United States v. PARKS

CourtNavy-Marine Corps Court of Criminal Appeals
DecidedJune 27, 2025
Docket202300243
StatusPublished

This text of United States v. PARKS (United States v. PARKS) 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. PARKS, (N.M. 2025).

Opinion

This opinion is subject to administrative correction before final disposition.

Before DALY, KISOR, and de GROOT Appellate Military Judges

_________________________

UNITED STATES Appellee

v.

Ramaje T. A. PARKS Aviation Ordnanceman Airman Apprentice (E-2), U.S. Navy Appellant

No. 202300243

Decided: 27 June 2025

Appeal from the United States Navy-Marine Corps Trial Judiciary

Military Judges: Donald R. Ostrom (arraignment and motions) D. Monique Brown (trial)

Sentence adjudged 8 July 2023 by a general court-martial tried at Na- val Station, Norfolk, Virginia, consisting of officer and enlisted mem- bers. Sentence in the Entry of Judgment: no punishment.

For Appellant: Lieutenant Jesse B. Neumann, JAGC, USN

For Appellee: Lieutenant K. Matthew Parker, JAGC, USN Major Mary Claire Finnen, USMC United States v. Parks, NMCCA No. 202300243 Opinion of the Court

Chief Judge DALY delivered the opinion of the Court, in which Senior Judge KISOR and Judge de GROOT joined.

This opinion does not serve as binding precedent, but may be cited as persuasive authority under NMCCA Rule of Appellate Procedure 30.2.

DALY, Chief Judge: Appellant was convicted, contrary to his pleas, of one specification of breach of restriction and one specification of willfully disobeying a superior commis- sioned officer, in violation of Articles 87b and 90, Uniform Code of Military Justice (UCMJ) respectively. 1 Appellant asserts four assignments of error (AOEs): (1) whether the evi- dence is legally sufficient to support Appellant’s conviction for breach of re- striction; (2) whether the evidence is legally sufficient to support Appellant’s conviction for willfully disobeying a superior commissioned officer; (3) whether Appellant’s conviction is legally sufficient when the order Appellant allegedly violated was never determined to be lawful by the military judge; (4) whether Appellant’s trial defense counsel were ineffective in failing to make obvious, valid objections to evidence of essential elements. We find no prejudicial error and affirm.

I. BACKGROUND

Appellant’s pregnant girlfriend, K.L., reported multiple incidents of domes- tic violence. Based on these allegations, Appellant’s commanding officer issued a Military Protective Order (MPO). 2 The MPO stated that Appellant, “is re- strained from initiating any contact or communication with [K.L.]” and “shall remain at all times and places at least 100 feet away from [K.L.] . . . or [K.L.’s] household including, but not limited to, residence and workplaces.” 3

1 10 U.S.C. § 887b and § 890.

2 Pros. Ex. 10.

3 Pros. Ex. 10 at 2.

2 United States v. Parks, NMCCA No. 202300243 Opinion of the Court

The ship’s legalman chief petty officer (LNC) testified that he reviewed the MPO with Appellant. Appellant’s leading chief petty officer was present as well. Both chiefs answered Appellant’s questions. It took forty-five minutes to complete the review. Appellant signed the MPO. It was admitted into evidence without objection. 4 K.L. testified that she and Appellant continued to exchange text messages and see each other while the MPO was in place. She also testified she believed she was “able to contact him . . . but he [was] not allowed to contact me.” 5 K.L. further explained how she knew it was Appellant on the phone because she “memorized [Appellant’s phone] number and that’s the emoji I put on his con- tact card.” 6 The Government admitted the screenshots of the text messages and Appellant’s contact card. 7 Defense counsel did not object to the screen- shots. 8 The Government also admitted five voicemails Appellant left for K.L. 9 De- fense counsel did not object to the voicemails. 10 K.L. also testified that on mul- tiple occasions she answered phone calls from Appellant. 11 She answered those calls because she did not have the phone numbers he called from saved on her phone. 12 Additionally, K.L.’s roommate testified that while the MPO was in place, Appellant showed up twice at the residence she shared with K.L. 13 The first time, she saw Appellant through a peephole in the front door and the next month, on 22 December 2022, when Appellant broke a window to enter the

4 R. 724.

5 R. at 570.

6 R. at 503.

7 R. at 502; Pros. Ex. 2.

8 R. at 502.

9 R. at 506-07, 534-35; Pros. Ex. 3, 6-9.

10 R. at 507, 535.

11 R. at 508, 533.

12 R. at 508, 533.

13 R. 789-92.

3 United States v. Parks, NMCCA No. 202300243 Opinion of the Court

residence. 14 In the second instance, the roommate testified Appellant borrowed her phone and called K.L. 15 Appellant was awarded nonjudicial punishment for violating the MPO. 16 Appellant‘s punishment included sixty days of restriction, with thirty days sus- pended. 17 The LNC testified that because their ship was a pre-commissioning unit, Sailors would serve restriction on other ships. The restriction orders is- sued to Appellant stated, “[y]ou understand that you are in a restricted status and you are restricted to the limits of USS JOHN C. STENNIS (CVN 74).” 18 The LNC did not go over the restriction orders with Appellant but affirmed someone else did. The LNC stated he signed the restriction orders “by direc- tion” and “then [Appellant] and also a witness signed it.” 19 The Government admitted the restriction orders into evidence without objection. 20 The assistant restriction petty officer aboard USS Stennis testified that Ap- pellant checked in and was instructed on the restriction process and proce- dures. On 22 December 2022, the assistant restriction petty officer received a report of a missing restricted Sailor. The restricted Sailors were directed to report to their muster area. All reported except Appellant. The same night, the watch commander reported to the assistant restriction petty officer that Ap- pellant had used a phone designated for restricted personnel and the number last called was K.L.’s phone number. At trial, the members convicted Appellant of breach of restriction and will- fully disobeying a superior commissioned officer. They acquitted Appellant of communicating a threat against K.L. and seven specifications of domestic vio- lence against K.L. The members sentenced Appellant to no punishment. Additional facts necessary to resolve Appellant’s AOEs are included in the discussion below.

14 R. 791-93.

15 R. at 794.

16 R. at 891-92.

17 Pros. Ex. 11.

18 Pros. Ex. 11.

19 R. at 731.

20 R. at 732; Pros. Ex. 11.

4 United States v. Parks, NMCCA No. 202300243 Opinion of the Court

II. DISCUSSION

A. Appellants convictions are legally sufficient.

1. Law We review issues of legal sufficiency de novo. 21 “The test for legal sufficiency is whether, after viewing the evidence in the light most favorable to the prose- cution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” 22 “[T]he term ‘reasonable doubt’ does not mean that the evidence must be free from any conflict.” 23 The test for legal sufficiency “gives full play to the responsibility of the trier of fact fairly to re- solve conflicts in the testimony, to weigh the evidence, and to draw reasonable inferences from basic facts to ultimate facts.” 24 “[I]n resolving questions of legal sufficiency, [an appellate court is] bound to draw every reasonable inference from the evidence of record in favor of the prosecution.” 25 Thus, “[t]he standard for legal sufficiency involves a very low threshold to sustain a conviction.” 26 “[T]he [G]overnment is free to meet its burden of proof with circumstantial evidence.” 27

2.

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