United States v. James

12 M.J. 944, 1982 CMR LEXIS 1060
CourtU.S. Navy-Marine Corps Court of Military Review
DecidedFebruary 26, 1982
DocketNMCM 81 2719
StatusPublished

This text of 12 M.J. 944 (United States v. James) is published on Counsel Stack Legal Research, covering U.S. Navy-Marine Corps 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. James, 12 M.J. 944, 1982 CMR LEXIS 1060 (usnmcmilrev 1982).

Opinion

MALONE, Judge:

Contrary to his pleas, appellant was convicted at special court-martial proceedings convened by the Commanding Officer, Second Battalion, Eighth Marines, of the offense of attempted damage to an automobile belonging to one Second Lieutenant W by pouring sugar into the vehicle’s gas tank, in violation of Article 80, Uniform Code of Military Justice (UCMJ) 10 U.S.C. § 880. He was acquitted of an unrelated offense when the fruits of a search of both his person and his wall locker conducted by Second Lieutenant W were suppressed at trial upon the motion of the trial defense counsel. Appellant was sentenced' on 19 September 1980 to a bad-conduct discharge, confinement at hard labor for three months, and forfeitures of $150.00 per month for six months. Initial action on review was taken by the Commanding General, Second Marine Division, located at Camp Lejeune, North Carolina, as an officer exercising general court-martial jurisdiction, pursuant to a request of the convening authority dated 20 January 1981. The request cited both paragraph 84c, Manual for Courts-Martial, 1969 (Rev.) and United States v. Walker, 7 M.J. 976 (N.C.M.R.1979) as authority.

Appellate defense counsel assigns two errors, the second of which summarily challenges the sufficiency of the evidence proving appellant’s guilt in the absence of any evidence regarding the capability of sugar introduced into an automobile’s gas tank to cause damage. Suffice it to say that the unrebutted evidence of appellant’s own intention and belief that by his actions he had inflicted damage to the vehicle in question provided the requisite proof of his guilt beyond a reasonable doubt. Of greater moment is appellant’s attack of the procedure whereby the convening authority herein relinquished his review responsibilities to the supervisory authority, in accordance with paragraph 84c, MCM.

That paragraph provides for review and action to be exercised in accordance with Article 60, UCMJ, 10 U.S.C. § 860, by any general court-martial authority when “it is impracticable for the person who convened the court ... to take initial action upon a record of trial . . . . ” It further provides that the convening authority should forward the record, ordinarily through the chain of command, to the general court-martial authority by letter of transmittal with a statement of the reasons for the failure to act on the record.

Appellant now cites as error the failure of the general court-martial authority to append that letter of transmittal to the record of trial when, in accordance with Article 65(b), UCMJ, 10 U.S.C. § 865(b), the record was forwarded to the Judge Advocate General of the Navy for review by this Court. Citing paragraph 82b, MCM, as the [946]*946authority for this requirement, appellant reasons that without the attachment of the letter this Court and other review authorities cannot properly determine the impracticability of the convening authority taking his action on the record. For two diverse but mutually supporting reasons, appellant’s argument fails to convince this Court, that prejudicial error has been committed requiring our remand of this record to the convening authority for his action.

Neither paragraph 82b nor paragraph 84c, MCM, requires attachment of the transmittal letter to the record. The former delineates the contents which shall comprise each record and the several and diverse matters and documents required to be a part of or appended to the record of the proceedings. The convening authority’s request to a general court-martial authority that he take initial action on the record is not one of these matters or documents discussed requiring appendage. Regarding the letter of transmittal, the latter paragraph merely suggests “[f]or purposes of regularity, the record should be forwarded by a letter of transmittal .. . . ” Thus, there is no requirement that the letter itself be appended to the record nor will such a requirement now be extrapolated by this Court from the Manual so long as there is no duplication of those conditions which proved fatal to the initial action taken in United States v. Walker, supra.

In Walker, the record was totally devoid of evidence of a request by the convening authority that the supervisory authority take the initial action due to the convening authority’s deployment. For that reason and the prejudice resulting from the supervisory authority’s usurpation of the convening authority’s review prerogative, thereby delimiting the clemency considerations flowing from the recommendation of the accused’s company commander that the accused be returned to duty and by the military judge to the convening authority that the punitive discharge be suspended, this Court set aside the action. Such a result is not required here in the face of ample evidence of compliance with the Manual provisions.

In this instance, the staff judge advocate, in his review, specifically refers the supervisory authority to the convening authority’s letter request. Going beyond a mere citation to the letter, the staff judge advocate included, as well, a summarization of the paragraph 84c provisions so as to apprise the supervisory authority of his authority to take the initial action in place of his subordinate commander under the circumstances of this case. It was further noted that the convening authority was still deployed at the time of the review with his unit to the Mediterranean. Additionally, the action itself stated it was being taken “[i]n accordance with paragraph 84c, MCM, 1969 (Rev.) . .. and at the Convening Authority’s request.” (SJA’s Review at 1).

After this issue was raised for the first time on appeal to this Court by appellate defense counsel, a copy of the letter of transmittal was obtained and, upon motion of appellate Government counsel, filed with the record. Certainly, had the document been appended to the record from the outset, the review before this Court would have been foreshortened. Indeed, it may well have obviated the entire issue, as we believe it does. Nevertheless, appellant’s argument that the letter must be appended to the record is subsumed by his argument that convening authority has failed to demonstrate why it was impractible for him to exercise his Article 60, UCMJ, review and action responsibilities. We therefore deem it prudent to address this latter argument.

It is appellant’s belief that the convening authority, by allegedly failing to demonstrate the impracticability of his taking the initial action in this case, thereby has deprived this Court of its ability to properly determine whether it was impracticable indeed. Although unstated by appellate defense counsel, this argument impliedly flows from the faulty premise that Article 60, UCMJ, mandates the Commanding Officer, Second Battalion, Eighth Marines, to take that initial action.

The Manual for Courts-Martial has delineated, of course, other circumstances [947]*947besides impracticability when someone may take initial action on a court-martial proceeding other than the person who normally would.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Walker
7 M.J. 976 (U.S. Navy-Marine Corps Court of Military Review, 1979)

Cite This Page — Counsel Stack

Bluebook (online)
12 M.J. 944, 1982 CMR LEXIS 1060, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-james-usnmcmilrev-1982.