United States v. Lattin

CourtUnited States Air Force Court of Criminal Appeals
DecidedApril 20, 2022
Docket39859
StatusUnpublished

This text of United States v. Lattin (United States v. Lattin) is published on Counsel Stack Legal Research, covering United States Air Force 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. Lattin, (afcca 2022).

Opinion

U NITED S TATES AIR F ORCE C OURT OF C RIMINAL APPEALS ________________________

No. ACM 39859 ________________________

UNITED STATES Appellee v. Liam C. LATTIN First Lieutenant (O-2), U.S. Air Force, Appellant ________________________

Appeal from the United States Air Force Trial Judiciary Decided 20 April 2022 ________________________

Military Judge: Bryan D. Watson. Sentence: Sentence adjudged 12 December 2019 by GCM convened at Luke Air Force Base, Arizona. Sentence entered by military judge on 28 January 2020: Dismissal, confinement for 10 years, and forfeiture of all pay and allowances. For Appellant: Major Alexander A. Navarro, USAF; Bethany L. Payton- O’Brien, Esquire. For Appellee: Lieutenant Colonel Brian C. Mason, USAF; Lieutenant Colonel Matthew J. Neil, USAF; Lieutenant Colonel Dayle P. Percle, USAF; Major John P. Patera, USAF; Mary Ellen Payne, Esquire. Before POSCH, RICHARDSON, and CADOTTE, Appellate Military Judges. Judge RICHARDSON delivered the opinion of the court, in which Senior Judge POSCH joined. Judge CADOTTE filed a separate opinion, dis- senting in part and in the result. ________________________

This is an unpublished opinion and, as such, does not serve as precedent under AFCCA Rule of Practice and Procedure 30.4. ________________________ United States v. Lattin, No. ACM 39859

RICHARDSON, Judge: A general court-martial comprised of officer members convicted Appellant, contrary to his pleas, of one specification of sexual assault of KA in violation of Article 120, UCMJ, 10 U.S.C. § 920, Manual for Courts-Martial, United States (2016 ed.) (2016 MCM), and one specification each of sexual assault and abu- sive sexual contact of AW in violation of Article 120, UCMJ.1,2 Consistent with his pleas, Appellant was found not guilty of two other specifications charged in violation of Article 120, UCMJ.3 The court-martial sentenced Appellant to a dismissal, ten years in confinement, and forfeiture of all pay and allowances. The convening authority did not disturb the sentence adjudged. Appellant, through counsel, raises eight assignments of error, which we have reordered: (1) whether his convictions were factually and legally suffi- cient; (2) whether the search of his cell phone violated both the terms of the authorization and his Fourth Amendment4 right to particularity; (3) whether the military judge’s omission of the specific intent pled in Specification 5 (abu- sive sexual contact of AW) from the instructions violated his due process rights; (4) whether the Government violated his due process rights when it charged him with sexual assault by bodily harm and then tried and convicted him of sexual assault upon a person incapable of consenting; (5) whether the military judge’s admission of testimony relating to AW’s character amounted to plain error; (6) whether the military judge’s admission of “human lie detector” evi- dence created plain error; (7) whether the trial counsel’s argument vouching for a witness and encouraging members to compare the charged offenses was improper; and (8) whether the trial defense counsel’s failure to object to incom- plete instructions, improper character evidence, human lie detector testimony, and improper argument (issues (3), (5), (6), and (7)) amount to ineffective as- sistance of counsel.

1 Unless otherwise noted, all references in this opinion to the UCMJ, Rules for Courts-

Martial (R.C.M.), and Military Rules of Evidence are to the Manual for Courts-Martial, United States (2019 ed.). 2 Before arraignment, the Government withdrew and dismissed three other specifica-

tions charged in violation of Article 120, UCMJ. 3 The military judge instructed the members that the two specifications involving KA

were “alleged in the alternative,” and therefore they could not find Appellant guilty of both. Appellant was convicted of sexual assault of KA by penile penetration, and ac- quitted of sexual assault by digital penetration. Additionally, Appellant was acquitted of sexual assault of AW by penile penetration. 4 U.S. CONST. amend. IV.

2 United States v. Lattin, No. ACM 39859

Appellant personally raises three additional issues on appeal:5 (9) whether his sentence to confinement for ten years is inappropriately severe; (10) whether the military judge erred in giving a false exculpatory statement in- struction for a general denial of guilt; and (11) whether trial defense counsel were ineffective for not filing a post-trial motion after the convening authority neglected to take action in the case. In addition, the court considers the issue of timely appellate review. We have carefully considered issues (4), (9), and (10) and determine no discussion or relief is warranted. See United States v. Matias, 25 M.J. 356, 361 (C.M.A. 1987).

I. BACKGROUND Appellant was a fighter pilot, assigned to Luke Air Force Base (AFB), Ari- zona. He lived in nearby Glendale, Arizona, in an apartment close to an enter- tainment district during the charged time frames. A. KA Appellant and KA met in the fall of 2016 while they were enrolled in un- dergraduate pilot training (UPT). Afterwards, they kept in touch sporadically. Appellant contacted KA in August 2018 and invited her to a party he would be attending with other UPT classmates near her duty station in Albuquerque, New Mexico. At the party, KA and Appellant flirted and engaged in some sex- ual behavior. Appellant invited KA to visit him, and over the next several weeks they made arrangements for that visit. They communicated frequently via text on their phones. KA flew into Arizona on the evening of Friday, 7 September 2018, and planned to return on Sunday. The evening she arrived, KA stayed with Appel- lant at his apartment. KA and Appellant were kissing on his couch, and Ap- pellant tried to unbutton KA’s pants. KA said no, and Appellant stopped and asked why. KA said she “didn’t want to,” and Appellant went upstairs and KA slept on the couch. The next morning, Appellant was “more short with his re- sponse to anything that [KA] was saying, and more physically distan[t].” This behavior continued during the rest of her visit. On Saturday, KA and Appellant, along with several coworkers and friends of Appellant, went on a five-hour “river float.” KS6 was one of those friends. He took notice of KA and told Appellant he was interested in her, but was nervous to talk to her. Appellant responded with encouragement. KS spent about half of the time on the river float getting to know KA. Alcoholic beverages were

5 See United States v. Grostefon, 12 M.J. 431 (C.M.A. 1982).

6 KS was Appellant’s peer and fellow officer.

3 United States v. Lattin, No. ACM 39859

abundant on the float. KA became intoxicated and her behavior became more outgoing. During the river float, she and KS talked and kissed. After the river float, on the bus to the parking lot, KS kissed KA “because she was very in- sistent,” “really forcing herself on me, asking me to kiss her, make out with her.” On the ride from the parking lot back to Glendale, KS and KA again were sitting together, “cuddled.” KS was dropped off at his home first; Appellant and KA went to Appellant’s apartment. KS arranged with Appellant to come to his apartment later that day and ask KA on a date. KA testified that she got “super drunk” during the river float and it caused gaps in her memory of the rest of that day. She remembered kissing Appellant once, but that he avoided her during the river float. She remembered talking to KS during the river float, and then on the ride back entering her phone number in KS’s phone. Her next memory is in Appellant’s apartment, “being leaned over an ottoman and facing the kitchen . . .

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