this second interview, Appellee affirmatively waived her Article 31(b), Uniform Code of Military Justice (UCMJ), 10 U.S.C. § 831(b) (2018), rights and made incriminating statements. A special court-martial convicted Appellee, contrary to her pleas, of one charge and specification of malingering (Charge I), and one charge and specification of making a false official statement (Charge II), in violation of Articles 83 and 107, UCMJ, 10 U.S.C. §§ 883, 907 (2018). The military judge sentenced Appellee to a bad-conduct

1 Although the statute refers to SVC, the Navy and Marine Corps refer to SVC as Victims’ Legal Counsel (VLC). See Dep’t of the Navy, Marine Corps Administrative Message 583/13, Establishment of the Marine Corps Victims’ Legal Counsel Organization (VLCO) (Oct. 13, 2013); Dep’t of the Navy, Navy Administrative Message 087/14, Establishment of Navy Victims’ Legal Counsel (VLC) Program (Apr. 14, 2014). This opinion uses Navy and Marine Corps terminology and the statutory term interchangeably. 2 Private First Class (PFC) Deremer was the appellant at the lower court and she is referred to as “Appellant” in the questions certified to this Court. Since the case was certified to this Court by the Judge Advocate General of the Navy on behalf of the Government as the Appellant, we refer to PFC Deremer as Appellee.

3 United States v. Deremer, No. 25-0158/MC Opinion of the Court

discharge and a reduction to the grade of E-1. The United States Navy-Marine Corps Court of Criminal Appeals (CCA) affirmed the finding of guilty as to Charge I and its specification, but set aside the finding of guilty and the sentence as to Charge II and its specification. United States v. Deremer, 85 M.J. 546, 555 (N-M. Ct. Crim. App. 2025) (en banc). The Judge Advocate General of the Navy (TJAG) certified four issues for review in this Court: I. Did the lower court err holding [Appellee], at an interview where she waived her right to counsel, was entitled to 10 U.S.C. § 1044e rights when she was interviewed as a suspect? II. Did the lower court err finding the interview violated [Appellee’s] due process rights, and finding the statement involuntary under Mil. R. Evid. 304? III. Did the lower court err holding that suppression is an appropriate remedy for a violation of 10 U.S.C. § 1044e? IV. Did the lower court err by affirming [Appellee’s] conviction for malingering despite holding her confession to NCIS should have been suppressed? United States v. Deremer, 86 M.J. 116 (C.A.A.F. 2025) (docketing notice of certificate for review). For the reasons stated below, we answer the first certified issue in the negative and hold that Appellee was entitled under 10 U.S.C. § 1044e to VLC when she was interviewed by NCIS as a suspect for making false sexual abuse and sexual harassment allegations. We answer the second and third certified issues in the affirmative and hold that 10 U.S.C. § 1044e, in its current form, creates neither a due process right to VLC nor a suppression remedy for violations of the statute. Accordingly, we set aside the decision of the CCA. In light of our resolution of the second and third certified issues, we need not reach the fourth certified issue.

4 United States v. Deremer, No. 25-0158/MC Opinion of the Court

I. Background Appellee enlisted in the United States Marine Corps and reported to boot camp at Parris Island, South Carolina, in June 2021. While at boot camp, Appellee reported to NCIS that she was sexually abused and harassed by PFC Hotel, 3 a female recruit in her training platoon. Appellee was seated in a wheelchair when she was interviewed by NCIS. During the interview, in the presence of her VLC, Appellee described multiple instances where PFC Hotel touched her inappropriately without consent, including once in a shower area and also in an open bunk room. Appellee also described several instances where PFC Hotel harassed her using sexually explicit remarks. Following the NCIS interview, the lead agent, Special Agent (SA) MP, told Appellee, “I may reach out to you again, it’s not likely. But what I’ll do is I’ll go through your VLC . . . . And he’ll reach out to you.” After interviewing Appellee, SA MP began interviewing witnesses. One witness corroborated Appellee’s allegations, stating she saw PFC Hotel force Appellee to touch her naked buttocks in the shower of the squad bay and heard PFC Hotel make sexually suggestive comments. However, six members of the training platoon told SA MP they did not witness any of the alleged behavior, and two of them said they did not believe Appellee was telling the truth because she had a reputation for untruthfulness. When SA MP interviewed PFC Hotel, she waived her rights and denied the allegations.

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