United States v. Hamilton

CourtU S Coast Guard Court of Criminal Appeals
DecidedApril 12, 2017
Docket1432
StatusUnpublished

This text of United States v. Hamilton (United States v. Hamilton) 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. Hamilton, (uscgcoca 2017).

Opinion

UNITED STATES COAST GUARD COURT OF CRIMINAL APPEALS

UNITED STATES

v.

James R. HAMILTON Senior Chief Operations Specialist (E-8), U.S. Coast Guard

CGCMS 24942 Docket No. 1432

12 April 2017

Special Court-Martial convened by Commander, Coast Guard Atlantic Area. Tried at Norfolk, Virginia, on 07 August 2014, 24-25 February 2015, and 30 April 2015.

Military Judge: CAPT Charles Purnell, JAGC, USN Trial Counsel: LT Jeremy A. Weiss, USCG Assistant Trial Counsel: CDR Martha A. Rodriguez, USCG Civilian Defense Counsel: Mr. Greg D. McCormack, Esq. Assistant Defense Counsel: LT Latham T. Hudson, JAGC, USN Appellate Defense Counsel: LT Philip A. Jones, USCGR LCDR Michael J. Meyer, USCGR Appellate Government Counsel: LT Sharyl L. Pels, USCGR LT Tereza Z. Ohley, USCGR

BEFORE MCCLELLAND, BRUCE & SPOLIDORO Appellate Military Judges

BRUCE, Judge:

Appellant was tried by special court-martial, military judge alone. Pursuant to his pleas of guilty, entered in accordance with a pretrial agreement, Appellant was convicted of two specifications of failure to obey a lawful general regulation, in violation of Article 92, Uniform Code of Military Justice (UCMJ); and one specification of assault and four specifications of assault consummated by a battery, in violation of Article 128, UCMJ. The military judge sentenced Appellant to confinement for eighty days, reduction to E-1, and a bad-conduct discharge. The Convening Authority approved the sentence, but suspended reduction below the grade of E-5, in accordance with the pretrial agreement. United States v. James R. HAMILTON, No. 1432 (C.G.Ct.Crim.App. 2017)

Before this Court, Appellant has assigned the following errors:

I. The trial defense counsel was ineffective in that he failed to warn Appellant that pleading guilty to assaults consummated by battery by rubbing a shipmate’s genitals and forcing another shipmate’s hand inside his pants carried a significant risk of sex offender registration in one or more jurisdictions.

II. Appellant’s pleas to specifications 1 and 3 of charge IV were improvident because he believed his pretrial agreement guaranteed he would never have to register as a sex offender, whereas this is not the case as to those specifications.

We discuss both issues and affirm.

Appellant’s claim of a risk of sex-offender registration is speculative We granted a motion to attach Appellant’s affidavit, in which he avers that his trial defense counsel “told me that the pretrial agreement he negotiated ensured I would never have to register as a sex offender, which was also my understanding of the language in the agreement. I now understand the language in Specifications 1 and 3 of Charge IV creates a risk of sex- offender registration in some states because it alleges I touched sexual body parts without consent.” (Appendix A to Assignments of Error and Brief on behalf of Appellant.)

We ordered an affidavit from trial defense counsel responding to Appellant’s allegations. We received affidavits of both Appellant’s trial defense counsel and his assistant defense counsel. These affidavits do not directly contradict Appellant’s averment, but they provide details of counsel’s advice suggesting that if counsel made the statement Appellant says he made, it may have been limited to the State of Virginia. We need not resolve the question of exactly what advice counsel gave Appellant, because we find that Appellant has failed to show that he faces any well-founded risk of having to register as a sex offender. Appellant’s claim of a risk of sex-offender registration is based on nothing but speculation that California might interpret its law in a way that is at odds with the plain language of the law.

He asserts that “under California law, a person commits a sexual battery when he ‘touches an intimate part of another person while that person is unlawfully restrained by the

2 United States v. James R. HAMILTON, No. 1432 (C.G.Ct.Crim.App. 2017)

accused or an accomplice, and if the touching is against the will of the person touched and is for the purpose of sexual arousal, sexual gratification, or sexual abuse’ or when, for the purpose of sexual arousal, sexual gratification, or sexual abuse, he ‘causes another, against that person’s will while that person is unlawfully restrained either by the accused or an accomplice . . . to masturbate or touch an intimate part of either of those persons or a third person.’ Cal. Penal Code § 243.4.” (Assignments of Error and Brief on behalf of Appellant at 6-7.) He further asserts that a person who commits sexual battery must register as a sex offender in California.

As discussed above, Appellant was convicted of failing to obey a general regulation on two occasions by wrongfully engaging in sexually intimate behavior with another crewmember aboard the USCGC NORTHLAND. Additionally, he was convicted of committing an assault and four assaults consummated by batteries. In pleading guilty to the orders offenses, Appellant never admitted that the sexually intimate behavior was against the will of the other crewmember or that the crewmember was restrained in any way. The assault offense did not require proof of a battery. None of the offenses Appellant pleaded guilty to, including the four offenses of assault consummated by a battery, required proof that any touching involved was for the purpose of sexual arousal, sexual gratification, or sexual abuse. It may be true, as Appellant states, that he was convicted of touching the sexual parts of his victims without consent. To be a sexual battery under California law, however, the touching would also have to have been for the purpose of sexual arousal, sexual gratification, or sexual abuse. In this case, Appellant did not admit or stipulate to such a purpose, the military judge did not find such a purpose proved, and the offenses of which Appellant was convicted did not require proof of such a purpose.

Appellant does not assert that he has been required to register as a sex offender. Additionally, he has failed to show that his convictions for specifications 1 and 3 of Charge IV, or any of the offenses of which he was convicted, would subject him to registration as a sex offender. Since we are not persuaded that the premise for Appellant’s assignments of error, that he faces a risk of sex-offender registration, is well founded, we reject his assignments of error.

3 United States v. James R. HAMILTON, No. 1432 (C.G.Ct.Crim.App. 2017)

Ineffective assistance Appellant asserts that trial defense counsel affirmatively told Appellant that he would never have to register as a sex offender, and claims that this was inaccurate where specifications to which he pleaded guilty alleged assault consummated by a battery by touching one shipmate’s intimate body parts and forcing another shipmate to place her hands in his pants.

The test for resolving an issue of ineffective assistance of counsel was established by the Supreme Court in Strickland v. Washington, 466 U.S. 668 (1984), and was incorporated into military law by United States v. Scott, 24 M.J. 186 (C.M.A. 1987). See also United States v. Molina, 68 M.J. 532 (C.G.Ct.Crim.App. 2009). First, the defendant must show that counsel’s performance was deficient. This requires showing that counsel made errors so serious that counsel was not functioning as the “counsel” guaranteed the defendant by the Sixth Amendment. Second, the defendant must show that the deficient performance prejudiced the defense. This requires showing that counsel’s errors were so serious as to deprive the defendant of a fair trial, a trial whose result is reliable.

Strickland, 466 U.S. at 687.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
United States v. Perron
58 M.J. 78 (Court of Appeals for the Armed Forces, 2003)
United States v. Ginn
47 M.J. 236 (Court of Appeals for the Armed Forces, 1997)
United States v. Scott
24 M.J. 186 (United States Court of Military Appeals, 1987)
United States v. Olson
25 M.J. 293 (United States Court of Military Appeals, 1987)
United States v. Molina
68 M.J. 532 (U S Coast Guard Court of Criminal Appeals, 2009)

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