United States v. Prasad

CourtCourt of Appeals for the Armed Forces
DecidedMay 19, 2020
Docket19-0412/AF
StatusPublished

This text of United States v. Prasad (United States v. Prasad) is published on Counsel Stack Legal Research, covering Court of Appeals for the Armed Forces primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Prasad, (Ark. 2020).

Opinion

This opinion is subject to revision before publication

UNITED STATES COURT OF APPEALS FOR THE ARMED FORCES _______________

UNITED STATES Appellee v. Krishil S. PRASAD, Airman First Class United States Air Force, Appellant No. 19-0412 Crim. App. No. 39003 Argued March 16, 2020—Decided May 19, 2020 Military Judges: Christina M. Jimenez (rehearing) and Shelly W. Schools For Appellant: David P. Sheldon, Esq. (argued); Major Mark J. Schwartz and Tami L. Mitchell, Esq. (on brief). For Appellee: Captain Jessica L. Delaney (argued); Lieuten- ant Colonel Brian C. Mason and Mary Ellen Payne, Esq. (on brief); Lieutenant Colonel G. Matt Osborn. Judge OHLSON delivered the opinion of the Court, in which Judges RYAN and SPARKS, joined. Chief Judge STUCKY filed a separate dissenting opinion in which Judge MAGGS joined. _______________

Judge OHLSON delivered the opinion of the Court. A general court-martial composed of officer and enlisted members convicted Appellant, contrary to his pleas, of two specifications of sexual assault and one specification of abu- sive sexual contact in violation of Article 120, Uniform Code of Military Justice (UCMJ), 10 U.S.C. § 920 (2012). The con- vening authority approved the adjudged sentence of a dishon- orable discharge, forfeiture of all pay and allowances, confine- ment for 30 months, and a reduction to the grade of E-1. Appellant was tried before our recent decisions held that is it impermissible to use Military Rule of Evidence (M.R.E.) 413 propensity evidence “as a mechanism for admitting evi- dence of charged conduct to which an accused has pleaded not guilty in order to show a propensity to commit the very same charged conduct.” United States v. Hills, 75 M.J. 350, 354 (C.A.A.F. 2016); see also United States v. Hukill, 76 M.J. 219, United States v. Prasad, No. 19-0412/AF Opinion of the Court

222 (C.A.A.F. 2017).1 However, the Hills and Hukill decisions were issued by the time Appellant's case was reviewed by the United States Air Force Court of Criminal Appeals. Citing our holding in those cases, the lower court held that the military judge erred in Appellant’s case by permitting evidence of the charged sexual offenses to be used as M.R.E. 413 propensity evidence and by instructing the members accordingly.2 United States v. Prasad, No. ACM 39003, 2017 CCA LEXIS 610, at *17, 2017 WL 4404557, at *6 (A.F. Ct. Crim. App. Sept. 5, 2017) (unpublished). Consequently, the Court of Criminal Appeals set aside the finding of guilt and the sentence as to Specification 1 of Additional Charge II3 and authorized a re- hearing. 2017 CCA LEXIS 610, at *33–34, 2017 WL 4404557, at *12. However, the Court of Criminal Appeals affirmed the remaining findings of guilt as to Specifications 1 and 3 of the Charge,4 finding the Hills error for those specifications to be harmless beyond a reasonable doubt. 2017 CCA LEXIS 610, at *33, 2017 WL 4404557, at *12.

1 We unequivocally reaffirmed the holding of Hills in United States v. Hukill, stating: [U]nder Hills, the use of evidence of charged conduct as M.R.E. 413 propensity evidence for other charged conduct in the same case is error, regardless of the forum, the number of victims, or whether the events are connected. Whether considered by members or a military judge, evidence of a charged and contested offense, of which an accused is presumed innocent, cannot be used as propensity evidence in support of a companion charged offense. 76 M.J. at 222. 2 Although the military judge did not have the benefit of our

Hills and Hukill decisions at the time of Appellant’s court-martial, appellate courts “apply the clear law at the time of appeal, not the time of trial.” United States v. Mullins, 69 M.J. 113, 116 (C.A.A.F. 2010) (citations omitted). 3 Specification 1 of Additional Charge II alleged that Appellant penetrated KG’s vulva with his penis without her consent. 4 Specification 1 of the Charge alleged that Appellant pene- trated KF’s vulva with his finger without her consent. Specification 3 of the Charge alleged that Appellant touched KF’s groin through the clothing with his penis without KF’s consent.

2 United States v. Prasad, No. 19-0412/AF Opinion of the Court

The convening authority subsequently dismissed Specifi- cation 1 of Additional Charge II, and ordered a rehearing for the purpose of sentencing Appellant on the affirmed findings, Specifications 1 and 3 of the Charge. United States v. Prasad, No. ACM 39003 (reh), 2019 CCA LEXIS 246, at *2, 2019 WL 2448247, at *1 (A.F. Ct. Crim. App. June 10, 2019) (un- published). A general court-martial consisting of officer mem- bers sentenced Appellant to a bad-conduct discharge, confine- ment for 210 days, forfeiture of all pay and allowances, and reduction to the grade of E-1. Id. The convening authority ap- proved the new sentence as adjudged. Id. We granted review to determine whether the Hills error with respect to Specifications 1 and 3 of the Charge is indeed harmless beyond a reasonable doubt.5 Although we openly acknowledge that this is a close issue, in light of the relative weakness of the Government’s case at trial, the military judge’s findings instructions, and trial counsel’s findings ar- gument, we hold that the Government has failed to meet its burden of proving that the Hills error in this case was harm- less beyond a reasonable doubt. I. Facts

Background Appellant was charged with committing numerous sexual offenses involving five different women.

5 The granted issue is: WHETHER THE AIR FORCE COURT ERRED IN ITS FIRST REVIEW OF APPELLANT’S CASE BY AFFIRMING THE FINDINGS OF GUILT FOR SPECIFICATIONS 1 AND 3 OF CHARGE I WHEN IT FOUND PREJUDICIAL ERROR AS A RESULT OF A HILLS VIOLATION. United States v. Prasad, 79 M.J. 323 (C.A.A.F. 2019) (order grant- ing review). Notably, the parties do not dispute that the propensity evidence and the military judge’s corresponding instructions were erroneous in light of Hills. Therefore, the only issue this Court must decide is whether the Hills error prejudiced Appellant.

3 United States v. Prasad, No. 19-0412/AF Opinion of the Court

The military judge ruled, and instructed the members, that the offenses alleged in the Charge,6 Additional Charge I,7 and Additional Charge II8 could be used as M.R.E. 413 pro- pensity evidence. Appellant was acquitted of all charges and specifications except Specification 1 of Additional Charge II, involving KG, and Specifications 1 and 3 of the Charge, in- volving KF. Evidence Presented at Trial The Government’s evidence at trial regarding the two specifications of which Appellant now stands convicted con- sisted of the testimony of KF and a pretext conversation be- tween KF and Appellant that was conducted using the Snap- chat messaging application. The Government did not introduce any physical or forensic evidence and did not pre- sent any corroborating witnesses. 1. Testimony of KF At trial, KF testified that on the evening of May 9, 2014, at Grand Forks Air Force Base, North Dakota, she encoun- tered Appellant in the hallway of their dormitory and greeted him with a hug. The two began talking and moved their con- versation into Appellant’s room. They sat on Appellant’s bed

6 The Charge included three specifications in violation of Article 120, UCMJ, 10 U.S.C. § 920. Specification 1 alleged that Appellant penetrated KF’s vulva with his finger without her consent. Specifi- cation 2 alleged that Appellant kissed KF’s breast without her con- sent. Specification 3 alleged that Appellant touched KF’s groin through the clothing with his penis without KF’s consent. 7 Additional Charge I included one specification in violation of Article 80, UCMJ, 10 U.S.C.

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Related

Chapman v. California
386 U.S. 18 (Supreme Court, 1967)
Mitchell v. Esparza
540 U.S. 12 (Supreme Court, 2003)
United States v. Mullins
69 M.J. 113 (Court of Appeals for the Armed Forces, 2010)
United States v. Wolford
62 M.J. 418 (Court of Appeals for the Armed Forces, 2006)
United States v. Kreutzer
61 M.J. 293 (Court of Appeals for the Armed Forces, 2005)
United States v. Hills
75 M.J. 350 (Court of Appeals for the Armed Forces, 2016)
United States v. Hukill
76 M.J. 219 (Court of Appeals for the Armed Forces, 2017)
United States v. Pollard
38 M.J. 41 (United States Court of Military Appeals, 1993)

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United States v. Prasad, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-prasad-armfor-2020.