United States v. Dunbar

31 M.J. 70, 1990 CMA LEXIS 1046, 1990 WL 134273
CourtUnited States Court of Military Appeals
DecidedSeptember 19, 1990
DocketNo. 62,967; NMCM 88-3025
StatusPublished
Cited by84 cases

This text of 31 M.J. 70 (United States v. Dunbar) 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. Dunbar, 31 M.J. 70, 1990 CMA LEXIS 1046, 1990 WL 134273 (cma 1990).

Opinions

Opinion of the Court

EVERETT, Chief Judge:

In October 1985, a military judge sitting alone as a special court-martial convicted appellant, pursuant to his pleas, of a single unauthorized absence of 78 days and sentenced him to a bad-conduct discharge, confinement for 1 month, forfeiture of $413, and reduction to the lowest enlisted grade.1 Pursuant to a pretrial agreement, the convening authority was obligated to disapprove the confinement and the forfeiture, but instead he approved the trial results despite the recommendation of the Staff Judge Advocate. Yet the undated court-martial order achieved the proper result by stating the sentence as the one agreed to rather than the one adjudged. The Court of Military Review affirmed. 28 MJ 972 (1989).

Based upon a delay of over 37 months between the date of his trial and the date that the record finally was docketed in the Court of'Military Review, Dunbar renews the contention he first made below that he was denied a speedy review of his conviction and, thus, is entitled to dismissal of the charge underlying it. However, because appellant has not demonstrated any prejudice emanating from this unconscionable delay, we cannot accede to his prayer for relief.

I

This Court is called upon once again to assess what prejudice, if any, an appellant has suffered when his case has been subjected to inordinate and inexcusable delay after he has been tried. The Court of [71]*71Military Review aptly described the issue as one where “appellant’s case has languished for 1097 days in post-trial appellate (the time between the convening authority’s action and docketing of the case by the Court of Military Review) limbo without explanation.” 28 MJ at 975.

The facts as they relate to this delay are rather simple — and they do not paint a pretty picture of the Navy’s post-trial case management. After he had been found guilty pursuant to his pleas of an unauthorized absence of less than 3 months, Dunbar requested during his sentence proceedings to be discharged from the Navy. In a pretrial agreement, the convening authority had agreed to disapprove all confinement that might be imposed if appellant received a punitive discharge as part of his sentence.2

Appellant’s full trial, including sentencing, lasted just 43 minutes; and the entire verbatim record extended to just 24 pages. There are 4 prosecution exhibits; 14 defense exhibits; and 1 appellate exhibit of 4 pages. The military judge authenticated the record within 10 days, and the convening authority acted upon the record within 24 days.

Incredibly, the record did not reach the United States Navy-Marine Corps Appellate Review Activity (ÑAMARA) in Washington, D.C., until late July 1988, well over 2V2 years after the convening authority had acted. The events in the several months preceding receipt of the record conjure mental images resembling the bumbling and bungling of a “Three Stooges” episode.

After much sea-to-sea, sea-to-land, and land-to-sea message traffic during April and May of 1988, it was concluded at last that the original record of trial had been lost — and a variety of possibilities came to mind as to how that might have happened. In any event, the Judge Advocate General wrote the convening authority and requested that the record either be located or reconstructed. Finally, the record was reconstructed; and the military judge authenticated it on July 7, 1988, without a number of papers and exhibits (including 13 defense exhibits).

On July 28, 1988, two records of appellant’s trial arrived at ÑAMARA — the reconstructed record and what apparently was a photocopy of the original record that contained all the exhibits and was substantially similar to the reconstructed record. After much ado about this curious circumstance, the case — at long last — was docketed in the Court of Military Review on November 18, 1988 — a total of 1121 days after the trial.

In what might be mere obeisance to the sadly obvious, the Government has offered no serious excuses for this extraordinary delay in the administrative mishandling of this rather ordinary record of trial. Instead, the Government responds to appellant’s cries for relief by saying that there is nothing from which to relieve him — that is, appellant has suffered no prejudice from this delay, no matter how reprehensible it is. Accordingly, we reach the question— what is the nature of the prejudice that is material to our disposition of a complaint of delay of this nature?

II

In addressing prejudice from appellant’s claim of foul, the court below stated:

[Dismissal of the charges is appropriate only when some error in the trial proceedings requires corrective action and the appellant would be prejudiced in the presentation of his case at a rehearing or when no useful purpose would otherwise be served by continuing the proceedings. [United States v.] Green, 4 M.J. [203] at 204 [(CMA 1978)]; United States v. Gray, 22 U.S.C.M.A. 443, 47 C.M.R. 484 (1973).

28 MJ at 975. The Government, likewise, relies heavily in this Court upon Green and [72]*72its predicate precedent. Thus, our attention initially turns to that case.

Green involved a delay of some 8 months in forwarding the accused’s signed petition for review from the staff judge advocate’s office, where he had filed it, to this Court, after service on him of the decision of the Court of Military Review. Judge Cook’s opinion there does reflect the notion found in the decision below in this case:

[A]bsent prejudicial error occurring during the court-martial proceedings, an inordinate delay at the appellate level does not justify dismissal of the charges. A dismissal is appropriate only where an accused “would be either prejudiced in the presentation of his case at a rehearing or ... no useful purpose would otherwise be served by continuing the proceedings.”

4 MJ at 204. Beyond that, however, little can be said with certainty in light of the two separate opinions.

Chief Judge Fletcher, concurring,

add[ed] that any “flagrant disregard” of the accused’s appellate rights under circumstances which shock the conscience of this Court will not be condoned even in the absence of particular prejudice to an individual accused.

Id. (footnote omitted; emphasis added). Finally, Judge Perry concurred in the result because of “the absence of prejudice flowing to the appellant from the” delay— without specifically identifying what type of prejudice he had in mind.

Considering all three opinions in Green, we are unsure whether that case stands, unequivocally, for any absolute legal principle or standard. Thus, unconstrained but appropriately guided by this precedent, we examine “prejudice” from post-trial delay. Specifically, we are concerned with a claim of prejudice other than that which might inure to an accused at his rehearing or new trial ordered to remedy prejudicial error discovered on appeal.

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Cite This Page — Counsel Stack

Bluebook (online)
31 M.J. 70, 1990 CMA LEXIS 1046, 1990 WL 134273, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-dunbar-cma-1990.