United States v. Latour

75 M.J. 723, 2016 CCA LEXIS 400, 2016 WL 3853739
CourtNavy-Marine Corps Court of Criminal Appeals
DecidedJuly 12, 2016
DocketNMCCA 201600114
StatusPublished
Cited by1 cases

This text of 75 M.J. 723 (United States v. Latour) is published on Counsel Stack Legal Research, covering Navy-Marine Corps 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. Latour, 75 M.J. 723, 2016 CCA LEXIS 400, 2016 WL 3853739 (N.M. 2016).

Opinion

Chief Judge BRUBAKER and Senior Judge FISCHER concur.

PUBLISHED OPINION OF THE COURT

MARKS, Judge:

This case is before us as an interlocutory appeal by the Government, filed pursuant to Article 62, Uniform Code of Military Justice, 10 U.S.C. § 862, and Rule FOR Courts-Martial 908, Manual for Courts-Martial, United States (2012 ed.). The Government challenges a trial ruling “which excludes evidence that is substantial proof of a fact material in the proceeding.” Art, 62(a)(1)(B), UCMJ.

The appellant alleges the military judge (MJ) abused his discretion by excluding from evidence relevant portions of the appellee’s admissions pursuant to Military Rule of Evidenoe 304(c), Supplement to the Manual for Courts-Martial, United States (2012 ed.) 1 when:

(1) The appellee did not move to suppress the statements or object prior to entering his pleas;
(2) The appellee’s spontaneous text message admission to an alleged victim was made in an informal exchange and not pursuant to a law enforcement in- , terrogation; and
(3) An alleged .victim testified she awoke the morning after the incident naked from the waist down with the appellee leaving her room. 2

Background

A general court-martial comprised of members with enlisted representation was convened and assembled to try the appellee for four specifications of sexual assault in violation of Article 120, UCMJ. There are two alleged victims among the four specifications, and the suppressed evidence relates to two specifications involving one alleged victim, BNS. Specifically, the appellee is charged with penetrating BNS’s vulva with his penis and finger while she was incapable of consenting because of impairment by a drug, intoxicant, or other similar substance.

The appellee pled not guilty to the charge and specifications during a 16 December 2015 Article 39(a), UCMJ, session. At the time the appellee entered pleas, he had not objected to the admission of any confessions or admissions for lack of corroboration under Mil, R. Evid. 304(c).

On 3 March 2016, the Government filed a motion to pre-admit a transcript and video *726 recording of the appellee’s first interrogation with Naval Criminal Investigative Service (NCIS), During the interrogation, the appel-lee admitted to digitally penetrating BNS and having sexual intercourse.with her, but described the acts as consensual. BNS has no memory of any sexual activity with the appel-lee. The MJ noted the appellee’s objection to pre-admission of the video and transcript for lack of corroboration during a 7 March 2016 Article 39(a) session. Although he initially reserved his ruling until after both alleged victims testified, the MJ denied the motion to pre-admit just before opening statements.

During direct examination, trial defense counsel objected to BNS’s expected testimony about a text message from the appellee. An exchange of text messages between BNS and the appellee hours after the alleged sexual assault included the appellee’s admission that, “[w]e made whoopy lol.” 3 At the resulting Article 39(a) session, trial defense counsel argued the text message was an admission lacking corroboration or, alternatively, hearsay. The MJ sustained the objection for insufficient corroboration. After BNS finished testifying, the MJ also suppressed the appel-lee’s recorded and transcribed interrogation for lack of corroboration. The MJ later memorialized his rulings in written Findings of Fact and Conclusions of Law, Appellate Exhibit XLIV. These rulings led to the Government’s interlocutory appeal sub judice.

Discussion

We review an MJ’s decision to exclude evidence for an abuse of discretion. United States v. McCollum, 58 M.J. 323, 335 (C.A.A.F. 2003). We review findings of fact under the clearly-erroneous standard and conclusions of law de novo. United States v. Ayala, 43 M.J. 296, 298 (C.A.A.F. 1995).

A military judge abuses his discretion when his findings of fact are clearly erroneous, the court’s decision is influenced by an erroneous view of the law, or the military judge’s decision on the issue at hand is outside the range of choices reasonably arising from the applicable facts and the law.

United States v. Miller, 66 M.J. 306, 307 (C.A.A.F.2008) (citations omitted).

The ruling that prompted this interlocutory appeal is based on Mil. R. Evid. 304(e)(1), which provides:

An admission or a confession of the accused may be considered as evidence against the accused on the question of guilt or innocence only if independent evidence, either direct or circumstantial, has been admitted into evidence that corroborates the essential facts admitted to justify sufficiently an inference of their truth.

A confession is defined as “an acknowledgment of guilt,” and “ ‘admission’ means a self-incriminating statement falling short of an acknowledgment of guilt, even if it was intended by its maker to be exculpatory.” Mil. R. Evid. 304(a)(l)(B)-(C).

I. Timing of the Objections

The Government first argues that the ap-pellee waived his Mil. R. Evid. 304(c) objections to both admissions because he failed to object before entering pleas.

Mil. R. Evid. 304(f)(1) states:

Motions to suppress or objections under this rule, or Mil. R. Evid. 302 or 305, to any statement or derivative evidence that has been disclosed must be made by the defense prior to submission of a plea. In the absence of such motion or objection, the defense may not raise the issue at a later time except as permitted by the military judge for good cause shown. Failure to so move or object constitutes a waiver of the objection.

By its plain language, Mil. R. Evid. 304 requires an accused to challenge a confession or admission for lack of corroboration before entering pleas. Nothing in Mil. R. Evid. 304 suggests that “[mjotions to suppress or objections under this rule” do not include motions and objections under Mil. R. Evid. 304(e). But the rule also confers discretion on an MJ to consider such a motion or objection after entry of pleas if he or she finds “good cause shown.” Mil. R. Evid. 304(f)(1).

*727 The Government urges us to overturn the MJ’s suppression of the appellee’s admissions because the appellee’s objections were untimely and sustained without good cause. Although we agree that Mil. R. Evid. 304(f)(1) applies to objections based on lack of corroboration, we cannot say that the MJ abused his discretion in considering the objections anyway. “[Ajbsent clear evidence to the contrary,” we presume the MJ knew and followed the law. United States v. Erickson, 65 M.J. 221, 225 (C.A.A.F. 2007). The MJ was silent on the applicability of Mil. R. Evid. 304(f)(1) to objections based on lack of corroboration.

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Bluebook (online)
75 M.J. 723, 2016 CCA LEXIS 400, 2016 WL 3853739, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-latour-nmcca-2016.