United States v. DOWNS

CourtNavy-Marine Corps Court of Criminal Appeals
DecidedMay 27, 2026
Docket202500109
StatusPublished

This text of United States v. DOWNS (United States v. DOWNS) is published on Counsel Stack Legal Research, covering Navy-Marine Corps 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. DOWNS, (N.M. 2026).

Opinion

This opinion is subject to administrative correction before final disposition.

Before KISOR, GANNON, and KORN Appellate Military Judges

_________________________

UNITED STATES Appellee

v.

Aron B. DOWNS Gunner’s Mate First Class Petty Officer (E-6), U.S. Navy Appellant

No. 202500109

Decided: 27 May 2026

Appeal from the United States Navy-Marine Corps Trial Judiciary

Military Judge: Kimberly J. Kelly

Sentence adjudged 1 November 2024 by a general court-martial tried at Naval Air Station Pensacola, Florida and Naval Air Station Jackson- ville, Florida. Sentence in the Entry of Judgment: reduction to E-1, con- finement for 18 years and 6 months, and a dishonorable discharge.

For Appellant: Lieutenant Jesse B. Neumann, JAGC, USN

For Appellee: Lieutenant Commander Philip J. Corrigan, JAGC, USN (argued) Lieutenant K. Matthew Parker, JAGC, USN (on brief) United States v. Downs, NMCCA No. 202500109 Opinion of the Court

Judge KORN delivered the opinion of the Court, in which Senior Judge KISOR and Judge GANNON joined.

This opinion does not serve as binding precedent, but may be cited as persuasive authority under NMCCA Rule of Appellate Procedure 30.2.

KORN, Judge:

A general court-martial composed of members convicted Appellant, con- trary to his pleas, of one specification of attempted sexual assault of a child, one specification of attempted sexual abuse of a child by intentionally com- municating indecent language, one specification of distributing child pornog- raphy, and one specification of viewing child pornography, in violation of Arti- cles 80 and 134, Uniform Code of Military Justice (UCMJ). 1 Appellant pleaded guilty to three specifications of communicating indecent language, in violation of Article 134. The military judge sentenced Appellant to reduction to E-1, con- finement for 18 years and 6 months, and a dishonorable discharge.

Appellant raises six assignments of error (AOE), which we renumber as follows:

I. Whether the military judge erred by (1) ruling that HN Bravo was not required to administer Article 31(b) warn- ings and (2) admitting evidence derived from Appellant’s unwarned statements to HN Bravo.

II. Whether the military judge erred in permitting the prior Whisper chats to be used as evidence of intent un- der Mil. R. Evid. 404(b).

III. Whether the evidence is factually sufficient to prove that the act of “traveling to meet ‘Kelsey’ ” was a substan- tial step taken with the specific intent of sexually assault- ing a fictitious minor.

1 10 U.S.C. §§ 880, 934.

2 United States v. Downs, NMCCA No. 202500109 Opinion of the Court

IV. Whether the military judge erred by admitting imper- missible sentencing evidence.

V. Whether Appellant’s sentence is plainly unreasonable.

VI. Whether under United States v. Palik, trial defense counsel was ineffective for failing to move for production of the NCIS interrogation under R.C.M. 914. 2

We find no prejudicial error and affirm the findings and sentence.

I. BACKGROUND The series of events that led to this appeal began when Appellant, a mar- ried 29-year-old with a newborn child, responded to a post on the messaging application “Whisper” which read “I don’t wana go to school tomorrow.” 3 Shortly after Appellant responded, the poster identified herself as “Kelsey,” a 12-year-old girl in sixth grade. Appellant sent a series of sexually explicit messages to “Kelsey,” and pro- posed meeting in person to engage in sexual activity. Unbeknownst to Appel- lant, he was actually corresponding with Mr. Sierra, 4 an adult man in Indiana who was posing as “Kelsey” in order to “catch and expose online child preda- tors.” 5 Because Appellant was in Jacksonville, Florida, Mr. Sierra enlisted a Flor- ida-based woman, Ms. Delta, to confront Appellant when he tried to meet “Kel- sey.” Ms. Delta ran “Protect the Innocent” (PTI), where she worked to expose would-be sex offenders, filmed the encounters, and posted them online. Ulti- mately Appellant and “Kelsey” agreed to meet at a movie theater in Jackson-

2 It is clear from the record that the portion of the interrogation that Appellant now

claims is missing never actually existed. Since Appellant’s argument relies on a re- cording that never was, defense counsel was not deficient for failing to seek it, and we see no need to further analyze this issue. See United States v. Matias, 25 M.J. 356, 361 (C.M.A. 1987); United States v. Murray, No. 2024-04, 2024 CCA LEXIS 280, *10 (A.F. Ct. Crim. App. July 12, 2024) (determining that R.C.M. 914 does not apply to a record- ing that never existed). 3 Pros. Ex. 2 at 1.

4 All names in this opinion, other than those of Appellant, the judges, and counsel,

are pseudonyms. 5 R. at 640-41.

3 United States v. Downs, NMCCA No. 202500109 Opinion of the Court

ville, after which they planned to spend the night at Appellant’s house. Appel- lant told “Kelsey” he would get condoms, asking her, “You want sex tonight don’t you?” 6 Ms. Delta went to the movie theater to confront Appellant. She was accom- panied by her husband, Hospital Corpsman (HN) Bravo, who filmed the en- counter. When the pair approached Appellant in the movie theater lobby, he ran out of the theater and into the parking lot. Ms. Delta and HN Bravo chased him, catching up to him near his car. While HN Bravo recorded the interaction, Ms. Delta spoke with Appellant about his chats with “Kelsey” and what he intended to do once he met her. Appellant initially claimed he only intended to watch a movie and planned to tell “Kelsey” he’d changed his mind about engaging in sexual activity with her. However, he admitted to sending the sexually explicit messages, repeat- edly said that he had a problem and needed help, and ultimately admitted that he had purchased a box of condoms and brought them with him to the movie theater. Ms. Delta then walked away to call local Clay County law enforce- ment, who came to the parking lot and spoke with Appellant. In Ms. Delta’s absence, HN Bravo continued the conversation with Appellant. Ms. Delta later reported Appellant’s actions to the Naval Criminal Investi- gative Service (NCIS), which opened an investigation and interviewed Appel- lant. Appellant spoke about his interactions with “Kelsey,” and further told the agents that they would find images of child pornography on his phone, and that he had exchanged child pornography with other Whisper users. A subsequent forensic examination of Appellant’s phone revealed multiple Whisper chats where Appellant had discussions about engaging in sexual ac- tivity with other Whisper users’ minor family members, and where he dis- cussed his sexual interest in both his own daughter and his wife’s 12-year-old sister. At trial, the Government introduced one of those chats to demonstrate Appellant’s intent to engage in sexual activity with “Kelsey.” 7 That chat in- cluded discussions where Appellant asked another Whisper user to bring their 15-year-old daughter to Florida so Appellant could have sex with her. This con- versation occurred contemporaneously with Appellant’s chat with “Kelsey.” The forensic examination also found Whisper chats where Appellant ex- changed child pornography with other Whisper users. The forensic examina- tion further revealed more than 700 images of child pornography on Appel- lant’s phone.

6 Pros. Ex. 3 at 110.

7 The military judge granted Appellant’s motion to exclude two other chats.

4 United States v. Downs, NMCCA No. 202500109 Opinion of the Court

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