United States v. Marshall

31 M.J. 712, 1990 CMR LEXIS 1633, 1990 WL 142771
CourtU S Air Force Court of Military Review
DecidedAugust 28, 1990
DocketACM 27820
StatusPublished
Cited by3 cases

This text of 31 M.J. 712 (United States v. Marshall) is published on Counsel Stack Legal Research, covering U S Air Force 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. Marshall, 31 M.J. 712, 1990 CMR LEXIS 1633, 1990 WL 142771 (usafctmilrev 1990).

Opinions

DECISION

KASTL, Senior Judge:

This appeal centers on a rule of evidence — co-conspirator statements under Mil.R.Evid. 801(d)(2)(E). As the military judge explained at trial, the evidentiary contest grew out of “a classical case of admission of a statement of a co-conspirator in furtherance of a conspiracy and while a conspiracy is still ongoing.”

We find no error on the particular facts before us and affirm.

Statements of Co-Conspirators

A

The appellant, Staff Sergeant Marshall, was convicted in Panama of various drug-related offenses in violation of Articles 81 and 112a, UCMJ, 10 U.S.C. §§ 881, 912a. His sentence is a dishonorable discharge, confinement for 12 years, total forfeitures, and reduction to airman basic. His of[713]*713fenses were wrongful use, possession with intent to distribute, and importation of cocaine; and conspiracy to wrongfully import cocaine into the United States. It was this latter crime which led to the evidentiary clash before us today.

Sergeant Marshall made a motion at trial to suppress the out-of-court statements made by Airman Basic Dillard, one of the alleged co-conspirators. Dillard, a supposed kingpin in the scheme, was a prisoner in a nearby Army correction facility. There was no showing that he was unwilling to testify or that the Government had sought to immunize him. Instead of calling Dillard, the prosecution relied on the third alleged conspirator, Airman Basic Wentz. Wentz testified under grant of immunity as to everything that happened during the drug conspiracy, including statements made by Dillard. The defense objected to Wentz’s testimony on two principal grounds: (a) the Government’s evidence was too weak to invoke the “co-conspirator rule” of Mil.R.Evid. 801(d)(2)(E); and (b) Sergeant Marshall’s Sixth Amendment confrontation rights were violated since the Government was able to smuggle the statements of Dillard into the trial even though he was not shown to be unavailable.

Prior to ruling on the motion, the military judge considered the testimony of five witnesses, together with twelve exhibits (leave records, airplane tickets, and the like), which tended to show a conspiracy and its details. The judge denied the defense motion. Essentially, he made the following findings: (1) A clear-cut, ongoing drug conspiracy was in operation and the accused was part of it when the statements in question were made; (2) Wentz’s proffered testimony as to Dillard’s participation and conduct was not strictly hearsay anyway — rather, it was directly admissible under Rule 801(d)(2)(E); (3) No impermissible “bootstrapping” 1 occurred — there was evidence independent of the statements uttered by Dillard; and (4) Especially when meshing Wentz’s testimony with that of the other four witnesses and the various prosecution exhibits, the proffered evidence was admissible under Mil.R.Evid. 801(d)(2)(E).

B

Under the circumstances, we hold that the military judge’s ruling was correct.

The use of co-conspirator statements under the Rules of Evidence may have expanded dramatically in courts-martial as a result of the United States Supreme Court decision in Bourjaily v. United States, 483 U.S. 171, 107 S.Ct. 2775, 97 L.Ed.2d 144 (1987). The appellant makes a vigorous attack on the trial court’s refusal to suppress the statements of Dillard as a co-conspirator, mainly on the basis of the unreliable evidence thereby reaching the triers of fact through a pernicious “back door” mechanism. The star Government witness, complains the appellant, never had to confront him in court. Various older authorities are marshaled in support of his argument. The Government response to his contention is that Bourjaily appears to have resolved the question to the contrary.

In his article The Use of Co-Conspirator Statements Under the Rules of Evidence: A Revolutionary Change in Admissibility, 124 Mil.L.Rev. 163, 164 (Spring 1989), Major Frederick L. Borch III suggests that:

The United States Supreme Court decisions of United States v. Inadi, [475 U.S. 387, 106 S.Ct. 1121, 89 L.Ed.2d 390 (1986)] and Bourjaily v. United States, [483 U.S. 171, 107 S.Ct. 2775, 97 L.Ed.2d 144 (1987)] dramatically alter Rule of Evidence 801(d)(2)(E), which governs the admissibility of co-conspirator hearsay. First, Bourjaily abolishes an old common law rule that had been considered to be a part of Rule 801(d)(2)(E). This rule provided that statements of co-conspirators were admissible only if evidence independent of them proved the existence of the conspiracy and the accused’s membership in it. Second, Inadi and Bourjaily in concert end the need for co-conspirator hearsay proffered under Rule [714]*714801(d)(2)(E) to be analyzed in terms of the sixth amendment’s right to confrontation.

The author continues:

The Supreme Court’s abolition of these two significant requirements — both of which had acted as barriers to the admissibility of out-of-court statements of non-testifying co-conspirators — is nothing short of revolutionary. Inadi and Bourjaily have so altered the traditional requirements for admissibility under Rule 801(d)(2)(E) as to now permit nearly all statements which satisfy the literal language of Rule 801(d)(2)(E) to be received into evidence.

Id. at 163-164.2

Busy military practitioners working with this complicated area would do well to review the abovementioned Supreme Court guidance, together with the excellent analysis by Major Borch. Other informative material appears at Saltzburg, Schinasi & Schleuter, Military Rules of Evidence Manual 617-619 (2nd ed. 1986) and Saltzburg & Redden, Federal Rules of Evidence Manual 779-803 (4th ed. 1986). See also United States v. Silverman, 861 F.2d 571 (9th Cir.1988) and the cases gathered at Annot., 44 A.L.R.Fed. 627 (1979). A leading military case is United States v. Arnold, 25 M.J. 129, 133 (C.M.A.1987) in which the Court expresses a preference for the appearance of witnesses but finds a showing of unavailability “not required.” 3 See also United States v. Hubbard, 28 M.J. 27, 33 (C.M.A.1989) and United States v. Quick, 22 M.J. 722, 725-726 (A.C.M.R.1986).

The Bourjaily/Inadi approach was severely criticized by Major Borch in his recent article. He sees a real possibility of individuals being convicted for guilt by association rather than because of a criminal agreement. He fears that the new approach will elude the strictness required by the confrontation clause; admit unreliable statements; and generally do away with historic barriers which allowed only solid, trustworthy evidence to come before voting members. See Borch, supra at 186-194.

C

In this case, it must be emphasized that

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Bluebook (online)
31 M.J. 712, 1990 CMR LEXIS 1633, 1990 WL 142771, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-marshall-usafctmilrev-1990.