United States v. Petitti

14 M.J. 754, 1982 CMR LEXIS 859
CourtU.S. Army Court of Military Review
DecidedSeptember 21, 1982
DocketSPCM 17403
StatusPublished

This text of 14 M.J. 754 (United States v. Petitti) is published on Counsel Stack Legal Research, covering U.S. Army 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. Petitti, 14 M.J. 754, 1982 CMR LEXIS 859 (usarmymilrev 1982).

Opinion

OPINION OF THE COURT

McKAY, Judge:

This case is before the Court for mandatory review pursuant to Article 66, Uniform Code of Military Justice, 10 U.S.C. § 866 (1976). The only issue presented is whether there is jurisdiction over an offense of communication of a threat between two service members that occurred off-post and in the civilian community. We hold there is jurisdiction.

The appellant, Specialist Four Petitti, was convicted, contrary to his pleas, at a special-court martial bench trial of using and selling marihuana and communicating a threat. The convening authority reduced the adjudged sentence of confinement and forfeiture of $365 pay per month from five months to three months for each, and otherwise approved the sentence that also included reduction to Private E-l and a bad-conduct discharge. In his brief to this Court, the appellant asserts the military judge erred to his substantial prejudice by denying his motion to dismiss the communication of a threat offense for lack of subject matter jurisdiction.

The facts necessary to resolve the asserted error establish that on 2 October 1981, Specialist Four Russell K. Lewis, while acting as a confidential informant for military police authorities, made a controlled buy of marihuana from the appellant in his government assigned family quarters at Fort Irwin, California, a military installation. While present in the appellant’s quarters, Lewis observed the appellant smoke marihuana. Lewis turned over the marihuana he purchased from the appellant to the military police and reported the appellant’s use of marihuana. Later that afternoon, military police authorities raided the appellant’s quarters.1 At the outset of the raid, a copy of the authorization to search his quarters, with supporting information, was given to the appellant. From the information thus provided, it could be deduced that Lewis had informed the police about the appellant’s drug activities. On 3 October 1981, Specialist Lewis, for personal reasons, went to the home of Sergeant Brewer, another service member, located approximately five miles east of Barstow, California. Barstow is the nearest town to Fort Irwin and is located some thirty-seven miles southwest of that military post. There is virtually nothing but desert between the two.2 There were other military personnel present at Sergeant Brewer’s and, soon, the appellant arrived with another soldier for a social visit. Shortly after his arrival, the appellant confronted Lewis with his copy of the search authorization. When Lewis denied knowing anything about it, an argument developed during which the appellant threatened Lewis as indicated in the communication of a threat specification.3 The incident was quieted by [757]*757Sergeant Brewer, and Lewis, who had become afraid, departed for a United States Marine Base at Barstow where he identified himself to authorities and asked for protection.

The appellant argues that there is no jurisdiction over the threat offense because it did not occur on a military installation but off-post away from military control, within the territory of the United States, and during peacetime. He also points out that there was no connection between his military duties and the offense, nor was he engaged in the performance of any duty relating to the military. In short, he contends there is no jurisdiction because the offense is not “service-connected”.

Without question there must be service-connection for a court-martial to have jurisdiction over an offense that occurs in the United States during peacetime. O’Callahan v. Parker, 395 U.S. 258, 89 S.Ct. 1683, 23 L.Ed.2d 291 (1969); United States v. Borys, 18 U.S.C.M.A. 547, 40 C.M.R. 259 (1969). Moreover, while status as a member of the armed forces is a constitutional predicate to the exercise of court-martial jurisdiction over the person, United States ex rel. Toth v. Quarles, 350 U.S. 11, 76 S.Ct. 1, 100 L.Ed. 8 (1955), service-connection cannot be established solely because of it. United States v. Hedlund, 2 M.J. 11 (1976). Most offenses occurring on--post and between service members, or against property thereon, however, are service-connected and there is court-martial jurisdiction. Relford v. Commandant, 401 U.S. 355, 91 S.Ct. 649, 28 L.Ed.2d 102 (1971). With respect to those offenses by service members that are committed off-post, the Supreme Court has provided twelve factors by which the offense should be analyzed for service-connection. Relford v. Commandant, supra 401 U.S. at 365, 91 S.Ct. at 655. In the past, the analytical process has been required to be completed on a case-by-case, offense-by-offense basis. United States v. Alef, 3 M.J. 414 (C.M.A.1977); United States v. Hedlund, supra. Recently, however, applying the Relford factors to a situation where the accused was charged with the off-post sale of drugs, the Court of Military Appeals concluded “that almost every involvement of service personnel with the commerce in drugs is ‘service connected’.” United States v. Trottier, 9 M.J. 337, 350 (C.M.A.1980). We believe that unlawful interference with military police law enforcement activities against illegal on-post drug trafficking is involvement “with the commerce in drugs” as that term is used in Trottier. Should we hold otherwise, the determination of court-martial jurisdiction by the Court in Trottier would have little meaning. For if the military police are unable to carry out normal and legitimate police investigation and procedures without illegal interference in drug cases, military personnel who choose thus to break the law are not likely to be brought before courts-martial for trial.

The use of confidential informants is, in our opinion and experience, not only common, but it is one of the more effective means that military police authorities have in detecting and stopping the drug traffic on military installations in general and troop barracks in particular. Cf., United States v. Garcia, 1 M.J. 26 (C.M.A.1975); United States v. Kelker, 50 C.M.R. 410 (A.C. M.R.1975); United States v. Heitmann, 46 C.M.R. 1242 (A.F.C.M.R.1973). If their effective employment is to continue, military authorities must be able to accord individual informants not only physical protection, but also protection through the legal process. They must therefore be able to prosecute offenses committed against them by military personnel when those offenses arise from or are closely connected to an informant’s drug enforcement activities. In the absence of that authority, the adverse impact upon military discipline, law enforcement on military installations and [758]*758military readiness is real, foreseeable and incalculable.

The threat offense in this case arose as a direct result of Lewis’ role as a confidential informant with respect to the appellant’s illegal sale and use of marihuana on a military installation on the preceding day.

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Related

United States Ex Rel. Toth v. Quarles
350 U.S. 11 (Supreme Court, 1955)
O'Callahan v. Parker
395 U.S. 258 (Supreme Court, 1969)
United States v. Borys
18 C.M.A. 547 (United States Court of Military Appeals, 1969)
United States v. Garcia
23 C.M.A. 403 (United States Court of Military Appeals, 1975)
United States v. Hedlund
2 M.J. 11 (United States Court of Military Appeals, 1976)
United States v. Valles-Santana
2 M.J. 1049 (U.S. Army Court of Military Review, 1976)
United States v. Alef
3 M.J. 414 (United States Court of Military Appeals, 1977)
United States v. Trottier
9 M.J. 337 (United States Court of Military Appeals, 1980)

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Bluebook (online)
14 M.J. 754, 1982 CMR LEXIS 859, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-petitti-usarmymilrev-1982.