United States v. Pinkney

22 C.M.A. 595
CourtUnited States Court of Military Appeals
DecidedFebruary 22, 1974
DocketNo. 27,220
StatusPublished

This text of 22 C.M.A. 595 (United States v. Pinkney) is published on Counsel Stack Legal Research, covering United States Court of Military 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. Pinkney, 22 C.M.A. 595 (cma 1974).

Opinion

OPINION OF THE COURT

Duncan, Chief Judge:

Prior to the trial in this case, the accused submitted a request for discharge in lieu of court-martial under the provisions of Chapter 10, AR 635-200, April 19, 1972. This is an administrative procedure available to all Army personnel under criminal charges which permits them to be separated from the military service, possibly under other than honorable conditions, rather thán to be subjected to trial by court-martial for offenses against the Uniform Code of Military Justice. Only an accused can initiate the request for discharge, and the Government has no obligation to act favorably upon it because the right to refer criminal charges against the accused for trial by court-martial is reserved to the convening authority who may deny the request for discharge. Needless to say, an accused need not incriminate himself when he requests discharge in lieu of court-martial, and a convening authority does not necessarily express a personal opinion on guilt or innocence or on the appropriateness of any punishment other than- the requested discharge when he denies such a request. The discharge in lieu of court-martial plays an important, though minor, role in the disposition of criminal offenses in the military service. We do not conceive it to be our function to review the merits of the practice. Nevertheless, when an accused seeks to avail himself of this administrative means to dispose of the criminal charges against [597]*597him, no harm should come to him as a result of the failure to so resolve the case by administrative discharge rather than criminal trial.

The problem in this case was created when the military jury learned that the accused had unsuccessfully requested a discharge in lieu of court-martial. Because this court-martial was empowered to adjudge a punitive discharge as part of the sentence, the accused’s intentions with respect to his military service were obviously of interest to the court-martial members. After conviction, the accused took the stand to give evidence relevant to sentencing. His testimony included a brief recitation of his family and educational background, and his military assignments. Mention was also made of the fact that he ánd his co-accused had made restitution for the larceny involved in the case. Contrary to the typical allocution at a court-martial, no mention was made of a desire to complete a career in the Army or of a pledge to earn an honorable discharge if returned to duty. On cross-examination, however, the trial counsel led the accused into these areas by asking if he had ever wanted to get out of the service before his term of service expired, and whether he had always wanted an honorable discharge. When the accused answered that he had always wanted to finish his time and get an honorable discharge, the trial counsel impeached his testimony by questioning him about his request for a Chapter 10 discharge. Subsequently, in his argument to the court-martial before sentencing, the trial counsel referred to the accused’s lack of concern about staying in the Army and his willingness to accept an undesirable discharge. The trial defense counsel did not object to either the cross-examination or the argument of the trial counsel. No cautionary instructions about this matter were given by the military judge.

When this case was reviewed by the U. S. Army Court of Military Review, the court held that it was error for the trial counsel to interject the Chapter 10 action into the case. The Court of Military Review compared the trial counsel’s actions to informing a court-martial about a pretrial agreement, United States v Massie, 45 CMR 717 (ACMR 1972), or the concessions made in connection with a former attempt to plead guilty, United States v Daniels, 11 USCMA 52, 28 CMR 276 (1959), or the convening authority’s views on the seriousness of a case, United States v Crutcher, 11 USCMA 483, 29 CMR 299 (1960). These cases all held that it was error to inject these collateral matters into a trial. Nevertheless, the Court of Military Review declined to grant relief on the grounds that the trial defense counsel failed to object at trial to the cross-examination and argument of the trial counsel.

We granted review in this case on the following issue:

Whether the appellant was materially prejudiced by the trial counsel’s improper cross-examination during extenuation and mitigation in which the convening authority’s pretrial refusal to grant a discharge for the good of the service was made known to the court members, particularly in light of the trial counsel’s subsequent argument on sentence which made reference to the request for administrative discharge and also in light of the military judge’s failure to provide any limiting instruction regarding the court members’ consideration of the matter.

On the underlying issue of the trial counsel’s error in introducing the subject of the administrative discharge request into his cross-examination of the accused before sentencing and then including this topic in his presentencing argument, we are in accord with the decision of the Court of Military Review. We agree that "[a] rule which attaches the possibility of future detriments to an accused’s entering into negotiations about the disposition of charges is not a good rule for administering criminal law.” An accused and his defense counsel who search out administrative alternatives to trial for the disposition of criminal charges, or who bargain in good faith about concessions in return for a plea of guilty, should be assured that their pretrial legal maneuvers will not later be used against the accused for any purpose. So long as military law makes provisions for plea bargaining and dis[598]*598charges in lieu of court-martial, the legitimate use by the defense of these parts of military law providing alternatives to trial is antithetical to any attempt by the prosecution to turn their use against the accused.

Normally, at a trial where the prosecution attempts to use the unsuccessful pretrial legal moves of the defense against an accused, the defense counsel should be expected to protect the legal interests of the accused by requesting the trial judge to stop the prosecution from presenting such evidence to the jury and to caution the jury against considering such evidence as they may have heard. In this case, however, the trial defense counsel did not object to the trial counsel’s cross-examination of the accused or to his argument before sentencing. Because of this inaction by trial defense counsel, the Court of Military Review granted no relief to the accused from the error of presenting his pretrial request for an administrative discharge to the military jury which sentenced him. The Court of Military Review applied the ordinary rule that "failure to object at trial does away with any necessity for military appellate courts to take cognizance of an error.” It is this ruling that is principally at issue before this Court.

The appellant has advanced three arguments why the doctrine of waiver should not be applied to the defense counsel’s failure to object at trial to the prosecution raising the matter of the request for discharge in lieu, of trial. First, the argument is made that the trial counsel’s actions indirectly informed the court-martial of the convening authority’s desire that the accused should be sentenced to "confinement and punitive elimination” from the service. If so, command influence or command control would have been interjected into the case, and as a consequence waiver of the error would be inappropriate under United States v Lackey, 8 USCMA 718, 25 CMR 222 (1958).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Fowle
7 C.M.A. 349 (United States Court of Military Appeals, 1956)
United States v. Lackey
8 C.M.A. 718 (United States Court of Military Appeals, 1958)
United States v. Daniels
11 C.M.A. 52 (United States Court of Military Appeals, 1959)
United States v. Crutcher
11 C.M.A. 483 (United States Court of Military Appeals, 1960)
United States v. Ryan
21 C.M.A. 9 (United States Court of Military Appeals, 1971)

Cite This Page — Counsel Stack

Bluebook (online)
22 C.M.A. 595, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-pinkney-cma-1974.