United States v. Harpole

CourtU S Coast Guard Court of Criminal Appeals
DecidedNovember 10, 2016
Docket1420
StatusUnpublished

This text of United States v. Harpole (United States v. Harpole) 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. Harpole, (uscgcoca 2016).

Opinion

UNITED STATES COAST GUARD COURT OF CRIMINAL APPEALS

UNITED STATES

v.

Koda M. HARPOLE Seaman (E-3), U.S. Coast Guard

CGCMG 0322 Docket No. 1420

10 November 2016

General Court-Martial convened by Commander, Coast Guard Pacific Area. Tried at Seattle, Washington and Alameda, California, 9 October, 10 November, and 1-5 December 2014.

Military Judge: CAPT Christine N. Cutter, USCG Trial Counsel: LT Geralyn M. Van de Krol, USCG Assistant Trial Counsel: LT Joel C. Coito, USCG Defense Counsel: LT Tereza Z. Ohley, USCGR Assistant Defense Counsel: LT Lindsay Geiselman, JAGC, USN Civilian Appellate Defense Counsel: Mr. James Trieschmann, Esq. Military Appellate Defense Counsel: LT Philip A. Jones, USCGR LT Jason W. Roberts, USCGR Appellate Government Counsel: LT Lars T. Okmark, USCGR

BEFORE MCCLELLAND, SPOLIDORO & JUDGE Appellate Military Judges

MCCLELLAND, Chief Judge:

Appellant was tried by general court-martial composed of members, including enlisted members. Contrary to his pleas, Appellant was found guilty of one specification of false official statements, in violation of Article 107, Uniform Code of Military Justice (UCMJ); two specifications of sexual assault, in violation of Article 120, UCMJ;1 and one specification of housebreaking, in violation of Article 130, UCMJ. The military judge sentenced Appellant to

1 Appellant was convicted of two specifications of sexual assault for the same incident, which were both prosecuted in consideration of contingencies of proof. One of the specifications was dismissed after findings as an unreasonable multiplication of charges. The dismissal was conditional, hence we consider both specifications. United States v. Koda M. HARPOLE, No. 1420 (C.G.Ct.Crim.App. 2016)

confinement for seven years, reduction to E-1, and a dishonorable discharge. The Convening Authority approved the sentence.

Before this Court, Appellant has assigned the following errors:

I. The evidence is legally and factually insufficient to support a conviction.

II. Article 120(b)(3), UCMJ, is unconstitutionally vague because the level of impairment that renders a person incapable of consenting is undefined.

III. The military judge erred by refusing to instruct the members as requested on the definition of “incapable”.

IV. The military judge abused her discretion when she allowed a victim advocate to testify as to Appellant’s privileged communications, in violation of M.R.E. 514.

V. The trial defense counsel were ineffective by failing to suppress SN Harpole’s unwarned admissions.

VI. The convening authority selectively ordered prosecution of Appellant in violation of equal protection.

VII. The promulgating order indicates Appellant was convicted under Charge II, Specification 1, but does not reflect the military judge’s conditional dismissal of that specification.

VIII. The military judge plainly erred when he instructed members they must find Appellant guilty.2

IX. Appellant’s due process rights were violated when the Court failed to render him timely appellate review.

In an appendix to the Assignments of Error and Brief (Appellant’s Brief), Appellant personally asserts seven issues:

A-I. Victim advocate procedures not properly followed.

A-II. Coast Guard SAPR policies not properly followed.

A-III. Coast Guard Investigative Service policy not properly followed.

A-IV. 10 U.S.C. §1044e not properly followed with procedure.

2 Appellant’s motion for leave to file supplemental assignments of error was granted on 13 October 2016, adding this and the next issue.

2 United States v. Koda M. HARPOLE, No. 1420 (C.G.Ct.Crim.App. 2016)

A-V. The way I was treated following my report of sexual assault.

A-VI. The way I was re-victimized numerous times throughout the initial report, court-martial, and ending up in a Naval brig.

A-VII. Miscellaneous issues.

The sexual assault and housebreaking specifications of which Appellant was convicted arose from an incident aboard USCGC POLAR STAR (WAGB-10) involving Appellant and a female petty officer who became the complainant, GR. According to the evidence at trial, Appellant sought assistance from a Victim Advocate on the ship three days after the incident. (R. at lines 15395-99.) He reported to the Victim Advocate that he had visited GR’s berthing area in the middle of the night after an evening of drinking, that he didn’t remember what happened, but he had been sexually abused in the past and knew what it felt like and that’s why he was talking to the Victim Advocate. (R. at lines 15443-58, 15472-79, 15506-08.) The appendix to Appellant’s Brief essentially sets forth Appellant’s complaints about the way he was treated following this disclosure and how his treatment fell short of the requirements of law and policy concerning persons who report being the victim of an alleged sex-related offense.

Appellant’s complaints in the appendix fall into three categories. Some of them are part and parcel of Assignments of Error I, IV and VI. Issue A-VII, “Miscellaneous issues,” raises some issues that were addressed at the court-martial; we see no error in the resolution of those issues at trial. The remainder of the issues, including but not limited to those relating to the Coast Guard Investigative Service (CGIS) and his experience in the brig where he was confined after trial pursuant to his sentence, we view as not relevant to the review this Court is tasked with carrying out under Article 66.

As to Assignment I, we conclude that the evidence is legally sufficient, and we are convinced beyond a reasonable doubt of Appellant’s guilt. We discuss the other assignments, direct correction of the promulgating order, and affirm the findings and sentence.

3 United States v. Koda M. HARPOLE, No. 1420 (C.G.Ct.Crim.App. 2016)

Constitutional challenge to Article 120(b)(3) Specification 1 of Charge II alleges that Appellant committed a sexual act upon GR when she “was incapable of consenting to the sexual act due to impairment by an intoxicant.” This allegation uses the language of Article 120(b)(3), UCMJ. Appellant contends that Article 120(b)(3) is unconstitutionally vague because it “does not define what level of impairment renders a person incapable of consenting.” (Appellant’s Brief at 12.) He adds, more cogently, “The statute provides no guidance in determining who is ‘incapable’ of consenting.” (Id. at 14.)

We reject Appellant’s contention. The problem is not that the statute fails to define who is incapable of consenting. A person of ordinary intelligence can understand what is prohibited: sexual conduct with a person who lacks the ability to consent. United States v. Solis, __ M.J. __ (N.M.Ct.Crim.App. 11 August 2016). “Incapable of consenting” means lacking the cognitive ability to appreciate the sexual conduct in question or the physical or mental ability to make or communicate a decision about whether they agree to the conduct. Id. (citing United States v. Pease, 75 M.J. 180 (C.A.A.F. 2016)).3 What is difficult, given a person under the influence of an intoxicant, is determining whether or not that person is in fact capable of consenting. This is not a defect in the statute but rather a reality of life.

Requested instruction on “incapable” Appellant complains that the military judge refused to give a defense-requested instruction on the definition of “incapable.” The requested instruction would pertain to Specification 1 of Charge II, alleging that the alleged victim was incapable of consenting to the sexual act due to impairment by an intoxicant.

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United States v. Harpole, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-harpole-uscgcoca-2016.