United States v. Littles

35 M.J. 644, 1992 CMR LEXIS 602, 1992 WL 181042
CourtU.S. Navy-Marine Corps Court of Military Review
DecidedJune 30, 1992
DocketNMCM 89 3620C
StatusPublished
Cited by3 cases

This text of 35 M.J. 644 (United States v. Littles) 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. Littles, 35 M.J. 644, 1992 CMR LEXIS 602, 1992 WL 181042 (usnmcmilrev 1992).

Opinion

LAWRENCE, Judge:

Appellant was tried by general court-martial, military judge alone, and contrary to his pleas was convicted of violating Articles 108, 121, and 134, Uniform Code of Military Justice (UCMJ), 10 U.S.C. §§ 908, 921, and 934. He was sentenced to a dishonorable discharge, confinement for 12 years, total forfeiture of all pay and allowances, and reduction to pay grade E-l. The convening authority disapproved the findings of guilty of two specifications of larceny and; upon reassessment, approved the sentence. The Naval Clemency and Parole Board subsequently directed that confinement in excess of 8 years be remitted.

After examining the record and the briefs of the parties concerning three assignments of error,1 we requested that counsel brief three additional issues.2 In an unpublished decision, we concluded that [646]*646the finding of guilty of Specification 1 of Charge II must be set aside and dismissed because the offense of which appellant was convicted by exceptions and substitutions was not a lesser included offense of the offense charged. Additionally, we found that prosecution sentencing evidence concerning appellant’s father’s prior criminal history was erroneously admitted and constituted prejudicial error. The sentence was set aside and the case was returned to the Judge Advocate General for a rehearing on sentence. Thereafter, the Government requested reconsideration of our decision regarding Specification 1 of Charge II and, following our affirmance of that conviction, reassessment of sentence by us. We granted the request to reconsider our prior decision.

The Article 108 Conviction as a Lesser Included Offense

Specification 1 of Charge II alleged a violation of Article 134 by selling an M16-A2 firearm “knowing or having reasonable cause to believe that the M16-A2 firearm was stolen, in violation of 18 U.S. Code Section 922.”3 After a contested trial, the military judge found appellant guilty by excepting the words quoted above and substituting the words “of some value” and “military property of the United States.” He found appellant not guilty of violating Article 134 but guilty of violating Article 108 by unlawfully selling military property, a stolen M16-A2 firearm. The specification as excepted and substituted thus reads:

In that [appellant] ... did, ... unlawfully sell a stolen M16-A2 firearm, of some value, military property of the United States.4

The issue before us is whether this Article 108 offense is a lesser included offense of the Article 134 offense by violating 18 U.S.C. § 922. We hold that it is not.

The Federal Rules of Criminal Procedure were promulgated in 1944. Since that date, Federal Rule of Criminal Procedure 31(c) [hereinafter Rule 31(c) ] has provided that “[t]he defendant may be found guilty of an offense necessarily included in the offense charged____” Indeed, Rule 31(c) was no more than a codification of preexisting law regarding conviction of a lesser included offense. Keeble v. United States, 412 U.S. 205, 208 n. 6, 93 S.Ct. 1993, 1995 n. 6., 36 L.Ed.2d 844, 847 n. 6 (1973). Article 79, UCMJ, 10 U.S.C. § 879, became law in 1951 and, mirroring the language of Rule 31(c), provides that “an accused may be found guilty of an offense necessarily included in the offense charged.” The legislative history of Article 79 makes clear that “the language of the [Article] is derived from the Federal Rules of Criminal Procedure.” A Bill to Unify, Consolidate, Revise, and Codify the Articles of War, the Articles for the Government of the Navy, and the Disciplinary Laws of the Coast Guard, and to Enact and Establish a Uniform Code of Military Justice, Hearings on H.R. 2498 Before a Subcomm. of the Comm, on Armed Services, 81st Cong., 1st Sess. 1224 (1949).

As initially drafted, the Manual for Courts-Martial, United States (MCM), 1951, adopted a strict elements test for determining lesser included offenses and provided that “[a]n offense is not included within an offense charged if it requires proof of any element not required in proving the offense charged or if it involves acts of which the accused was not apprised upon his arraignment.” MCM, 1951, 11158. This language was entirely consistent with the “elements approach” to determining lesser included [647]*647offenses in the federal courts, an approach that “was settled doctrine at the time of [Rule 31(c)’s] promulgation and for more than two decades thereafter.” Schmuck v. United States, 489 U.S. 705, 720, 109 S.Ct. 1443, 1452, 103 L.Ed.2d 734, 748 (1989).

The elements approach did not remain settled doctrine in military law, however. Citing Stevenson v. United States, 162 U.S. 313, 16 S.Ct. 839, 40 L.Ed. 980 (1896), and other federal cases, the Court of Military Appeals held that “whether a lesser degree of homicide is necessarily included within that charged, depends almost exclusively on the facts stated and proved in support of the offense alleged. ” United States v. Davis, 2 C.M.A. 505, 508, 10 C.M.R. 3, 6 (1953). In United States v. Duggan, 4 C.M.A. 396, 15 C.M.R. 396 (1954), in finding that riot may be a lesser included offense of mutiny, the Court stated:

[W]e must look to the allegations of the specification, and proof in support thereof, in each case to determine whether a lesser included offense is in issue. While the standards we have adopted in considering whether one offense is included in another may be more generous than those prescribed by other courts, in an unbroken line of decisions we have made the test turn on both the charge and the evidence. When both offenses are substantially the same kind so that accused is fairly apprised of the charges he must meet and the specification alleges fairly, and the proof raises reasonably, all elements of both crimes, we have held they stand in the relationship of greater and lesser offenses.

4 C.M.A. at 399-400, 15 C.M.R. at 399-400. Subsequent cases followed this principle, and by the mid-1960’s the Duggan approach had become the “basic test” for determining whether or not an offense is included in a charged offense. United States v. Thacker, 16 C.M.A. 408, 37 C.M.R. 28, 30 (1966).

This broad approach for determining lesser included offenses was reiterated by the Court of Military Appeals in United States v. Baker, 14 M.J. 361 (C.M.A.1983).

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35 M.J. 644, 1992 CMR LEXIS 602, 1992 WL 181042, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-littles-usnmcmilrev-1992.