United States v. RENTAS

CourtNavy-Marine Corps Court of Criminal Appeals
DecidedApril 30, 2026
Docket202500082
StatusPublished

This text of United States v. RENTAS (United States v. RENTAS) is published on Counsel Stack Legal Research, covering Navy-Marine Corps 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. RENTAS, (N.M. 2026).

Opinion

This opinion is subject to administrative correction before final disposition.

Before KISOR, GANNON, and FLINTOFT Appellate Military Judges

_________________________

UNITED STATES Appellee

v.

Joshua J. RENTAS Lance Corporal (E-3), U.S. Marine Corps Appellant

No. 202500082

Decided: 30 April 2026

Appeal from the United States Navy-Marine Corps Trial Judiciary

Military Judges: Cory A. Carver (Arraignment) Thomas R. Fricton (Trial and Entry of Judgment)

Sentence adjudged 2 December 2024 by a general court-martial tried at Camp Foster, Marine Corps Base Butler, Okinawa, Japan, consisting of a military judge sitting alone. Sentence in the Entry of Judgment: reduction to E-1, confinement for 36 months, forfeiture of all pay and allowances, and a dishonorable discharge.

For Appellant: Lieutenant Commander Christopher C. McMahon, JAGC Mr. Benjamin N. Young, Esq. United States v. Rentas, NMCCA No. 202500082 Opinion of the Court

For Appellee: Lieutenant Erin Bourneuf, JAGC USN Major Mary Claire Finnen, USMC

This opinion does not serve as binding precedent, but may be cited as persuasive authority under NMCCA Rule of Appellate Procedure 30.2.

PER CURIAM: Appellant was convicted, consistent with his pleas, of four specifications of possession of child pornography and one specification of distribution of child pornography in violation of Article 134 of the Uniform Code of Military Justice (UCMJ). 1 Appellant asserts two assignments of error (AOEs): (1) whether Ap- pellant’s pleas were improvident; and (2) whether trial defense counsel pro- vided ineffective assistance of counsel.

I. BACKGROUND

In accordance with a plea agreement, Appellant pleaded guilty to pos- sessing child pornography on four electronic devices: two laptop computers, an iPhone, and a separate external hard drive. He also pleaded guilty to distribu- tion of child pornography. 2 When he submitted his proposed plea agreement to the convening authority, Appellant attached a “letter of apology” explaining that he was sorry for possessing and distributing child pornography and ex- plaining how it had happened. 3 He had previously made a confession to Naval Criminal Investigative Service (NCIS) agents and consented to the search and seizure of his electronic devices. 4 Appellant’s providence inquiry was thorough and detailed. At one point, with respect to one of the specifications (Specification 2: possession of child pornography on the external hard drive), Appellant asserted that he had put

1 10 U.S.C. § 934.

2 R. at 20.

3 App. Ex. XI.

4 App. Ex. V.

2 United States v. Rentas, NMCCA No. 202500082 Opinion of the Court

the hard drive in “the trash can.” 5 Trial counsel immediately asked for a recess, which lasted approximately eight minutes. 6 After the recess, the providence inquiry continued and Appellant explained that by “trash” he meant that he had put the hard drive in a desk drawer that was “full of a bunch of trash.” 7 He also explained that he had transferred the data on the hard drive, including some of the child pornography files, onto a different laptop. 8 He planned to eventually get rid of the hard drive. 9 The military judge ultimately accepted his pleas, found him guilty of all five specifications, and sentenced him, pursu- ant to the specific sentence in the plea agreement: dishonorable discharge; con- finement for 36 months for each specification (all to be served concurrently); reduction to E-1; and forfeiture of all pay and allowances. 10

II. DISCUSSION

Appellant raises two related AOEs pursuant to United States. v. Grostefon: 11 (1) that his pleas were improvident because both his defense coun- sel and trial counsel pressured him during the recess into continuing to plead guilty, and therefore his guilty pleas were not voluntary; and (2) that his de- fense counsel was ineffective for failing to obtain the services of a digital foren- sic expert. 12 In support of his appeal, Appellant twice moved this Court to at- tach a post-trial declaration to the record. This Court denied Appellant’s Mo- tion to Attach, and further denied Appellant’s Motion to Reconsider this denial. We now reconsider our rulings and grant Appellant’s Motion to Attach.

5 R. at 46.

6 R. at 46.

7 R. at 49.

8 R. at 50.

9 R. at 50.

10 R. at 127. The military judge recommended that the convening authority sus- pend 6 months of confinement. Id. 11 12 M.J. 431 (C.M.A. 1982.)

12 See Appellant’s Brief.

3 United States v. Rentas, NMCCA No. 202500082 Opinion of the Court

A. Appellant’s pleas of guilty were not improvident. His assertion that his counsel and trial counsel placed undue pressure upon him during a recess to continue to plead guilty is without merit.

1. Standard of Review We review a military judge’s decision to accept a guilty plea for an abuse of discretion and questions of law arising from the guilty plea de novo. 13 An abuse of discretion occurs when there exists “something in the record of trial, with regard to the factual basis or the law, that would raise a substantial question regarding the appellant’s guilty plea.” 14 Put slightly differently, pursuant to Article 45, UCMJ, a guilty plea shall not be accepted if an accused, after a plea of guilty, sets up a matter inconstant with the plea, or if it appears that he has entered the plea improvidently, or through lack of understanding of its mean- ing and effect. 15 Thus, we apply the substantial basis test, looking at whether there is something in the record of trial, with regard to the factual basis or the law, that would raise a substantial question regarding an appellant’s guilty plea. If an accused sets up a matter inconsistent with the plea at any time during the proceeding, the military judge must either resolve the apparent in- consistency or reject the plea. 16 “A guilty plea shall not be accepted if it appears to be improvident.” 17 An affirmative defense to a charged offense would, by definition, constitute a matter inconsistent with a plea of guilty and a military judge must resolve the apparent inconsistency or reject the plea. 18 That said, not every mitigating statement requires further inquiry, and a military judge is not required to re- open a plea and inquire further where an accused raises the mere possibility of a defense. 19 But if a party sets up matter raising a possible defense, then the

13 United States v. Inabinette, 66 M.J. 320, 322 (C.A.A.F. 2008).

14 United States v. Hayes, 70 M.J. 454, 457 (C.A.A.F. 2012) (quoting Inabinette, 66

M.J. at 322). 15 10 U.S.C. § 845.

16 Rules for Courts-Martial 910(h)(2).

17 Article 45, UCMJ.

18 Hayes, 70 M.J. at 458; United States v. Mease, 57 M.J. 686, 690 (N-M. Ct. Crim.

App. 2022). 19 See United States v. Shaw, 64 M.J. 460 (C.A.A.F. 2007).

4 United States v. Rentas, NMCCA No. 202500082 Opinion of the Court

military judge is required to make further inquiry and resolve any apparent ambiguity or inconsistency. 20

2. Analysis We find no substantial question regarding Appellant’s guilty plea to Speci- fication 2. He alleges in his declaration that during the recess, trial counsel and his defense counsel both told him that he should “stick to the script” or else his plea deal would fall apart and he risked over 50 years of confinement. 21 He further states that he felt as if they were working against his interests. 22 He does not raise a coercion issue though.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Roe v. Flores-Ortega
528 U.S. 470 (Supreme Court, 2000)
United States v. Hayes
70 M.J. 454 (Court of Appeals for the Armed Forces, 2012)
United States v. Inabinette
66 M.J. 320 (Court of Appeals for the Armed Forces, 2008)
United States v. Shaw
64 M.J. 460 (Court of Appeals for the Armed Forces, 2007)
United States v. Phillippe
63 M.J. 307 (Court of Appeals for the Armed Forces, 2006)
Jae Lee v. United States
582 U.S. 357 (Supreme Court, 2017)
United States v. Murray
42 M.J. 174 (Court of Appeals for the Armed Forces, 1995)
United States v. Mease
57 M.J. 686 (Navy-Marine Corps Court of Criminal Appeals, 2002)
United States v. Grostefon
12 M.J. 431 (United States Court of Military Appeals, 1982)

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United States v. RENTAS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-rentas-nmcca-2026.