United States v. Drayton

39 M.J. 871, 1994 CMR LEXIS 106, 1994 WL 102960
CourtU.S. Army Court of Military Review
DecidedMarch 28, 1994
DocketACMR 9201149
StatusPublished
Cited by3 cases

This text of 39 M.J. 871 (United States v. Drayton) is published on Counsel Stack Legal Research, covering U.S. Army Court of Military Review primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Drayton, 39 M.J. 871, 1994 CMR LEXIS 106, 1994 WL 102960 (usarmymilrev 1994).

Opinion

OPINION OF THE COURT ON REMAND

LANE, Judge:

Pursuant to his pleas, the appellant was convicted by a military judge sitting as a special court-martial of larceny from the post exchange (PX), in violation of Article 121, Uniform Code of Military Justice, 10 U.S.C. § 921 (1988) [hereinafter UCMJ]. The convening authority approved the adjudged sentence to a bad-conduct discharge, forfeiture of $500.00 pay per month for six months, and reduction to Private El.

This case initially came before this court for review on 27 August 1992. Pursuant to United States v. Grostefon, 12 M.J. 431 (C.M.A.1982), the appellant asserted, inter alia, that his company commander, Captain (CPT) Jochen A. Thomas, was unlawfully influenced by his battalion commander (Lieutenant Colonel (LTC) Nash) to recommend specific court-martial action against him. This court affirmed the findings of guilty and the sentence without opinion. United States v. Drayton, ACMR 9201149 (A.C.M.R. 3 Dec. 1992) (unpub.).1 On 9 July 1993, the United States Court of Military Appeals set aside our decision, and remanded the case to this court to make specific findings regarding the appellant’s assertion “that his company commander was subjected to unlawful command influence.” United States v. Drayton, 38 M.J. 310 (C.M.A.1993) (summary disposition).

Subsequently, appellate counsel filed additional pleadings relative to the remanded issue. In an affidavit admitted before this court, the appellant restates his allegation of unlawful command influence upon his company commander.2 He further alleges, for the first time, that his battalion command sergeant major held a shoplifting briefing by PX security personnel prior to the appellant’s trial. Thereafter, “[a]ll the senior NCOs in the Battalion that would have spoke (sic) highly of me, told me ... they would have to think about it before they would testify on my behalf.” In response, the government filed an affidavit from CPT Thomas. He states that he discussed the case with his battalion commander, but denies that he was directed to recommend a certain court-martial or ever told the appellant that the decision was other than his own.3 For the rea[871]*871sons set forth below, we hold that the appellant’s allegations of unlawful command influence are without merit.

I. Company Commander’s Recommendation

A.

Unlawful command influence is proscribed by Article 37(a), UCMJ, 10 U.S.C. § 837(a), which states, in pertinent part: ,

No person subject to this chapter may attempt to coerce or, by any unauthorized means, influence the action of a court-martial or any other military tribunal or any member thereof, in reaching the findings or sentence in any case, or the action of any convening, approving, or reviewing authority with respect to his judicial acts.

In United States v. Bramel, 29 M.J. 958, 967 (A.C.M.R.), aff'd, 32 M.J. 3 (C.M.A.1990) (summary disposition), this court held that the foregoing language of Article 37(a) proscribes unlawful command influence “over the adjudicative processes of courts-martial ... empowered to determine guilt ... and to impose punishment____” The court held that an Article 32, UCMJ, investigation was not subject to the principles of Article 37(a), UCMJ, as its purpose was to gather evidence upon which a recommendation as to disposition of charges could be made, making it “accusatorial in nature and function.... ” Id. In other words, the reach of Article 37(a), UCMJ, extends only to the adjudicative processes of courts-martial, not to the accusatorial processes. The recommendation of a subordinate commander to his superior commander is also part of the accusatory process leading up to the referral or nonreferral of charges for trial, and does not directly affect the conduct of the trial or the parties thereto. Thus, we hold that the alleged directive to the company commander (if it occurred) does not, as a matter of law, constitute unlawful command influence.4

While not so stating, Bramel in effect repudiates the broad sweep of the unlawful command control language found in United States v. Hawthorne, 7 U.S.C.M.A. 293, 22 C.M.R. 83 (1956). In Hawthorne, the court was dealing with a command directive related to the disposition of charges against repeat offenders which also prescribed that the policy would be made known to court members. The court stated that it

has consistently held that any circumstance which gives even the appearance of improperly influencing the court-martial proceedings against the accused must be condemned. In regard to the pretrial proceedings, we set aside a conviction because, in his advice to the convening authority, the Staff Judge Advocate misstated the Investigating Officer’s recommendation for trial. United States v. Greenwalt, 6 USCMA 569 [285], 20 CMR 285 [(1955) ].

Hawthorne, 22 C.M.R. at 87-88. After conceding that the court did not desire to “curb” the convening authority in the exercise of his command powers, it found that that commander’s directive sought to curb the power to exercise discretion in the disposition of charges granted by the Uniform Code of Military Justice to the accused’s immediate commander. It also found that the directive entrenched upon the accused’s right to an impartial court-martial. “In sum, the policy directive directly tended to control the judicial processes rather than merely attempting to improve the discipline of the command. It was, therefore, illegal.” Id. at 89.

[872]*872The major defects in Hawthorne are that the court does not distinguish between pretrial and trial processes, and never once, in its entire discussion of “command control,” does it cite Article 37, UCMJ. Likewise, Greenwalt, which the court cites as an example of improper command influence in the pretrial stages of the court-martial process, does not rest on Article 37, UCMJ. Greenwalt held that the staff judge advocate, in misstating the investigator’s recommendation, failed in his Article 34, UCMJ, obligation.5 20 C.M.R. at 288. Thus, we are not hesitant to follow Bramel and draw a distinction between the accusatorial and adjudicative processes in a court-martial scenario, and to find that Article 37(a), UCMJ, only applies to the latter.6

B.

There are two methods available for challenging deficiencies in the accusatorial process. The first is to invoke the de facto accuser doctrine. Article 1(9), UCMJ, 10 U.S.C.A. § 801(9); United States v. Corcoran, 17 M.J. 137 (C.M.A.1984). In Corcoran, the court held that a convening authority was an accuser where he was the person who directed that charges be signed and sworn to by another and had other than an official interest in the prosecution of the accused. Id. at 138. Here, the alleged improper action is by the battalion commander, who lacked authority to convene a special court-martial empowered to impose a bad-conduct discharge.

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Cite This Page — Counsel Stack

Bluebook (online)
39 M.J. 871, 1994 CMR LEXIS 106, 1994 WL 102960, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-drayton-usarmymilrev-1994.