United States v. Private ADAM R. MAAS

CourtArmy Court of Criminal Appeals
DecidedJanuary 13, 2026
Docket20230090
StatusUnpublished

This text of United States v. Private ADAM R. MAAS (United States v. Private ADAM R. MAAS) is published on Counsel Stack Legal Research, covering Army 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. Private ADAM R. MAAS, (acca 2026).

Opinion

UNITED STATES ARMY COURT OF CRIMINAL APPEALS Before FLOR, POND, and STEELE Appellate Military Judges

UNITED STATES, Appellee v. Private El ADAM R. MAAS United States Army, Appellant

ARMY 20230090

Headquarters, Defense Language Institute Foreign Language Center Jessica Conn, Military Judge (arraignment) Robert E. Murdough, Military Judge (motions hearing and trial) Lieutenant Colonel Yvonne L. Sallis, Staff Judge Advocate

For Appellant: Colonel Philip M. Staten, JA; Lieutenant Colonel Autumn R. Porter, JA; Lieutenant Colonel Mitchell D. Herniak, JA; Captain Matthew S. Fields, JA (on brief).

For Appellee: Colonel Richard E. Gorini, JA; Lieutenant Colonel Jonathan P. Rabell, JA; Major Justin L. Talley, JA (on brief).

13 January 2026

MEMORANDUM OPINION

This opinion is issued as an unpublished opinion and, as such, does not serve as precedent

POND, Senior Judge:

An enlisted panel, sitting as a general court-martial, found appellant guilty, contrary to his pleas, of one specification of sexual assault without consent and two specifications of abusive sexual contact, in violation of Article 120, Uniform Code of Military Justice, 10 U.S.C. § 920 [UCMJ]. The military judge sentenced appellant to a dishonorable discharge, forty months of confinement, and forfeiture of all pay and allowances.

On appeal before this court, appellant argues his convictions warrant reversal because the military judge erroneously included in his instructions that a "sleeping, unconscious, or incompetent person cannot consent," which was an MAAS - ARMY 20230090

uncharged theory of criminal liability. In light of our superior court's decision in United States v. Mendoza, 85 M.J. 213 (C.A.A.F. 2024), we agree that the instruction was in error but conclude the error was harmless beyond a reasonable doubt and affirm.

BACKGROUND The Sexual Assault

The 19-year-old appellant and the 17-year-old victim were friends and fellow enlisted Soldiers who had just successfully completed their initial phase of Advanced Individual Training ( AIT) together at the Presidio of Monterey in fall of 2021. For the first time, appellant, the victim, and their friends were able to request a four-day pass, a privilege they had not yet been granted, which allowed them to leave the barracks, leave post, and not have to report to formations during the upcoming Thanksgiving weekend. Appellant booked a hotel room in downtown Monterey at the Candle Bay Inn. Similarly, the victim booked a room with another female Soldier, PFC , at the nearby Sand Dollar hotel. The day after Thanksgiving, appellant texted the victim and another friend, Private , to come hang out with him at his hotel. The victim took an Uber to appellant's hotel room where she spent the day drinking, talking, and watching television with appellant, Private , and another Soldier. Private and the other Soldier did not have authorized passes, and so they returned to post before the 2100 curfew. The victim, however, decided to stay. She wanted to continue having fun, and PFC was spending time with her boyfriend in their room at the Sand Dollar. She also felt it would not be smart to take an Uber back to her hotel alone, at night, after she had been drinking. The victim slept in one bed. Appellant slept in the other. When asked if she had any concerns staying the night with appellant, the victim testified, "no ... we were friends." She saw appellant as a "battle buddy," meaning they would "protect one another" and "keep each other safe."

The next morning, the victim and appellant ordered McDonald's and extended appellant's hotel room for another night. The victim split the cost of the room with appellant, so that there would be no expectation that he was doing something special for her. Private returned around 1100, and the three of them once again drank, talked, and watched television in appellant's hotel room throughout the day. At around 1800 or 1900 hours, Private asked appellant to step outside. Appellant complied and smoked a cigarette. While he was gone, the victim and Private had consensual sex. Outside, appellant briefly saw the victim and Private through the hotel window. The victim testified that while she had been drinking that afternoon, she was "still feeling normal"­ not "nauseous or anything."

2 MAAS - ARMY 20230090

Private asked the victim if she wanted to come back to post with him in an Uber but she declined, not wanting to walk the ten to fifteen minutes from the gate to the barracks. After appellant returned from smoking a cigarette, the victim went into the bathroom. Private and appellant stepped outside to talk. Appellant asked Private if "it was his turn to go at it." Private told appellant "that's not a good idea ...I don't think she sees you like that." The victim emerged from the bathroom and lay on the bed but moved to the floor because she began feeling nauseous. She went back into the bathroom because she felt like she might vomit. Private who once again had curfew, took an Uber and returned to post. Before he left, Private observed that the victim seemed "tired, a bit drunk." The victim testified that at some point-either before or after she had consensual sex with Private -appellant was mixing vodka and cranberry juice drinks .of which she had three to four, but she could not remember the exact order of things.

What transpired next varies significantly between the testimonial accounts of the victim and appellant at trial. The victim testified she did not remember how she got from the bathroom to the bed but awoke, clothed, on top of appellant who grabbed her hips and began moving her back and forth on top of him. The victim testified she was feeling confused and scared and was physically unable to move or speak because she was afraid. She lay limp with her eyes closed. Appellant got up at a certain point, stating, "This is a bad idea. I'm so drunk. I shouldn't do this." The victim testified she was unable to get up and leave out of fear-"it happens when I wake up and I'm afraid. I just -­ flight or freeze, I can't move." Appellant returned to the bed and rolled her back and forth to touch her buttocks while she lay on her stomach and then rolled her on her back to put his hand up her shirt to touch her breasts and down her pants to touch and penetrate her vagina with his finger. Appellant then manipulated her limp body to pull her face down on the bed so that her legs were dangling off the edge, pulled her jeans down, and penetrated her vagina with his penis. The victim testified she was still limp, could not move, and felt "violated, afraid, angry " because she could not do anything. The victim also testified that she did not consent to any of the sexual acts with appellant and at no point indicated that she consented to appellant's touching of her. "I thought we were friends. I didn't agree to this. I didn't say this could happen. I didn't say it was okay ..."

Appellant's version of events was different. He testified that when the victim emerged from the bathroom, she embraced him and they began kissing passionately. They kissed each other's necks and appellant gave the victim a hickey, which was later noted on the victim's sexual assault examination.1 The victim then leaned into appellant causing him to fall backwards onto the bed

1 Private did not recall giving the victim hickeys.

3 MAAS - ARMY 20230090

with the victim lying on top of him. Appellant testified the victim initiated and actively participated in the sexual acts not once but twice. First, she did so by removing her jeans from one leg,straddling appellant,and moving her underwear to the side.

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United States v. Private ADAM R. MAAS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-private-adam-r-maas-acca-2026.