United States v. RENE ALFARO

CourtArmy Court of Criminal Appeals
DecidedSeptember 30, 2025
Docket20220282
StatusUnpublished

This text of United States v. RENE ALFARO (United States v. RENE ALFARO) 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. RENE ALFARO, (acca 2025).

Opinion

UNITED STATES ARMY COURT OF CRIMINAL APPEALS

Before POND, MORRIS, and FLEMING Appellate Military Judges

UNITED STATES, Appellee v. Sergeant RENE D. ALFARO United States Army, Appellant

ARMY 20220282

Headquarters, Eighth Army Christopher E. Martin, Military Judge Colonel Rebecca K. Connally, Staff Judge Advocate

For Appellant: Captain Matthew S. Fields, JA; Robert A. Feldmeier, Esquire (on brief); Major Matthew S. Fields, JA; Robert A. Feldmeier, Esquire (on reply brief).

For Appellee: Colonel Christopher B. Burgess, JA; Colonel Jacqueline J. DeGaine, JA; Major Justin L. Talley, JA; Captain Stewart A. Miller, JA (on brief).

30 September 2025

This opinion is issued as an unpublished opinion and, as such, does not serve as precedent.

MORRIS, Senior Judge:

A military judge, sitting as a general court-martial, convicted appellant, contrary to his pleas, of one specification of violating a lawful general regulation and three specifications of sexual assault, in violation of Articles 92 and 120, Uniform Code of Military Justice, 10 U.S.C. §§ 892, 920 [UCMJ]. The military judge sentenced appellant to a dishonorable discharge, confinement for twenty-four months, and reduction to the grade of E-3.

Appellant raises six assignments of error; two assignments of error in his original brief, two additional assignments of error in a supplemental brief filed under seal, and two supplemental assignments of error alleging appellate post-trial processing delay and requesting further review in light of the Court of Appeals for the Armed Force’s [CAAF] decision in United States v. Mendoza, 85 M.J. 213 (C.A.A.F. 2024). Appellant’s assignments of error concerning the Military Rule of ALFARO — ARMY 20220282

Evidence [Mil. R. Evid.] 513 issue, Mendoza, and appellate post-trial processing delay warrant discussion, but no relief.!

BACKGROUND

At the time of the incident, appellant was a noncommissioned officer stationed at Camp Humphreys, Republic of Korea. The victim was appellant’s direct subordinate who had arrived in Korea approximately two weeks prior to the sexual assault for which appellant was charged and convicted. On the night of assault, the victim arrived at appellant’s barracks room with another male soldier to conduct her initial counseling. Because she was also celebrating her twenty-first birthday, she brought a bottle of vodka with her, which she had already begun to consume. The other male soldier and appellant each drank a small amount of the alcohol. After drinking a large amount of the bottle, the victim, who was suffering the effects of intoxication, started behaving strangely and dancing seductively. She then climbed into appellant’s bed and fell asleep. Shortly thereafter she woke up and vomited on appellant’s floor and fell back to sleep. The next time she woke up, she slid out of appellant’s bed and through her vomit on the floor. Appellant helped her into the shower and left her there. The victim fell multiple times while in the shower. Appellant checked on the victim and sent the other soldier to the victim’s room to get her a change of clothes. After returning with the victim’s clothes, the soldier continued to help clean up the victim’s vomit. Sometime later, the victim came out of the bathroom wearing a towel and climbed into appellant’s recliner, before transitioning back into appellant’s bed to sleep. With the victim asleep, appellant and the other soldier continued to talk about the military before the other soldier retired to his own barracks room across the hall. Before the soldier left, appellant told him he planned to sleep in his chair and would take care of the victim.

Approximately twenty minutes after he left, the other soldier heard appellant’s door open and shut and assumed the victim was returning to her barracks room. While it is not clear if that was in fact the victim leaving or not, the victim testified that during the time she remained in the room, she was awakened by painful penetrations of her vagina three separate times. The first penetration of her vagina was with an unknown object, to which she responded by trying to move away, prompting appellant to tell her to take another shower. She complied and returned to his bed and was awakened by appellant penetrating her vagina for a second time, this time, with his finger. The victim tried to leave again but, due to her intoxicated state, was unable to locate her clothes and remove herself from the bed. After she awoke a third time by a vaginal penetration with appellant’s finger, the victim located her clothes and left the room. At trial, when pressed by trial defense counsel

' We have given full and fair consideration to the remaining matters personally raised by appellant pursuant to United States v. Grostefon, 12 M.J. 431 (C.M.A. 1982), and find them to be without merit. ALFARO — ARMY 20220282

about her memory of the sexual assault, the victim testified that at all times she was aware of and remembered the sexual assaults in appellant’s barracks room.

After leaving appellant’s room, the victim immediately called her boyfriend, another soldier who was stationed in the United States. Her boyfriend was initially angry with her because he believed she put herself in “a bad situation.” The victim then told her cousin, who after listening to what occurred, told her she was a victim. The next morning, the victim went to breakfast with appellant and the soldier from the night before. Also, later this same day, appellant sent a text message to the victim stating, “Hey, wanted to apologize to you ‘bout last night and being so touchy with you.” He followed up with, “Besides that, great conversation, though, lol.” About a month later, while the victim was spending time drinking alcohol with appellant and the same male soldier, the victim testified that appellant swiped his hand over her vaginal area, prompting her to file a restricted sexual assault report. Over the course of the next ten months, the victim continued to communicate personally and professionally with appellant in an attempt to cope with and normalize the incident. Ultimately, she decided to switch her report to unrestricted. The government subsequently charged appellant with sexual assault and violating the Army’s regulation prohibiting undue familiarity between noncommissioned officers and junior enlisted soldiers, including the victim.

Prior to trial, defense filed a motion to compel discovery of the victim’s behavioral health appointment history, prescriptions, and mental health diagnosis to assist with defense preparation. In their motion, defense counsel asserted the requested discovery was not privileged and did not fall under the protections of Mil. R. Evid. 513. Both the government and the victim’s Special Victims’ Counsel (SVC) filed responses requesting the military judge deny the defense request, arguing the request was overly broad and did not identify how the information was relevant to the defense preparation. The SVC’s response also explicitly stated the victim was invoking her psychotherapist-patient privilege.” In a written ruling after a closed hearing on the issue, the military judge concluded that mental health appointment records, diagnoses, and prescriptions were not privileged under Mil. R. Evid. 513 and ordered the government to provide the following for in camera review: (1) any records of AV1’s mental health diagnoses from the time of her entry on active duty through July 2020 and (2) any records of antidepressant medications prescribed to AV 1 in the year before the sexual assault.

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United States v. RENE ALFARO, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-rene-alfaro-acca-2025.