United States v. Meek

40 M.J. 675, 1994 CMR LEXIS 411, 1994 WL 407240
CourtU.S. Navy-Marine Corps Court of Military Review
DecidedJuly 21, 1994
DocketNMCM 91 02664
StatusPublished
Cited by1 cases

This text of 40 M.J. 675 (United States v. Meek) 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. Meek, 40 M.J. 675, 1994 CMR LEXIS 411, 1994 WL 407240 (usnmcmilrev 1994).

Opinions

LARSON, Chief Judge:

Pursuant to his pleas, the appellant was convicted at special court-martial, military judge sitting alone, of unauthorized use of a government vehicle and multiple larcenies, in violation of Articles 92 and 121, respectively, Uniform Code of Military Justice (UCMJ), 10 U.S.C. §§ 892, 921. On appeal, in a summary assignment of error, he claims that the military judge erred by failing to dismiss the charges against him because of misconduct by the original trial counsel.1 Although we find instances of over-reaching and inappropriate behavior by the trial counsel (TC), as well as certain improprieties by the originally detailed defense counsel (DC), we hold that the appellant suffered no prejudice as a result.

The events in question unfolded at the Naval Legal Service Office Detachment, Zings Bay, Georgia, where witnesses had gathered for trial. The civilian defense counsel (CDC) was interviewing the appellant and his wife when the DC entered the office and profanely declared that the CDC was ineffective, had not talked to the witnesses, and that he [DC] would “have no part of it.”2 The DC was quickly followed into the office by the TC, who, in agreeing with the DC and stating to the appellant that the CDC was “misrepresenting” him, rudely ordered the appellant’s wife out of the office, and engaged the appellant in an unseemly verbal dispute. Record at 203. During the tumultuous pretrial preparation period, the TC had also told most of the defense witnesses, who were gathered to be interviewed by the defense, that the appellant was “trying to worm out of the court-martial,” or words to that effect. Furthermore, in an awkward arrangement, the TC forbade the CDC from using the appellant or his wife to summon the witnesses from the waiting area without her assistance or the assistance of a chief petty officer or secretary assigned to the Detachment. In addition, the TC provided legal counsel to one defense witness (F)— who had been punished under Article 15, UCMJ, 10 U.S.C. § 815, for aiding and abetting the appellant — regarding his concerns that he might face additional punishment. Finally, the TC contacted a defense-requested witness (B) and, in interviewing him, threatened and intimidated him by telling him he should be afraid to come to the trial site and talk with uniformed personnel because he would face a court-martial.

Ultimately, both the TC and the DC were replaced by other counsel before pleas were entered, the latter at the request of the appellant and the former because she had been transferred to another command. Record at 219. The CDC and newly detañed defense counsel moved to dismiss the charges as a result of prosecutorial misconduct arising primarily from the factual scenario set forth above. The military judge took extensive testimony on the issue3, entered findings, and ultimately denied the motion. In particular, after stating that “I want [677]*677to know if these witnesses feel they are intimidated in dealing with the defense and, if they are, I’m going to set it straight right now,” (Record at 83) the judge brought all but one of the witnesses, who could even remotely have been touched by the pretrial conduct of the TC, to the stand. He thoroughly established that the witnesses understood that they were to speak freely and truthfully to the appellant and his counsel without fear of repercussion. The military judge found that “because there has been absolutely no prejudice to the accused whatsoever in this ease, the motion [to dismiss for prosecutorial misconduct] is denied.” Record at 231. His other findings include the following:

1. Any requirement the TC placed on witnesses to notify command personnel of their whereabouts was designed to ensure control of the witnesses in the building or to explain sequestration rules to the witnesses regarding testimony and no prejudice resulted.
2. The TC’s order for appellant’s wife to leave the office used by civilian defense counsel was improper, but no prejudice resulted.
3. TC’s comments regarding civilian counsel’s inadequate preparation were not intended to influence the appellant’s decision as to employment of counsel and had no such effect.
4. TC’s comment in front of several witnesses that appellant “was trying to worm out of this trial” was improper, but was made out of frustration, not intending to influence and not actually influencing the witnesses to the detriment of the appellant.
5. TC’s legal counsel to witness [F] that, notwithstanding his having received nonjudicial punishment under Article 15, UCMJ, 10 U.S.C. § 815 as an aider and abettor to appellant, he could still be court-martialled for the same offense was not improper. [The military judge found that this was advice regarding the lack of a need for immunity.]
6. TC’s comments over the telephone to out-of-state defense witness [B], whose appearance was at first opposed by the Government, regarding his own possible court-martial through the Navy Reserve were improper and should not have been made, but no prejudice resulted.

Id. at 230-31.

A trial counsel acting on behalf of the United States and as an officer of the court is duty bound to protect an accused’s right to a fair trial and to ensure that justice is done. United States v. Freemen, 28 M.J. 789, 795 n. 8 (N.M.C.M.R.1989) (quoting Berger v. United States, 295 U.S. 78, 88, 55 S.Ct. 629, 633, 79 L.Ed. 1314 (1935)). The proper standard by which to review allegations of prosecutorial misconduct is whether they are so egregious as to deny the accused a fair trial. United States v. Hernandez, 779 F.2d 456 (8th Cir.1985); United States v. Sloan, 30 M.J. 741 (A.F.C.M.R.), petition denied, 32 M.J. 41 (C.M.A.1990).

Our first task is to determine whether counsel’s behavior amounted to prosecutorial misconduct. The specific instances of conduct by the TC found to be improper by the military judge fall into the broad category of attempting to limit defense access to witnesses through intimidating or improperly influencing the witnesses. The military judge found, and we agree, that the TC’s comment to defense witness (B) — to the effect that he would risk court-martial himself should he appear to testify at the appellant’s court-martial — was inappropriate.4 Whether or [678]*678not the comment was calculated to intimidate the witness, it is clear that it was likely to do so.5 Similarly, the TC’s off-hand comment to the assembled defense witnesses that the appellant was trying to “worm” his way out of court-martial was improper. It conveyed her negative, personal, and totally irrelevant opinion of the appellant to witnesses called to testify on his behalf and had the potential to improperly influence their testimony.

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Related

United States v. Meek
44 M.J. 1 (Court of Appeals for the Armed Forces, 1996)

Cite This Page — Counsel Stack

Bluebook (online)
40 M.J. 675, 1994 CMR LEXIS 411, 1994 WL 407240, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-meek-usnmcmilrev-1994.