United States v. Fink

2025 WL 3293721
CourtU S Coast Guard Court of Criminal Appeals
DecidedNovember 26, 2025
Docket1502
StatusUnpublished

This text of 2025 WL 3293721 (United States v. Fink) is published on Counsel Stack Legal Research, covering U S Coast Guard 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. Fink, 2025 WL 3293721 (uscgcoca 2025).

Opinion

UNITED STATES COAST GUARD COURT OF CRIMINAL APPEALS

UNITED STATES

v.

James D. FINK Fireman (E-3), U.S. Coast Guard

CGCMG 0398 Docket No. 1502

26 November 2025

General court-martial sentence adjudged on 23 August 2023.

Military Judge: CDR Timothy N. Cronin, USCG Civilian Defense Counsel: Mr. Scott Hockenberry, Esq. Appellate Defense Counsel: LCDR Thadeus J. Pope, USCG Appellate Government Counsel: Mr. John P. Nolan, Esq. LCDR Elizabeth M. Ulan, USCG LT Christopher J. Hamersky, USCG Special Victims’ Counsel: Mr. Paul T. Markland, Esq.

BEFORE MCCLELLAND, BRUBAKER & TASIKAS Appellate Military Judges

BRUBAKER, Judge:

This is the second time this case has come before us. As the case was being tried at a general court-martial, the complainant filed a petition with us seeking a writ of mandamus under Article 6b, Uniform Code of Military Justice (UCMJ). In re Y.B., 83 M.J. 501, 503 (C.G. Ct. Crim. App. 2022). We stayed the proceedings and ultimately granted the writ, holding that, contrary to the military judge’s ruling, certain evidence was inadmissible under Mil. R. Evid. 412. Id. at 508. The United States Court of Appeals for the Armed Forces (CAAF) granted Appellant’s writ-appeal petition, held that it had jurisdiction to review the petition, but declined to do so at that time without prejudice to Appellant’s right to raise the issues in the ordinary course of appellate review. Fink v. Y.B., 83 M.J. 222, 225 (C.A.A.F. 2023). United States v. James D. FINK, No. 1502 (C.G. Ct. Crim. App. 2025)

Subsequently, a general court-martial of members with enlisted representation convicted Appellant, contrary to his pleas, of one specification of sexual assault, in violation of Article 120, UCMJ. Appellant was sentenced to confinement for thirty days, reduction to E-1, and a dishonorable discharge. Judgment was entered accordingly.

Appellant now raises eleven issues:

(1) Can an interlocutory appeal under Article 6b(e)(1), UCMJ, be used to review a military judge’s downstream evidentiary rulings based on evidentiary rules beyond those listed in Article 6b(e)(4), UCMJ?

(2) Did this Court err in granting the interlocutory writ of mandamus?

(3) Were civilian law enforcement required to provide Appellant with Article 31(b) warnings where they were working in conjunction with military law enforcement?

(4) Were civilian law enforcement required to provide Appellant with Article 31(b) warnings because one of the interrogators was a person subject to the Code as a military retiree?

(5) Are the provisions of Mil. R. Evid. 317 triggered when military law enforcement participates in the interception of wire or oral communications along with civilian law enforcement?

(6) Is relief warranted where the mandatory Mil. R. Evid. 304(g) “weight of the evidence” instruction was omitted following the denial of the suppression motion?

(7) Is relief warranted where the military judge gave an erroneous prior inconsistent statement instruction and failed to give the correct instruction?

(8) Where the members circled “not guilty” to Charge I and its specification on the findings worksheet, then crossed it off and circled “guilty” instead, indicating either (1) they originally voted not guilty but then engaged in reconsideration without following the proper procedures or (2) an administrative mistake was made on the findings worksheet, did Mil. R. Evid. 606(b)’s 2013 amendment, allowing inquiry into whether “a mistake was made in entering the findings or sentence on the findings or sentence forms,” permit inquiry into whether the circling of “not guilty” resulted from a mistake as opposed to an initial vote to acquit?

(9) When two members who were enlisted at empanelment were promoted to warrant officer during the pendency of the trial, did the military judge err by improperly advising Appellant of his forum selection options and/or by excusing the two members over Defense objection?

2 United States v. James D. FINK, No. 1502 (C.G. Ct. Crim. App. 2025)

(10) Is the evidence legally and factually insufficient?

(11) Did trial counsel make improper argument that warrants relief?

We resolve issues 10 and 11 summarily. Regarding issue 10, we conclude that the evidence supporting Appellant’s conviction is legally and factually sufficient. See Article 66(d), UCMJ; United States v. Casillas, ___ M.J. ___, No. 24-0089, 2025 WL 2446502, at *5 (C.A.A.F. Aug. 20, 2025); United States v. Harvey, 85 M.J. 127, 130–31 (C.A.A.F. 2024). Regarding issue 11, we conclude that Appellant forfeited his objection to trial counsel’s argument by failing to object at trial and fails now to establish plain and prejudicial error. See United States v. Fletcher, 62 M.J. 175, 179 (C.A.A.F. 2005). We discuss the remaining issues, but we conclude there is no prejudicial error and affirm.

Background Appellant and then-Seaman (SN) Y.B. were both members of the same unit. One evening, Appellant’s roommate invited several members of the unit to a get-together at their home. As guests ate food and played video games, Appellant and SN Y.B. mostly socialized with each other; Appellant had a gaming computer in his bedroom, which interested her. Unlike most of the guests, both were of legal drinking age, and at one point, they left to obtain alcohol, returned, and resumed socializing while drinking alcohol. As many guests were leaving, Appellant asked her if she wanted to stay overnight. She agreed. As she waited on his bed for him to return so they could play on his computer, she fell asleep. She awoke to find herself naked from the waist down and him standing nearby, naked from the waist down. She immediately dressed and went home.

Hours later, she reported a sexual assault. The Coast Guard Investigative Service (CGIS) opened an investigation and notified the local police department, which was standard protocol for an off-base incident. The following day, a CGIS special agent and a detective from the Fairfax County Police Department (FCPD) interviewed SN Y.B. At the end of the interview, the detective asked her to participate in a controlled call with Appellant, in which she would ask him questions about the incident while the call was being recorded. She agreed, and the call occurred,

3 United States v. James D. FINK, No. 1502 (C.G. Ct. Crim. App. 2025)

during which Appellant admitted to digitally penetrating her vagina. A recording and transcript of the call were admitted at trial.

The next day, two FCPD detectives interviewed Appellant at his Coast Guard unit. They received assistance in setting up the interview from the CGIS special agent, but the agent did not attend the interview. The detectives informed Appellant he was not required to speak with them, but they did not provide any Miranda1 or Article 31(b), UCMJ, warnings. During the interview, Appellant admitted to digitally penetrating SN Y.B.’s vagina while she was asleep. Immediately after the interview, before leaving the unit, the detectives gave a copy of the interview recording to the CGIS special agent. The recording and a transcript of the interview were admitted at trial.

FCPD later informed CGIS that there would not be a local prosecution. FCPD and CGIS each prepared a report concerning its investigation.

Prior Interlocutory Decision Appellant raises two issues regarding our grant of the interlocutory writ of mandamus in In Re Y.B., 83 M.J. 501. First, he posits that it was improper for us to consider the military judge’s ruling under Article 6b, UCMJ, because it was based not on his initial pretrial ruling under Mil. R. Evid. 412, but on a later “downstream” evidentiary ruling that certain testimony was admissible. Appellant’s Br. at 72.

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Bluebook (online)
2025 WL 3293721, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-fink-uscgcoca-2025.