United States v. Hightower

5 M.J. 711
CourtU.S. Army Court of Military Review
DecidedJune 22, 1978
DocketSPCM 12827
StatusPublished

This text of 5 M.J. 711 (United States v. Hightower) 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. Hightower, 5 M.J. 711 (usarmymilrev 1978).

Opinions

OPINION OF THE COURT

CARNE, Senior Judge:

Appellant, a U. S. Army recruiter, was convicted, contrary to his pleas, of three specifications of effecting unlawful enlistments, in violation of Article 84, Uniform Code of Military Justice (UCMJ), 10 U.S.C. § 884, and one specification of failure to obey the enlistment regulation, in violation of Article 92, UCMJ, 10 U.S.C. § 892. At his trial before a special court-martial, appellant received a sentence of a bad-conduct discharge and reduction to the lowest enlisted grade. The convening authority approved the sentence. Our review of appellant’s case is pursuant to Article 66, UCMJ.

Appellant was the junior member of a two-man recruiting station under the supervision of Sergeant First Class Ward. Staff Sergeant Riddle, with whom appellant was acquainted from prior association, was a member of a neighboring recruiting station. Appellant and Riddle apparently were in the practice of “feeding” applicants for enlistment processing into each other’s recruiting jurisdiction, a practice which, if the applicant is otherwise eligible for enlistment, is permissible. Each of the four specifications now before us concerns the unlawful enlistment of a different applicant. The threshold question in the instant case, therefore, is whether these particular applicants, who were being processed from one recruiting jurisdiction to another, were eligible for enlistment. If the applicants are determined to have been ineligible for enlistment, the ultimate question becomes whether appellant effected their enlistment knowing the applicants to be ineligible. Resolution of these questions requires that we set forth the facts relating to each enlistment.

John Corner took the Armed Forces Qualifications Test (AFQT) in Riddle’s jurisdiction, but did not achieve the requisite score to satisfy the mental requirement for enlistment. Corner was subsequently offered as an applicant by Riddle to appellant. The proper procedure to be followed in enlisting an applicant who has failed the AFQT (with one exception not here applicable) is to wait at least thirty days before retesting. A retest may be accomplished after thirty days but within six months only with the permission of the appropriate recruiting area commander.1 Retests after six months have elapsed may be authorized by the district recruiting commander.2 In the instant case, however, appellant had Corner retested within six months without approval from any higher authority, and subsequently effected his enlistment in the U. S. Army. This conduct formed the basis for Charge I, Specification 1, alleged as a violation of Article 84, UCMJ.

Diana Pack took the Armed Forces Women’s Selection Test (AFWST) in appellant’s jurisdiction, but did not achieve a qualifying score. A scheme was designed whereby Karen Miller, a friend of Pack’s who had previously passed the mental examination, agreed to take the test in place of Pack during a retest in Riddle’s jurisdiction. There is some testimony to the effect that appellant initiated this scheme. It is also clear from the record that appellant aided Pack with full knowledge that Miller would sit for the retest in Riddle’s jurisdiction, and with Riddle’s knowledge of, and participation in, the scheme. Miller did in fact sit for the retest, and Pack was subsequently enlisted in the U. S. Army on the basis of Miller’s score. Charge I, Specification 3, was bottomed on these facts.

Alvin Harvest failed an AFQT administered in appellant’s jurisdiction. Harvest was attempting to enlist under the “buddy plan” with a friend who passed the AFQT at the same time Harvest failed. SFC Ward, appellant’s supervisor, was the recruiter of credit for Harvest’s friend. In an effort to ensure the friend’s enlistment, Ward requested appellant’s assistance in [714]*714having Harvest retested in Riddle’s jurisdiction. As a result of appellant’s efforts, Riddle agreed to the retest for Harvest. Appellant, who knew of Harvest’s failure, nevertheless delivered Harvest to Riddle for the purpose of a retest within six months and without prior authorization. Harvest was subsequently enlisted in the U. S. Army on the basis of that retest. Charge I, Specification 4, resulted from these misdeeds.

Allen Hatmaker applied for enlistment in appellant’s jurisdiction, but Hatmaker could not provide the required verification of age. After allegedly exhausting the proper channels of inquiry recommended by the applicable regulation, a form entitled “Date of Birth Verification Statement” was prepared by forging the name “B. A. Matthews” as a minister in a section of the form allowing verification by a religious institution. Whether appellant forged the signature himself, as Hatmaker alleged, or Ward forged the signature in appellant’s presence, as appellant testified, need not now detain us. It is clear from appellant’s own testimony that he knew that the document was false, that the use of the document was wrong, and that he personally advised Hat-maker to cover-up the forgery if questioned. Nevertheless, the appellant enlisted Hatmaker in the U. S. Army. From these facts Charge II, the Article 92, UCMJ, violation, was drafted.

I

Appellant first alleges that Specifications 1, 3 and 4 of Charge I do not state an offense, because failure to follow the proper retest procedure does not render the applicant ineligible within the meaning of Article 84, UCMJ, once that applicant has in fact achieved a qualifying score on the AFQT or AFWSTI *3 retest prior to enlistment. Our reading of the governing regulation and Article 84 leaves us unpersuaded by appellant’s argument.

Article 84 reads in pertinent part as follows:

Any person subject to this chapter who effects an enlistment . . . in . the armed forces of any person who is known to him to be ineligible for that enlistment . . . because it is prohibited by law, regulation, or order shall be punished as a court-martial may direct.

The regulation in effect at the time of appellant’s alleged offenses was Army Regulation 601-210, as amended by changes through 1 December 1975. We view the term “enlistment,” as used in the regulation and in Article 84, to include the necessary processing phase prior to the actual swearing of the applicant as an enlistee.4 Consequently, any irregularity in the administration of the examination necessary to assure the requisite mental qualification of an applicant, if that irregularity affects the eligibility of the applicant, is within the purview of Article 84.

The basic eligibility table in the enlistment regulation5 sets forth the trainability requirements including, inter alia, receiving the requisite qualifying score on the AFQT or AFWST.6 The eligibility table refers, in that same section, to Chapter 4 of the regulation for the proper administration of the AFQT and AFWST tests and retests. Chapter 4 states that the purpose of applicant processing is to ensure that all applicants accepted for enlistment meet the required qualifications and, to that end, one element of the processing phase is to pre[715]*715vent fraudulent or erroneous enlistments.7

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Bluebook (online)
5 M.J. 711, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-hightower-usarmymilrev-1978.